Response from Mr K A Lasbury (Individual)
1. Mr K A Lasbury (Individual) : 31 Jul 2013 15:34:00
Please add your response below, quoting the further proposed main modification reference number or relevant document title including reference to section / page / paragraph: (limit 3000 words)
I am responding to the latest round of consultations and shall be grateful if you will pass my response to the Inspector, please.
In my experience it is accepted practice not to undertake consultations during main holiday periods when people are away or preoccupied with other issues. However I assume that all involved with this prolonged process are keen to draw it to a conclusion.
I have three comments on the documents published on 26th July:-
Ex104 Highway Clarifications Technical Note AECOM July 2013
This note purports to clarify for the Inspector recommendations which fall into categories of “requirement”, “desirable” or “requiring consideration”.
The Introduction again repeats the consultant’s incorrect application of highway design standards in respect of access to/new junctions with the existing highway network. Again they are relying on the standards included within the Manual for Streets published by the Department for Transport. Whilst a passing reference is made to “other appropriate design standards”, these are not being called upon in respect of sites to which they should apply. I refer to Design Manual for Roads and Bridges which is relevant for roads with 30 mph speed limits. Cumbria County Council acknowledged (in the hearing in November 2012) that the standards in this Manual are used by the Council.
I again repeat that the use of Manual for Streets is inappropriate in respect of site R170M – land to the north of Laurel Gardens – as Burnside Road does not have the characteristics of a street – on either approach to the proposed access or at the site of the access itself.
It is simply inadequate to propose extension of the 30 mph speed limit (presumably as a requirement); and to comment as follows “additional traffic calming measures, such as gateway treatments will likely be necessary” (presumably as requiring consideration). Such action would not sufficiently change the characteristics of Burneside Road – and thus driving perceptions/behaviour – for the safe adoption of the lower standards permitted within Manual for Streets.
EX061UU Schedule of Further Proposed Main Modifications
MM0128 Updated.
The modification proposed here is an extension of the 30 mph speed limit on Burneside Road as a minimum adjacent to the northern extent of the site.
I fully accept that the 30 mph speed limit has to be extended IF this site is developed. However, as explained above, and in several other representations, this will not adequately change Burneside Road – and particularly the way it is driven – to mean that the lower standards applicable to streets can be safely adopted.
It is clear, and has been adequately demonstrated, that the visibility standard which should be used in connection with any access here cannot be achieved on site (i.e. those within DMRB).
On that basis, yet again, I argue that inclusion of this site is unsound, because safe access cannot be achieved, and it should therefore be withdrawn from the Land Allocations.
Other issues.
I am disappointed that the Council has not taken the opportunity, in these latest publications, to address various concerns over the impact of the Land Allocation proposal on Kendal’s Infrastructure. For example, to my knowledge, there is still nothing in the public domain which acknowledges and addresses the current congestion, and the additional congestion from development traffic, on Windermere Road and Sandes Avenue, the primary access into Kendal from the north and the major access to the large industrial areas off Shap Road. The Council has stated that Kendal’s economy is suffering from traffic congestion but has, yet again, ignored this fundamental omission within the Land Allocations.
Conclusion
I believe that enough evidence has been given to the Inspector to demonstrate the site R170M cannot be safely accessed. On that basis its inclusion within the Land Allocation is unsound.
I also believe that enough evidence has been put before the Inspector to confirm the inadequacies of the Council’s proposals to deal with the traffic congestion and other infrastructure deficiencies within Kendal. The fact that these latest main modifications make no attempt to address those deficiencies is further evidence that the proposals in respect of Kendal as a whole are also unsound.
I trust the Inspector will find accordingly within his report.
Many thanks
Kevin Lasbury
