Local Development Framework Consultation

Subject: Areas, R97M, MN34 and a third, undefined area marked with a dotted red circle on South Lakeland District Council’s latest Framework map, lying immediately to the South of Helme Lodge. (We understand this indicates a broad location for future housing development in 2022-2027.)
This 'addendum' to our submission (dated 17/5/12) relates to Mr. Berkeley's schedule, page 6, "Kendal, matters 3.1/ 3.2 / and 3.3."
As requested, it is in response to the submission made by SLDC's submission dated 18/9/12 entitled:
"LAND ALLOCATIONS DEVELOPMENT PLAN DOCUMENT (DPD)
(ii) South Lakeland District Council’s response to Matter 1.6 of the Inspector’s ‘Matters and Issues’"
Questions /Comments From HLHG Ltd, in response to SLDC, in the order listed by the SLDC submission are:
Reference R97M-mod &part of MN34# mod:
a) SA value: SLDCM say: "the site performs reasonably well … on the edge of Kendal and has good access to a range of services and facilities." Whilst we cannot deny this, so too has Kendal Castle, also being so close to the main town. However, is that a reason for building all over it? Placed, as it is, in the middle band of SA value, (marked "moderate/neutral ... Compared to other sites in the settlement"), does this judgement take sufficient account of the loss of amenity, the wonderful views from the canal footpath, and what will be the canal when it is restored? These paths are used by many walkers and cyclists -- and hopefully by canal boats. How has such loss of amenity been taken into account, especially when SDLC 's comments say "it is greenfield and has moderate/high landscape, moderate heritage impact and moderate /high bio-diversity value." Such comments seem contradictory to the recommendation to allocated the Parkland for 73 houses.
b) SHLAA, measuring the "deliverability" of the site, places it in the lowest category "least developable sites". Elsewhere in the documents, SLDC acknowledges that the highways department has effectively ruled out Natland Mill Beck Lane as a suitable access point for traffic. It also admits that the entrance from Natland Road would be difficult to engineer (expensive?) given the line of the proposed canal. Yet the SLDC comments read: "it can be satisfactorily accessed." How can these two viewpoints be aligned? Although an engineering possibility – nearly anything can be engineered these days – is economically viable so to do (have there been any costings for canal bridges etc?); and is safe and it desirable so to do, to allow traffic from 73 houses to exit onto Natland road in the same area as a canal / road crossing and a probable Marina entrance, allowed for in E31M#?
c) Landscape Impact: again SLDC has categorised R97M as being the middle band as "moderate/neutral… (which) can be moderated through landscape mitigation measures." Could this be explained given the very high risk there would be to avenues of mature beech trees lining the canal area; as well as to other mature oaks / beeches dotted around the parkland. Any houses built in between would totally change the character, the landscape impact by any criteria, surely, in the environs of the grade 2 listed building, Helme Lodge? And as 'mature trees' there would also be safety implications, with falling branches and trees -- unless they were felled, which would both devastate the 'landscape impact' and contravene environmental safeguards.
d) Site Access: again the site is placed in the middle category, access "with constraints which are considered can be overcome… moderate/neutral". We have already questioned this in b) above, and further ask what traffic impact assessments have been made since the recent expansion of Natland village and further proposed developments there, as well as a possible Marina or light industry at E31M#?
e) Heritage: again the site is classified in the "moderate/neutral ..." category, accepting "potential impact on built heritage designations". We understand this to mean Helme Lodge itself, which, if so, we would argue, is to substantially undervalue the 200-year-old 'rural aspect' of Helme Lodge. To build on the old parkland is to change the nature of the estate forever.

Conclusion
In their submission, with the exception of 'Flooding', SDLC places R97M-mod &part of MN34# mod in the middle or bottom (least suitable) of their development bands, most crucially rating the deliverability of this site in the lowest band. We hope the above objections stand in their own right. Our case rests, not only on the environmental vandalism entailed in the proposal for so many houses on such a beautiful (Grade 2 listed) area of Parkland amenity , but on the fact that R97M is considered so difficult (expensive?) to engineer. We submit that it is neither realistic, economic, nor viable for access and safety and in consequence should not be included in the SLDC Land Allocation Plan.