Local Development Framework Consultation

To Mr Simon Berkeley BA MA MRTPI,
Planning Inspector


Dear Mr Berkeley


Response to Schedule of Main Modifications (SMM) of SLDC Land Allocations DPD, April 2013, and supporting new evidence base, particularly in regard to site R121M, land east of Castle Green Lane/Road

1. In response to point MM0088 of the SMM regarding the assumption by Cumbria County Council (CCC) of responsibility for flood risk and surface water management, I note that neither CCC nor SLDC have as yet presented evidence or even plans for assessing site R121M. SLDC has so far ignored evidence presented by local residents in regard to the flood risk on this site and its impact on the Stock Beck Scheme.

2. In response to point MM024 of the SMM which states that site specific Development Briefs will be developed for major, complex or sensitive sites, I note that no such brief is listed for R121M. Why is this? R121M should count as both a complex and sensitive site. Local residents have catalogued in great depth a whole series of issues relating to flood risk, poor highways access, impact on landscape and environment etc. What are the criteria for selecting sites for specific Development Briefs?

3. While I note the requirement for the Viability Studies prepared by HDH Planning and Development to demonstrate that site R121M may or may not generate sufficient sale value for the landowner and profit for the developer, such studies seem pointlessly abstract without further evidence of the costs and implications of trying to develop the site. The site is subject to major concerns and has been rejected for development on previous occasions. In the Viability Study appendix showing the site specific map (pp 21-22), HDH Planning and Development state that the promoter of the site has estimated abnormal costs of £336,176. What exactly does this cover and how has this cost been estimated?

4. However it is the Further Highway Evidence Report prepared by AECOM which I gives me greatest concern (and in particular those relating to R121M on page 60). The 'findings' are so cursory as to be risible. In particular:
4.1. the lack of even the most outline of plans showing potential road layouts, entrance/egress to and from Castle Green Road
4.2. the issue regarding orientation of the cul-de-sac stub in Oak Tree Road which would necessitate a 180 degree turn for a route to enable onward access into any new estate
4.3. the narrowness of parts of Oak Tree Road which is down to 4.25 metres at its narrowest and most dangerous point close to the entrance to Castle Green Road
4.4. the susceptibility of the most of the lower part and entrance of Oak Tree Road to frost, snow and ice; this has been demonstrated several times over every Winter when passage to and from the estate has been hazardous or impassable except to four-wheel drive vehicles
4.5. the complete unsuitability of attempting to convert what is essentially a quiet estate road (Oak Tree Road) into potentially a throughway from one part of Castle Green Road to another part of Castle Green Road via Oak Tree Road
4.6. the number of blind bends and pinch points on Oak Tree Road which with the current low traffic of a quiet estate will inevitably lead to accidents, danger to pedestrians and cyclists when the road has to serve as a busy through road for well over double the residences (including both Oak Tree Road and the new site) the existing road was meant to serve
4.7. the impact on residents on Oak Tree Road of increased traffic from the new estate with potential restrictions on their own parking, and a huge increase in noise, pollution and subsequent reduced quality of life

This 'Evidence report' (which hardly merits the name) leaves me with little else to conclude that this is vacuous study funded by CCC which does little else but approve CCC's own totally inadequate desktop assessment. It illustrates the lack of independence and reliability of a study funded by CCC to validate its own findings by a paid third party (AECOM). It also illustrates that both CCC and SLDC have failed to carry out a proper highways assessment for site R121M and its impact on Oak Tree Road.

I should also remind you of my previous objections presented to SLDC which have covered the impact of this proposed development on drainage, flooding, biodiversity, environment and landscape. I regret to inform you that SLDC have comprehensively failed to engage with local residents and our concerns, and continue to ignore evidence and information which we have presented and which they find inconvenient and contrary to their intentions.

I thank you for your attention in this matter

Yours sincerely


David R Baxter