Local Development Framework Consultation

Dear Sir / Madam,

I wish to make comment on the Major Amendments Document.
Firstly MM 051 the Berners Site.
The main modification states there will be “leisure use” and the development will “create a cluster of facilities and attractions”.
The Core Strategy states that “tourism, leisure and heritage sectors are to be developed in order to achieve a sustainable local economy”.
The proposed plan for this site AND the town does not fulfil these stated objectives.

Secondly, infrastructure provision to support the proposed development area to the south of Grange.
The footpath provision linking Lindale to Grange is on the opposite side of the town to the proposed development area which is approx 2 ¼ miles away.
This cannot be described or classified as “supportive infrastructure” for the proposed development area.

MM052 I would now make reference to the proposed cycleway / footpath from the Promenade to Kentsford Road.
No due consideration has been given to the route being of an acceptable standard to accommodate the mixed use of pedestrians, cyclists and the disabled. Risk assessment shows that with the physical restrictions alongside the sections adjacent the railway line (the highest risk section being immediately behind the properties on Kentsford Road) there is a substantial increase in the risk for all users. This is predominantly due to width and poor sight lines.
To simply dedicate this substandard route that does not comply with your own strategy documents for multi use is unacceptable. The design criteria must take into account the complete spectrum of all user groups if this facility is to be considered as truly supportive infrastructure. There are a number of these facilities in South Lakeland where use by the designated groups is extremely low, this is predominantly due to poor design and not being fit for purpose.

The Core Strategy states;
Policy T4, “all development and associated highway proposals should provide for safe, direct, convenient and attractive means of movement on foot”.

Policy T5, on cycling states “when assessing development and associated highway proposals, safe, direct, convenient and attractive provision for cyclists will be sought”. This may also include “detailed traffic management and traffic calming schemes to ensure both cyclist safety and priority of movement”.

Policy T13, “seeks the safe and convenient movement of pedestrians and cyclists as well as people in cars”.
It is clear that pedestrians, cyclists and the disabled (the less able bodied also) should not have to use substandard or potentially unsafe infrastructure as part of community development as is proposed with this route. These user groups are entitled to the same consideration as other highway users when assessing “safe and convenient movement”.

I would now describe the problems associated with the current proposal using the Promenade / Kentsford Road footpath;
Starting at Kentsford Rd, access is via numerous steep concrete steps onto a section of narrow elevated path alongside the railway line. This section of footpath is not wide enough to allow two people to pass comfortably and will not accommodate multi use safely. This first section has the railway track at a lower level on one side and retaining walls to the rear gardens of properties on Kentsford Rd on the other side. The use of bicycles on this section will create conflict between user groups, its inevitable given the restricted width.
The next section of concern is the access directly onto the Promenade from Cart Lane. The section under the railway track onto the Promenade is via two 90 degree turns within 3 metres, both are blind turns with restricted width. This combination will significantly increase the risk of accident. There is also a severe height restriction at this point and its possible that an adult on an upright commuting bicycle will risk a head injury. At the opposite end of the Promenade near the railway station again there is a 90 degree turn. The risk at this location is reduced, due to the width of the access road and Promenade at this point giving better sight lines, this may lead to an increase in the speed of access / egress by less responsible cyclists.

Lastly, the Core Strategy states that Grange has a number of cycle ways crossing the town, this is totally untrue. The town is on the Walney to Weir cycle route using the National Cycle Network. This route descends Low Fell Gate down the B5277 into Kentsbank Road, down Main Street and into the Meathop road near the golf club. This route is far from ideal and at times is dangerous due to the volume of traffic, this will not benefit any of the development proposals. This route would not conform or satisfy policies T3, T4 and T 13. There are no other designated cycle routes in the town.

The Local Plan should comply with Core Strategy Policy, it should not be selectively applied to the detriment of any section of the community in relation to essential supportive safe infrastructure.