Local Development Framework Consultation

Dear Sir

Response to consultation on proposed SLDC modifications to Land Allocations Development Plan Document (DPD)

I make my response with particular reference to Kendal North East site R121M (section 3.20 in the DPD). Both the SLDC proposed 'Main Matters' and its schedule of 'responses to issues raised in 1.6' reveal incoherences and inconsistencies in regard to site R121M remaining in the allocation. I have limited these to three main headings of Flooding, Landscape Impact and Access, as I believe that there is enough evidence to show SLDC's assessment of the site under these areas alone is flawed or lacks sufficient data to allow the site to remain in the allocation. This does not preclude the modifications showing flaws in SLDC's assessments of the site under other areas such as biodiversity and community approval.

Flooding:
Other sites in the '1.6 matrix' which have been recognised as being in both flood zones 1 and 3a and which impact on the Stock Beck Flood Alleviation Scheme have been removed from the Allocation Plan (I refer to sites R663, RN137, R124, RN96 and RN96M). The 1.6 matrix in regard to site R121M and the Main modification 07 both refer to R121M having part in Flood Risk Zone 3a and being at moderately/high risk of surface flooding. However site R121M DOES impact on the Stock Beck Flood Alleviation Scheme and this has been omitted from the 1.6 matrix. R121M has a well proven track record of a HIGH risk of surface flooding and water from the site flows onto Castle Green Road into the Stock Beck Scheme (or in flood simply into the rear of houses on Oak Tree Road). Yet the flood risk is only marked as 'orange' rather than 'red' – such is SLDC's desperation to get this site allocated.

Landscape Impact:
How is it in the 1.6 Matrix that R121M and R56 have been rated 'orange' for Landscape Impact, yet R676KE and R141 have been rated 'red'? How can R121M and R56 be realistically separated from R676KE and R141 in terms of the impact of development on these sites. Even worse, the fact that these sites are all rated 'green' under the Gillespie EHLSS shows how useless the latter was as an evidence base. In fact all previous assessments of the entire site whether by SLDC in 1997 or under the Cumbria County Council Landscape designation in 1999 recognised no differentiation of the site – it was all landscape of high character where development would have high impact. The differentiation of landscape impact in the 1.6 Matrix again simply demonstrates SLDC's consistently flawed landscape assessment and evidence base for this site, and its desperation to have development on whatever part of the site it thinks it can manage.

Site Access:
This is marked 'green' in the 1.6 Matrix for site R121M but it has never been made explicit how this is to be achieved. If access is to be by Oak Tree Road then there are all manner of problems with this due to traffic flow, width of road, nature of junction etc. There is simply no evidence base for the 'green' rating so allocated as we do not know upon what assessment this has been given.

Under the circumstances, R121M should be removed from allocation within the DPD.

Yours sincerely

D R Baxter