Local Development Framework Consultation

0.0 Whole Document

Yes

Question 1 - Test of Legal Compliance
Natural England broadly supports the Land Allocations Development Plan Document – Proposed Submission Document and considers that it meets the first test of soundness, i.e. that it is legally compliant.

NO, I do not wish to participate at the oral examination

Question 3 - Taking part in the Examination
Please note that while Natural England does not wish to appear at the Examination in support of their representations, notifications at the point of submission, publication of the recommendations of the planning inspector and adoption of the DPD are requested.
We hope that these comments will be of assistance to in your progression of the four documents. For
any correspondence or queries relating to this consultation only, please contact Mr Jamie Robert Melvin using the details set out below. For all other correspondence, please use the address at the top of the letter or email consultations@naturalengland.org.uk.
Yours faithfully,

Please notify me

2.23

No

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.

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England?s letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

Section 2 Land Allocations
To which part of the South Lakeland District Council Land Allocation DPD does this representation relate?
Paragraph No: 2.23: How do we decide which sites should be developed and when?
Biodiversity is a core component of sustainable development. All local authorities and other public authorities have a duty to have regard to the conservation of biodiversity in exercising their functions. The duty is set out in Section 40 of the Natural Environment and Rural Communities (NERC) Act 2006 and states that: “Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity”.
The importance of this duty in relation to the site allocations should be taken fully into consideration, reflecting the importance placed on minimising impacts on biodiversity and providing net gains in biodiversity where possible, and the requirement to plan positively for the “creation, protection, enhancement and management of networks of biodiversity and green infrastructure” as set out in the NPPF.
Change(s) considered necessary to make the South Lakeland District Council Land Allocations DPD sound:
Reference to the duty would be appropriate in respect to describing the detailed criteria by which sites have been assessed (paragraph 2.23).

NO, I do not wish to participate at the oral examination

Please notify me

2.25

No

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.

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England's letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

To which part of the South Lakeland District Council Land Allocation DPD does this representation relate?
Paragraph No: 2.25: Managing Flood Risk
As has been raised previously, Natural England and the Environment Agency are working to restore natural functioning of rivers which may involve the removal of artificial river bank modifications to allow recovery of natural geomorphological processes and river function, where this does not conflict with flood defences. This may involve for example, the removal of artificial blockstone revetments in favour of soft engineering, and in some cases reconnecting the river with the floodplain.
While the Core Strategy contains a policy which seeks to direct development away from areas at high risk of flooding, the implications of river restoration also need to be considered in relation to development proposals near and/or adjacent to the River Kent SAC.
Change(s) considered necessary to make the South Lakeland District Council Land Allocations DPD sound:
Natural England consider that paragraph 2.25 should be amended by inserting the following text at the end of this paragraph:
‘Natural England and the Environment Agency are working to restore the natural functioning of rivers. This may involve the removal of artificial river bank modifications, where feasible, to allow recovery of natural processes and river functioning, where this does not conflict with flood defences. The implications of river restoration need to be considered in relation to development proposals located near and/or adjacent to the River Kent Special Area of Conservation (SAC).’

NO, I do not wish to participate at the oral examination

Please notify me

2.64

No

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.

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England's letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

Paragraph No: 2.64 Policy/Site No: Policy LA1.10: Existing Green Infrastructure
Natural England?s view is that greenspaces should be conserved and enhanced wherever possible. If, exceptionally, small areas are developed or partly developed, compensatory provision of greenspace and enhancement of spaces ought to be provided elsewhere. Wherever development is proposed, the proposals should take full advantage of opportunities to provide new habitat and accessible natural greenspace, as well as conserving and enhancing existing habitat.
Change(s) considered necessary to make the South Lakeland District Council Land Allocations DPD sound:
Natural England considers that paragraph 2.64 should be amended as follows:
„Where possible, opportunities will be taken to enhance and increase the quality and value of all three types of open space. There is a presumption that these spaces will not be developed except in very exceptional circumstances. Wherever development is proposed, the proposals should take full advantage of the opportunities to provide new habitat and accessible natural greenspace, as well as conserving and enhancing existing habitat. It should be noted that Green Gaps are not greenspaces or open spaces. These are designated to prevent coalescence of settlements and not because of any intrinsic greenspace value that they may have.?

NO, I do not wish to participate at the oral examination

Please notify me

LA1.10 Existing Green Infrastructure

No

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.

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England's letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

Paragraph No: 2.64 Policy/Site No: Policy LA1.10: Existing Green Infrastructure
Natural England?s view is that greenspaces should be conserved and enhanced wherever possible. If, exceptionally, small areas are developed or partly developed, compensatory provision of greenspace and enhancement of spaces ought to be provided elsewhere. Wherever development is proposed, the proposals should take full advantage of opportunities to provide new habitat and accessible natural greenspace, as well as conserving and enhancing existing habitat.
Change(s) considered necessary to make the South Lakeland District Council Land Allocations DPD sound:
Natural England considers that Policy LA1.10 should be amended as follows:
„DEVELOPMENT AFFECTING PUBLIC OPEN SPACES OR AMENITY SPACES WILL NOT BE PERMITTED UNLESS THEIR COMMUNITY AND BIODIVERSITY VALUE GREEN INFRASTRUCTURE SIGNIFICANCE IS SAFEGUARDED OR ENHANCED. IF, EXCEPTIONALLY, SMALL AREAS ARE DEVELOPED OR PARTLY DEVELOPED, EQUIVALENT COMPENSATORY PROVISION, OR ENHANCEMENT OF EXISTING GREENSPACE ELSEWHERE WILL BE REQUIRED.'

NO, I do not wish to participate at the oral examination

Please notify me

3.7

No

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.

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England's letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

Section 3 Kendal and Surrounding Area
To which part of the South Lakeland District Council Land Allocation DPD does this representation relate?
Paragraph No: 3.7- 3.8: Infrastructure Planning Issues in Kendal
As has been raised previously, Natural England and the Environment Agency are working to restore natural functioning of rivers which may involve the removal of artificial river bank modifications, to allow
recovery of natural geomorphological processes and river function, where this does not conflict with flood defences e.g. in central Kendal. This may involve for example, the removal of artificial blockstone revetments in favour of soft engineering, and in some cases reconnecting the river with the floodplain. The implications of river restoration therefore need to be considered in relation to development proposals near and/or adjacent to the River Kent SAC.
Change(s) considered necessary to make the South Lakeland District Council Land Allocations DPD sound:
Natural England considers that a new paragraph 3.9 should be inserted:
‘Natural England and the Environment Agency are working to restore the natural functioning of rivers. This may involve the removal of artificial river bank modifications, where feasible, to allow recovery of natural processes and river functioning, where this does not conflict with flood defences. The implications of river restoration need to be considered in relation to development proposals located near and/or adjacent to the River Kent Special Area of Conservation (SAC).’

NO, I do not wish to participate at the oral examination

Please notify me

LA2.4 Land at Kendal Parks

No

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.

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England's letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

To which part of the South Lakeland District Council Land Allocation DPD does this representation relate?
Paragraph No: 3.23 – 3.24 Policy/Site no: Policy LA2.4 Land at Kendal Parks
Natland Beck crosses the northern part of the site and forms part of the River Kent and Tributaries SAC and SSSI. Natural England?s key concern is to ensure no adverse impact on the water quality and flow of the River Kent SAC both during construction, use and ongoing maintenance of any development. There should be no run-off to the River Kent SAC. In addition, the Appropriate Assessment identifies in Annex 1 that due to “direct spatial conflict with a European site” a permanent fence to create a 10m wide no-working buffer zone should be erected adjacent to Natland Beck and any developments located at least 15m from it. This mitigation measure should be reflected in the policy.
Change(s) considered necessary to make the South Lakeland District Council Land Allocations DPD sound:
Natural England requires that Policy LA2.4 should be amended as follows:
„A LANDSCAPED AND PERMANENTLY FENCED BUFFER ZONE OF 10M AROUND NATLAND BECK (PART OF RIVER KENT SPECIAL AREA OF CONSERVATION) WITH ANY DEVELOPMENT SET BACK AT LEAST 15M FROM THE BECK AND….’

NO, I do not wish to participate at the oral examination

Please notify me

LA2.5 Land at Oxenholme Road

No

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.

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England's letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

To which part of the South Lakeland District Council Land Allocation DPD does this representation relate?
Paragraph No: 3.25 Policy/Site no: Policy LA2.5 Land at Oxenholme Road
A watercourse which forms part of the River Kent and Tributaries SAC and SSSI crosses this site. Natural England?s key concern is to ensure that there is no adverse impact on the water quality and flow of the River Kent SAC both during construction, use and ongoing maintenance of any developments. There should be no run-off to the River Kent SAC. In addition, the Appropriate Assessment identifies in Annex 1 that due to “pollution risk and the watercourse being a tributary of Natland Beck” a “buffer zone to the stream of at least 10m is required”. This mitigation measure should be reflected in the policy.
Change(s) considered necessary to make the South Lakeland District Council Land Allocations DPD sound:
Natural England considers that Policy LA2.4 should be amended as follows:
“…CREATES A LANDSCAPED BUFFER ZONE AND HABITAT OF 10M AROUND THE WATERCOURSE …”

NO, I do not wish to participate at the oral examination

Please notify me

3.35

No

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.

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England's letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

To which part of the South Lakeland District Council Land Allocation DPD does this representation relate?
Paragraph No: 3.34 – 3.35: Scroggs Wood Strategic Employment Site, Kendal Policy/Site no: Policy LA2.9: Strategic Employment Allocations, Kendal
This strategic employment site allocation includes land near to and in the catchment of the River Kent SAC. Natural England?s key concern is to ensure that there is no adverse impact on the water quality and flow of the River Kent SAC both during construction, use and ongoing maintenance of any developments. There should be no run-off discharges to the River Kent SAC.
Any development would need to be located at least 15m from the river. A landscape scheme of locally native trees should be provided in a permanently fenced-off 10m buffer zone from the river. Any security or flood lighting during construction and use of any developments should be directed away from the river to reduce the impact of disturbance on otters and other protected species using the river corridor. Clean, inert materials should be used for any developments.
Scroggs Wood is a Woodland Trust site which should be protected from any adverse impact from developments in this area.
Change(s) considered necessary to make the South Lakeland District Council Land Allocations DPD sound:
Natural England considers that paragraph 3.35 should be amended as follows:
„A landscaped and permanently fenced buffer zone of at least 10m consisting of a hedgerow of native vegetation is required between Scroggs Wood and any development. Scroggs Wood should be allowed to expand into this buffer zone by natural re-vegetation. Any new development should be set back at least 15m from the boundary of Scroggs Wood’.

NO, I do not wish to participate at the oral examination

Please notify me

LA2.9 Strategic Employment Allocations, Kendal

No

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.

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England's letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

To which part of the South Lakeland District Council Land Allocation DPD does this representation relate?
Paragraph No: 3.34 – 3.35: Scroggs Wood Strategic Employment Site, Kendal Policy/Site no: Policy LA2.9: Strategic Employment Allocations, Kendal
This strategic employment site allocation includes land near to and in the catchment of the River Kent SAC. Natural England?s key concern is to ensure that there is no adverse impact on the water quality and flow of the River Kent SAC both during construction, use and ongoing maintenance of any developments. There should be no run-off discharges to the River Kent SAC.
Any development would need to be located at least 15m from the river. A landscape scheme of locally native trees should be provided in a permanently fenced-off 10m buffer zone from the river. Any security or flood lighting during construction and use of any developments should be directed away from the river to reduce the impact of disturbance on otters and other protected species using the river corridor. Clean, inert materials should be used for any developments.
Scroggs Wood is a Woodland Trust site which should be protected from any adverse impact from developments in this area.
Change(s) considered necessary to make the South Lakeland District Council Land Allocations DPD sound:
Natural England considers that Policy LA2.9 should be amended as follows:
„A LANDSCAPE AND GREEN INFRASTRUCTURE FRAMEWORK TO INCORPORATE A SUBSTANTIAL BUFFER OF NATIVE VEGETATION OF AT LEAST 10M TO SCROGGS WOOD …”,
AVOIDANCE OF DEVELOPMENT VERY FAR EAST PART OF THE SITE CLOSEST TO THE RIVER KENT WITH ANY DEVELOPMENT SET BACK AT LEAST 15M FROM THE RIVER AND SEPARATED BY A LANDSCAPED BUFFER ZONE’

NO, I do not wish to participate at the oral examination

Please notify me

3.37

No

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.

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England's letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

To which part of the South Lakeland District Council Land Allocation DPD does this representation relate?
Paragraph No: 3.37 Land south of K Shoes Factory, Natland Road Policy/Site no: E31
This employment site allocation includes land near to and in the catchment of the River Kent SAC. Natural England?s key concern is to ensure that there is no adverse impact on the water quality and
flow of the River Kent SAC both during construction, use and ongoing maintenance of any developments. There should be no run-off or discharges to the River Kent SAC.
Any development would need to be located at least 15m from the river. A landscape scheme of locally native trees should be provided in a permanently fenced-off 10m buffer zone from the river. Any security or flood lighting during construction and use of any developments should be directed away from the river to reduce the impact of disturbance on otters and other protected species using the river corridor. Clean, inert materials should be used for any developments.
Change(s) considered necessary to make the South Lakeland District Council Land
Allocations DPD sound:
Natural England considers that paragraph 3.37 should be amended as follows:
Significant structural landscaping and tree planting and robust boundary treatment along the western and southern edges of the site in particular will be needed to ensure development is sympathetic to existing landscape character, and also views from Natland Road, as well as protecting the setting of the Watercrook Roman Fort and civil settlement Scheduled Ancient Monument. A permanent fence should be erected to create a 10m wide no-working buffer zone between the north west boundary of the site and the River Kent and any developments should be located 15m from the watercourse. A landscaped scheme of locally native trees in the permanently fenced-off buffer zone should be provided. Any security or flood lighting during construction and use of any developments should be directed away from the River Kent to reduce the impact of disturbance on otters and other protected species using the river corridor’.

NO, I do not wish to participate at the oral examination

Please notify me

3.70

No

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.

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England's letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

To which part of the South Lakeland District Council Land Allocation DPD does this representation relate?
Paragraph No: 3.70: Land at Mainline Business Park, Milnthorpe Policy/Site no: E13M-mod
Natural England?s main concern is to ensure that Stainton Beck and the River Bela downstream are not adversely affected by development on this site. Measures are needed to ensure no adverse impact on the water quality and flow of these watercourses during construction, use and ongoing maintenance of any developments. Clean, inert materials should be used for any developments.
There are Otters on the River Bela and biodiversity enhancement opportunities to improve the riparian habitat particularly on the south east boundary of E13M-mod, adjacent to Stainton Beck, should be explored.
Change(s) considered necessary to make the South Lakeland District Council Land
Allocations DPD sound:
Natural England considers that paragraph 3.70 should be amended by inserting the following text at the end of paragraph 3.70:
‘Surface water runoff should be to mains drains. No development should take place until measures are in place to ensure that Milnthorpe Waste Water Treatment Works has the capacity to cope with the increased demand from development of this site and that there is no discharge to either Stainton Beck or the River Bela.
A permanent fence should be erected to create a 10m wide no-working buffer zone between the south east boundary of the site and Stainton Beck and any developments should be located
15m from the watercourse. A landscape scheme of locally native trees in the permanently fenced-off buffer zone from the river would improve biodiversity. Any security or flood lighting during construction and use of any developments should be directed away from Stainton Beck to reduce the impact of disturbance on Otters and other protected species using the wildlife corridor’.

NO, I do not wish to participate at the oral examination

Please notify me

3.107

No

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.

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England's letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

To which part of the South Lakeland District Council Land Allocation DPD does this representation relate?
Paragraph No: 3.107 Policy/Site no: Land Adjacent to Hall Park, Burneside (R489M )
The northern part of R489M (Land Adjacent to Hall Park) is near to the River Kent and Tributaries SAC and SSSI. Natural England?s key concern is to ensure no adverse impact on the water quality and flow of the River Kent SAC during construction, use and ongoing maintenance of any developments. There should be no run-off or discharges to the River Kent SAC. The Appropriate Assessment identifies in Annex 1 that due to “direct spatial conflict with a European site” a “Buffer zone against River Kent of at least 10 metres width is required”.
Change(s) considered necessary to make the South Lakeland District Council Land Allocations DPD sound:
Natural England considers that paragraph 3.107 should be amended as follows:
„…the need for Sustainable Drainage systems and the need to avoid development close to the River Sprint both because of flood risk and because of potential impacts on the River Kent and tributaries Special Area of Conservation. A permanent fence should be erected to create a 10m wide no-working buffer zone adjacent to the river. Any development needs to be located at least 15m from the river. A landscape scheme of locally native trees should be provided in the permanently fenced-off buffer zone from the river. There will also be a need for well lit pedestrian links to the village centre. Any security or flood lighting during construction and use of any developments would need to be directed away from the river to reduce the impact of disturbance on Otters and other protected species using the river corridor. Clean, inert materials should be used for any development’.

NO, I do not wish to participate at the oral examination

Please notify me

3.123

No

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.

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England's letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

To which part of the South Lakeland District Council Land Allocation DPD does this representation relate?
Paragraph No: 3.123 Policy/Site no: Policy LA2.14: Land north of Sycamore Drive, Endmoor
The development brief for this site should take account of the fact that the site is approximately 100m from Peasey Beck.
Change(s) considered necessary to make the South Lakeland District Council Land Allocations DPD sound:
Natural England considers that paragraph 3.123 should be amended as follows:
„This site at the northern end of the village will soften what is currently an abrupt urban edge. This site is proposed for residential and community use. Given its size and proposed mixed use potential, it would require a Development Brief. The key issue to be addressed is the need to provide a form of boundary treatment along the northern edge to minimise visual impact from the north and A65, by means of open space and landscaping. The provision of a public footpath/cycle link from site to Gatebeck Road should also be provided, if practicable. Community facilities could be incorporated within the development scheme where required. Measures should be put in place to ensure that
there is no adverse impact on the water quality and flow of Peasey Beck both during construction, use and during ongoing maintenance of any developments. Surface water runoff should preferably be to mains drains. Development in Endmoor is currently constrained by the capacity of the Waste Water Treatment Works and development of this site is unlikely to take place until Phase 2 of the DPD (2017-22).?

NO, I do not wish to participate at the oral examination

Please notify me

3.125

No

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.

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England's letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

To which part of the South Lakeland District Council Land Allocation DPD does this representation relate?
Paragraph No: 3.125: Employment Sites around Endmoor, Land at Gatebeck, Endmoor
The development brief for this site should take account of the boundary with Peasey Beck.
Change(s) considered necessary to make the South Lakeland District Council Land Allocations DPD sound:
Natural England considers that paragraph 3.125 should be amended as follows:
„Endmoor is well located for the M6. A 3 ha site, north of Gatebeck Lane, adjacent to Gatebeck Industrial Estate, offers the opportunity for additional employment development. Visual impacts will be important and the site offers the opportunity to incorporate extensive landscaping to the south to screen the site from the village and Gatebeck Lane. The site will require the preparation of a Development Brief to provide more detailed assessment and guidance on access, landscaping, flood risk, biodiversity and the remaining structures associated with the sites previous use. Measures should be put in place to ensure that there is no adverse impact on the water quality and flow of Peasey Beck both during construction, use and during ongoing maintenance of any developments. Surface water runoff should preferably be to mains drains. Development in Endmoor is currently constrained by the capacity of the Waste Water Treatment Works’.

NO, I do not wish to participate at the oral examination

Please notify me

LA1.3 Housing Allocations - All Endmoor sites

Yes

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England's letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

Support for the South Lakeland District Council Land Allocation DPD:
Natural England supports the constraint on development in Endmoor due to the capacity of the Waste Water Treatment works. Development should not take place until the Endmoor Waste Water Treatment Works has the capacity to cope with the increased demand these developments will make and to ensure that there is no unregulated discharge to the river.

NO, I do not wish to participate at the oral examination

Please notify me

LA3.3 Mixed Use Allocation at Guide's Lot, Grange-over-Sands

No

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.

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England's letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

Section 4 Land Allocations – Grange-over-Sands and surrounding area
To which part of the South Lakeland District Council Land Allocation DPD does this representation relate?
Paragraph n.o.: 4.14: Guides Lot, Allithwaite Road Policy/Site no: Policy LA3.3: Mixed Use Allocation at Guides Lot, Grange-over-Sands
Natural England?s main concern with respect to this designation is to ensure no SSSI, Limestone Pavement Orders, or Regionally Important Geological Sites are adversely affected by the proposals. The SSSI is designated for its calcareous grasslands and to maintain these in favourable condition, the site requires grazing.
Any development on this site should be located at least 15m from the SSSI and a permanent hedge erected to create a 10m no working buffer zone between any development and the SSSI.
Change(s) considered necessary to make the South Lakeland District Council Land Allocations DPD sound:
Natural England considers that Policy LA3.3 should be amended as follows:
„AS WELL AS OTHER CORE STRATEGY POLICY REQUIREMENTS, DEVELOPMENT MUST ENSURE THAT AN APPROPRIATELY PLANTED AND PERMANENTY FENCED BUFFER STRIP OF 10M WIDTH IS RETAINED ADJACENT TO THE WART BARROW SITE OF SPECIAL SCIENTIFIC INTEREST AND ANY NEW DEVELOPMENT SHOULD BE SET BACK AT LEAST 15M FROM THE BOUNDARY OF THE SSSI SITE’’.

NO, I do not wish to participate at the oral examination

Please notify me

4.16

No

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.

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England's letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

Paragraph No: 4.16: Land west of Cardrona Road
Natural England?s main concern with respect to this designation is to ensure no SSSI, Limestone Pavement Orders, or Regionally Important Geological Sites are adversely affected by the proposals. The SSSI is designated for its calcareous grasslands and to maintain these in favourable condition, the site requires grazing.
Any development on this site should be located at least 15m from the SSSI and a permanent hedge erected to create a 10m no working buffer zone between any development and the SSSI.
Change(s) considered necessary to make the South Lakeland District Council Land Allocations DPD sound:
Natural England considers that paragraph 4.16 should be amended as follows:
„This 1 ha site can accommodate around 28 dwellings. This field also adjoins Wart Barrow Site of Special Scientific Interest. The key issue is the need to take the proximity to the adjacent SSSI into account and any new development should be located at least 15m from the boundary. There is a need to incorporate new planting including erection of a permanent hedge to create a protected site buffer of 10m width and the extension of woodland to north to act as wildlife corridor /screening for existing properties.

NO, I do not wish to participate at the oral examination

Please notify me

LA5.4 Land at Ulverston, Canal Head - Development Brief

No

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.

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England's letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

Section 5 Land Allocations – Ulverston and Furness
To which part of the South Lakeland District Council Land Allocation DPD does this representation relate?
Paragraph No: 5.34-5.38: Canal Head Strategic Employment Site and 5.43-5.45: Canal Head Mixed Use site
Policy/Site no: Policy 5.4 Land at Ulverston Canal Head – Development Brief (Site M26/E30/M2)
Measures need to be put in place to ensure no adverse impact on the water quality and flow of Ulverston Canal during construction, use and during ongoing maintenance of any developments. The Appropriate Assessment identifies the potential hydrological connections between the Canal and Morecambe Bay SAC, and makes Sustainable Drainage Systems (SuDs) obligatory. In addition, biodiversity enhancement opportunities should be explored to encourage marginal vegetation of native water side plants along the canal margins. Natural England will be pleased to advise on suitable species.
Change(s) considered necessary to make the South Lakeland District Council Land Allocations DPD sound:
Natural England requests the following insertion to Policy 5.4 to make the DPD sound:
STRATEGIC EMPLOYMENT SITE
„AND ANY NECESSARY MEASURES TO ADDRESS ADVERSE BIODIVERSITY IMPACTS INCLUDING THE ESTABLISHMENT OF A 10M BUFFER ZONES BETWEEN ANY DEVELOPMENT AND THE CANAL’.
MIXED USE SITE:
“THE MITIGATION OF ANY ADVERSE BIODIVERSITY IMPACTS INCLUDING THROUGH THE ESTABLISHMENT OF A 10M BUFFER ZONES BETWEEN ANY DEVELOPMENT AND THE CANAL”.

NO, I do not wish to participate at the oral examination

Please notify me

5.37

Yes

SOUTH LAKELAND LAND ALLOCATIONS DEVELOPMENT PLAN
Thank you for your invitation to submit a representation in relation to the South Lakeland Land Allocations Development Plan Proposed Submission Document.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Question 2 - Test of Soundness
Natural England has a number of specific concerns in relation to the test of soundness which we wish to bring to the Inspectors attention. These primarily relate to the “justifiable” test, i.e. whether the Development Plan Document (DPD) is founded on a robust and credible evidence base and/or is not considered the most appropriate strategy when considered against the reasonable alternatives.
While Natural England has not suggested alternative sites for development through the plan process, requests for our interests to be fully considered in the process of selecting and assessing sites for development and in protecting certain designated sites from development in the Local Development Framework have been made. These interests include biodiversity and protected species, geodiversity, landscape character and quality, provision of greenspace, access to the countryside and other greenspace, soil conservation, sustainable design and construction, and environmental land management. Natural England would also like to see proposals which show both measures to reduce greenhouse gas emissions and adaptation to climate change.
The representations in many cases, reiterate the guidance given by Natural England to the informal consultation on development sites (May, 2010) which sought specific comments on the sites suggested for allocation including, amongst other things, sites to be avoided because of their environmental impacts or where mitigation would be needed.
As set out in Appendix 2 to Natural England's letter of response dated 6th July 2010, Natural England responded by providing specific comments on sites which were under consideration, including where particular measures would be needed to avoid or mitigate impacts on designated sites. Where Natural England is of the opinion that these mitigation measures have not been appropriately reflected in the policy, they form the subject of these representations. Proposed amendments have been indicated by the use of bold italics.

Support for the South Lakeland District Council Land Allocation DPD:
As previously raised by Natural England, the Appropriate Assessment identifies the potential hydrological connections between the Canal and Morecambe Bay SAC and makes SuDs obligatory (Annex 1). This is appropriately reflected in paragraph 5.37 of the text, although this is not directly reflected in the policy wording.

NO, I do not wish to participate at the oral examination

Please notify me