3 responses from Kentrigg West Action Group (KWAG) , c/o PFK Planning
1. Kentrigg West Action Group (KWAG) , c/o PFK Planning : 23 May 2012 16:24:00
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Policy/Site No.
LA1.3 Housing Allocations - R170M-mod KENDAL NORTH OF LAUREL GARDENS
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
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.
The DPD is not consistent with national policy.
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 am instructed by the Kentrigg West Action Group (KWAG), which has more than 400 supporters, to submit the following representations to the SLDC Consultation: "Land Allocations - Publication Stage". These representations relate primarily to site R170M - Land to the North of Laurel Gardens but do touch on other aspects of the document in so far as they have implications for/relate to the site.
The earlier emerging options Land Allocations document showed a total of 251 dwellings on site R170M , with the development spread over phases 2 and 3. The current document shows a reduced total of 197 dwellings to be constructed during phase 3; 2022-2025. The stated reasons for these changes relate to the need to accommodate an access to the site and , primarily because of infrastructure deficiencies - The Windermere Road/ Burneside Road junction and the sewerage network. KWAG considers that site R170M should be removed altogether from the land allocations process for the reasons set out below.
General Comments
1
There is growing concern amongst South Lakeland communities regarding the credibility of the evidence base used by the District Council at the Core Strategy stage. There is undoubtedly a need for affordable housing in South Lakeland but the emerging lack of community support for the current proposals shows that there is widespread concern that the overall scale of new housing proposed goes well beyond the development needs of the area and that it is therefore unsustainable. KWAG therefore considers that there should be a robust and fundamental re-evaluation of the housing target figures, to objectively assess the need for market and affordable housing in the district, before the Land Allocations are confirmed. Should a reduced revised figure be then found to be more appropriate then this adds to the justification for removing site R170M from the final document.
2
The recently produced National Planning Policy Framework (NPPF) sets out detailed revised guidance to Local Planning Authorities concerning the preparation of Local Plans, stressing the importance of public involvement and support and the need for plans to have sufficient flexibility to adapt to rapid change. KWAG considers that before submitting the Land Allocations document to the Planning Inspectorate it is vitally important that SLDC prepares and publishes a statement showing how it considers that the proposals comply or otherwise with all of the requirements of the NPPF.
3
Another major concern is that development in the town on the scale proposed will require a major infrastructure investment programme to cover such matters as sewerage capacity (a particularly important issue in NW Kendal), waste water treatment, highway improvements, nature conservation and air quality improvements. However at this crucial stage when decisions are due to be made on land allocations there appears to be no robust plan for infrastructure provisions, just a series of commitments to bid for funds in future as set out in the brief Infrastructure Position Statement. The scale of development proposed makes it unwise to expect that "delivery partners" will provide such essential infrastructure. Simply relying on developer-driven planning applications is not a sound or credible approach.
Until these three general issues have been adequately resolved the plan cannot be considered to be Sound.
Detailed Objections
KWAG submits that the development of site R170M would be unsustainable, primarily by being detrimental to highway safety leading to greater congestion, and by being harmful to the landscape quality and character of the surrounding area. As such its development would be contrary to the principles central to Core Strategy and a number of the supporting policies.
1 Highway Capacity
The primary vehicular access to this site, and to the two proposed sites (93 dwellings) in Burneside is along the Class C Burneside road. This road contains a number of sub standard features, primarily a very poor and congested junction with the A5284 Windermere Road. This junction is close to Kendal town centre and the Highway Authority acknowledges that it, and others in the immediate vicinity, currently operates at an above acceptable capacity and just below maximum capacity. It therefore is in need of considerable improvement. In KWAG's view the ability to do this is limited to changing the traffic light sequence in line with other junctions on Sandes Avenue as physical improvements are not possible because of the proximity of large and important buildings. Depending on which other sites in the town are developed the junction could end up above capacity, particularly in the afternoons. Coupled with other features such as a railway bridge over a narrow section of carriageway, on street parking in the absence of off street provision the conclusion is that Burneside Road is totally unsuitable to cater for the increased traffic flows that would be generated by an additional 197 dwellings, as well as the increased number planned for Burneside. Indeed the 2009 Kendal Traffic Assessment concluded that the town's existing highway network +improvements would only just accommodate the number of new houses proposed if three of the proposed sites were removed from the process. One of these three sites was site R170M. The most recent Transport Study by Cumbria CC does not repeat this conclusion, giving no explanation. KWAG considers that there is confusion over the likely impacts on traffic of the allocation proposals and is calling for a new all embracing Traffic Study and Report to be commissioned.
2 Highway Access
Because of the poor alignment of Burneside Road at the only possible entrance to the site from it the Highway Authority has concluded that "achieving adequate visibility will be problematic", and this has been confirmed by measurements taken on site by a KWAG member who is a former County Highway Engineer. The road alignment and traffic speeds are such that it will not be physically possible to provide a safe vehicular access to this site to an approved standard when approaching from / exiting towards Kendal - the most common journey that residents are likely to make.
It is KWAG's view that these highway capacity and access problems could only be satisfactorarily overcome by the provision of a Kendal Northern Relief Road, linking Plumgarths Island on the A591 to the A6(Shap Road), for which of course there is no provision.
3. Landscape Setting
Kendal has a clearly defined landscape setting and nowhere is that more apparent than in NW Kendal. The site forms part of a rolling farmland landscape situated at the boundary between the Morecambe Bay Limestone Character Area and the Coniston Slates Character Area, as set out on the Landscape Character Map of England. The Cumbria Landscape Classification puts the site within Landscape Character type 7b, Drumlin Field. This is not a common landscape and its local importance is therefore enhanced. The immediate scenery is primarily limestone with highly characteristic limestone boundary walls dividing up the fields geometrically and all set in an attractive drumlin filled valley. This gives the high quality landscape a strong identity and provides a visually interesting, attractive and clearly defined landscape setting for the town of Kendal which sits just below it. By developing this site the quality of the landscape and that surrounding it will be significantly harmed, by virtue of developing the "toe" of a drumlin, contrary to the Council’s stated aim of maintaining and enhancing the landscape of Kendal (Core Strategy Policy CS2). KWAG considers that the protection of this unique landscape has not been given sufficient weight in the allocations process.
The site forms part of the currently defined "Green Gap" designated to avoid coalescence between Kendal and Burneside. Within this gap there are a number of small, tight groups of farm buildings dispersed amongst the drumlins that contribute highly to the character of the landscape. Whilst a physical separation between Kendal and Burneside would remain the perception of a gap gradually "closing up” would be apparent. In his report into the 1996 Local Plan the Inspector dealt with a proposal to omit some of the land in this area from the Green Gap. He concluded “..I consider the Plan should seek to engender a degree of public confidence that the separation secured will not, at some future time, be lightly squandered. For these reasons I believe that, where a Green Gap is seen as necessary, it is more important that the whole gap between the settlements should be designated as green gap than that substantial but arbitrary landscape features should be rigidly followed" The landscape has not changed in the last 16 years and it is more important than ever that the principles laid down by this Inspector should be adhered to today.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
KWAG represents the views of over 400 local residents who are opposed to these proposals. We wish to participate in the oral examination as we believe that the issues we have raised have not been given sufficient weight by SLDC in the production of the Land Allocations Document and that the only way to forward is for us now is to present our case to the Planning Inspector
2. Kentrigg West Action Group (KWAG) , c/o PFK Planning : 23 May 2012 16:55:00
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
Paragraph No.
0.0 Whole Document
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
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.
The DPD is not consistent with national policy.
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 am instructed by the Kentrigg West Action Group (KWAG), which has more than 400 supporters, to submit the following representations to the SLDC Consultation: "Land Allocations - Publication Stage". These representations relate primarily to site R170M - Land to the North of Laurel Gardens but do touch on other aspects of the document in so far as they have implications for/relate to the site.
General Comments
1
There is growing concern amongst South Lakeland communities regarding the credibility of the evidence base used by the District Council at the Core Strategy stage. There is undoubtedly a need for affordable housing in South Lakeland but the emerging lack of community support for the current proposals shows that there is widespread concern that the overall scale of new housing proposed goes well beyond the development needs of the area and that it is therefore unsustainable. KWAG therefore considers that there should be a robust and fundamental re-evaluation of the housing target figures, to objectively assess the need for market and affordable housing in the district, before the Land Allocations are confirmed. Should a reduced revised figure be then found to be more appropriate then this adds to the justification for removing site R170M from the final document.
2
The recently produced National Planning Policy Framework (NPPF) sets out detailed revised guidance to Local Planning Authorities concerning the preparation of Local Plans, stressing the importance of public involvement and support and the need for plans to have sufficient flexibility to adapt to rapid change. KWAG considers that before submitting the Land Allocations document to the Planning Inspectorate it is vitally important that SLDC prepares and publishes a statement showing how it considers that the proposals comply or otherwise with all of the requirements of the NPPF.
3
Another major concern is that development in the town on the scale proposed will require a major infrastructure investment programme to cover such matters as sewerage capacity (a particularly important issue in NW Kendal), waste water treatment, highway improvements, nature conservation and air quality improvements. However at this crucial stage when decisions are due to be made on land allocations there appears to be no robust plan for infrastructure provisions, just a series of commitments to bid for funds in future as set out in the brief Infrastructure Position Statement. The scale of development proposed makes it unwise to expect that "delivery partners" will provide such essential infrastructure. Simply relying on developer-driven planning applications is not a sound or credible approach.
Until these three general issues have been adequately resolved the plan cannot be considered to be Sound.
Detailed Objections
KWAG submits that the development of site R170M would be unsustainable, primarily by being detrimental to highway safety leading to greater congestion, and by being harmful to the landscape quality and character of the surrounding area. As such its development would be contrary to the principles central to Core Strategy and a number of the supporting policies.
1 Highway Capacity
The primary vehicular access to this site, and to the two proposed sites (93 dwellings) in Burneside is along the Class C Burneside road. This road contains a number of sub standard features, primarily a very poor and congested junction with the A5284 Windermere Road. This junction is close to Kendal town centre and the Highway Authority acknowledges that it, and others in the immediate vicinity, currently operates at an above acceptable capacity and just below maximum capacity. It therefore is in need of considerable improvement. In KWAG's view the ability to do this is limited to changing the traffic light sequence in line with other junctions on Sandes Avenue as physical improvements are not possible because of the proximity of large and important buildings. Depending on which other sites in the town are developed the junction could end up above capacity, particularly in the afternoons. Coupled with other features such as a railway bridge over a narrow section of carriageway, on street parking in the absence of off street provision the conclusion is that Burneside Road is totally unsuitable to cater for the increased traffic flows that would be generated by an additional 197 dwellings, as well as the increased number planned for Burneside. Indeed the 2009 Kendal Traffic Assessment concluded that the town's existing highway network +improvements would only just accommodate the number of new houses proposed if three of the proposed sites were removed from the process. One of these three sites was site R170M. The most recent Transport Study by Cumbria CC does not repeat this conclusion, giving no explanation. KWAG considers that there is confusion over the likely impacts on traffic of the allocation proposals and is calling for a new all embracing Traffic Study and Report to be commissioned.
2 Highway Access
Because of the poor alignment of Burneside Road at the only possible entrance to the site from it the Highway Authority has concluded that "achieving adequate visibility will be problematic", and this has been confirmed by measurements taken on site by a KWAG member who is a former County Highway Engineer. The road alignment and traffic speeds are such that it will not be physically possible to provide a safe vehicular access to this site to an approved standard when approaching from / exiting towards Kendal - the most common journey that residents are likely to make.
It is KWAG's view that these highway capacity and access problems could only be satisfactorarily overcome by the provision of a Kendal Northern Relief Road, linking Plumgarths Island on the A591 to the A6(Shap Road), for which of course there is no provision.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
KWAG represents the views of over 400 local residents who are opposed to these proposals. We wish to participate in the oral examination as we believe that the issues we have raised have not been given sufficient weight by SLDC in the production of the Land Allocations Document and that the only way to forward is for us now is to present our case to the Planning Inspector.
3. Kentrigg West Action Group (KWAG) , c/o PFK Planning : 23 May 2012 17:01:00
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.
LA1.9 Green Gaps between - KENDAL and BURNESIDE
1.1 Do you consider that the South Lakeland District Council Land Allocations DPD is legally compliant?
Yes
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.
The DPD is not consistent with national policy.
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.
3. Landscape Setting
The site forms part of the currently defined "Green Gap" designated to avoid coalescence between Kendal and Burneside. Within this gap there are a number of small, tight groups of farm buildings dispersed amongst the drumlins that contribute highly to the character of the landscape. Whilst a physical separation between Kendal and Burneside would remain the perception of a gap gradually "closing up” would be apparent. In his report into the 1996 Local Plan the Inspector dealt with a proposal to omit some of the land in this area from the Green Gap. He concluded “..I consider the Plan should seek to engender a degree of public confidence that the separation secured will not, at some future time, be lightly squandered. For these reasons I believe that, where a Green Gap is seen as necessary, it is more important that the whole gap between the settlements should be designated as green gap than that substantial but arbitrary landscape features should be rigidly followed" The landscape has not changed in the last 16 years and it is more important than ever that the principles laid down by this Inspector should be adhered to today.
3.1 If your representation is seeking a change, do you consider it necessary to participate in the oral part of the examination?
YES, I wish to participate at the oral examination
3.2 If you wish to participate in the oral part of the examination, please outline why you consider this to be necessary.
KWAG represents the views of over 400 local residents who are opposed to these proposals. We wish to participate in the oral examination as we believe that the issues we have raised have not been given sufficient weight by SLDC in the production of the Land Allocations Document and that the only way to forward is for us now is to present our case to the Planning Inspector.
