Local Development Framework Consultation

Copy To Simon Berkeley , Planning Inspector

Dear Sirs

R121 M Local Development Framework

I am writing to ask that R121M be removed from the framework at this final stage on the following grounds :

Landscape
Development on R121M will have a detrimental impact on the town landscape that will be irreversible. This wooded and walled sloping landscape has hitherto been protected by inspectors and should remain so. This valuable beautiful rural landscape view, particularly on exiting Kendal in an easterly direction, will be destroyed. This development would close the necessary gap to keep the Castle Green Lane Rural Hamlet community distinct. The view across from the Castle Green Hotel to the fells will be marred by a road , new junction and pollutant street lighting. It will be impossible to mitigate the loss of this landscape. This additional street lighting will also impact on the protected wildlife adjacent to the site and light pollute the rural woodland and breeding ground for falcons and hawks. R121M must be removed. If building goes ahead there will be no view of Kendal Castle from the West Coast Line.

West Coast Line Building Buffer Zone
It will be difficult and costly to landscape and mitigate noise to any newbuild houses on R121M which lies completely within the prescribed West Coast Line Building Buffer Zone. Yet again SLDC and Russell Armer have failed to take into account a serious impediment when planning to build on this site. Costs appear to be stacking up against building on this site, and certainly making it less and less cost effective to build what is really needed in the area, affordable homes.

Flooding
The area has yet again encountered flash flooding in the last two weeks causing flooding at both bridges restricting traffic flow around East Kendal. SLDC have not provided sufficient detail or costings to prove that any proposed new housing and faster run off will not make the flooding situation even worse. Remove R121M or guarantee in writing to all residents within a square mile of R121M that no future flooding will occur in the area. This site will prove too costly to address the flooding issues and still build what is really needed in Kendal, affordable homes.

Environmental Impact
An Environmental Impact Assessment should have been completed before R121M was added and as a highly sensitive site this again and mitigation of the results will be another expensive cost. Any change in drainage for buildings or roads will impact on the stable wildlife and protected sites adjacent to R121M. These adjacent sites contain many species not found closer to Kendal including, in the words of Bowland Conservation Researchers and Railtrack assessors we spoke to, “a high quality colony of Great Crested Newts”. With only 2 ponds of this nature within Kendal, SLDC should not risk destroying the stability of one of them. Any changes to the drainage of the land below the site will impact on the wildlife in the area and their ability to feed from and pass through the wildlife corridors currently protected and funded by SLDC. The population of voles, moles, frogs, toads, chicks and smaller creatures and insects on which the Kestrels, Buzzards and Herons, Moor Hens and birds feed will be reduced as their habitat is destroyed by virtue of the wet land being reduced to urban housing. This is a Kestrel breeding ground and any urbanisation will impact on future breeding. If numbers of dwellings are a criteria and affordable housing crucial this valuable environmentally sensitive site does not justify being destroyed.

Great Crested Newts
These creatures deserve an objection on their own behalf. With national recognition that their population is endangered, any movement or damage to this colony would be devastating to Kendal. To move or damage the colony is an insult to Kendal residents as well as to the newts who have obviously found a home in Kendal in which they thrive. SLDC as a “green” council should be proud of its natural assets, and be fighting to retain them and protect them, not displace them for the profit of a developer or land owner, when there are other less sensitive sites available. The passage of the newts between the pond and other wetlands locally and to overwintering sites will be barred by walls, barriers, tarmac roads and house construction. I was saddened to witness ridicule at my expense when referring to these matters at the enquiry. The representatives from Russell Armer and SLDC seemed to find it amusing that the Great Crested Newt colonies have to be considered seriously. That does not bode well for their conduct in the future. Barriers , roads , junctions and alteration to the water content around these colonies can not help but damage the colonies. Damaging the colonies is illegal. SLDC and Russell Armer need to take their legal obligation more seriously than was evident at Kendal Town Hall and show how they will protect these colonies not laugh. SLDC regularly maintains in its literature and on its signage that it is protecting its wildlife and environment and should therefore do its utmost to protect these remaining special species within the town boundary. If SLDC is truly a “green” council it must remove R121M in its entirety.


Traffic
Any additional dwellings on R121M are a ridiculous proposal on this steeply sloping with existing landscape and drainage issues including ice and snow. It is already difficult to exit properties and the hotel on Castle Green Lane and from properties on the western side of the A684, especially during rush hour and in bad weather. The screeches, accidents and near misses outside the Castle Green Hotel bear testament to this as traffic fails to observe the 40mph limit in either direction which commences near any proposed new junction. The prospect of more cars, and 2 per family is the norm so this is a reasonable figure even with “affordable” housing, having to wait at junctions to exit and enter, and therefore polluting the adjacent nature sites is unacceptable. To put traffic lights in place or introduce yet another junction would alter the nature of this rural landscaped route into Kendal and create an urban area in what has hitherto been the rural edge of town. I had a near miss in the snow while driving up the A684 as a car from Oak Tree failed to stop due to slipping on the steep icy slope. The nature of the land in R121 M is even steeper and with serious drainage issues the potential for ice and snow related accidents doesn’t bear thinking about entering an exiting a busy main road. R121M would provide a traffic hazard if built on. Please remove it.

Tourism and Economic Impact and loss of well being due to loss of Public Amenity
At a time when SLDC are spending money on signage around the town to indicate to visitors and locals alike the amenities within the town, this proposal would destroy a town amenity valuable to both tourists and residents, and which encourages external economy into the town. This open patch of green is a vital lung and mental boost to the Kendal residents, dog walkers, joggers and walkers from all the surrounding areas and international visitors to the Castle Green Hotel who photograph the view across to the fells and up to the woodland. Well being and civic pride will be reduced as a result and I ask therefore that R121M should be removed in its entirety.

Not Affordable Housing
The plans are supposedly being considered in order to help the local housing affordability situation. Only the minimum 35% affordable housing has been quoted on this site. It is more likely that there may only be around 20 affordable homes or less. The nature of the site, flood precautions and drainage work, landscaping, house design, cost of experts, consultants and assessments , so as not to impact on the landscape and surrounding dwellings and trees, will all have a cost impact which will have to be passed on to the buyers, probably reducing the percentage of truly “affordable” housing even further, and probably the size of those dwellings too, to ensure that the larger homes subsidise the smallest. This is a sad development for the town that those who can only afford the least valuablle properties are being forced into smaller sized homes which do not provide decent rooms to live in. Kendal is losing valuable land to benefit the few, not the majority. Developing R121M will not truly deal with the real local housing issue of “affordable” housing but will risk the visual heritage, environment and attraction of Kendal. In the interim R121M must be taken out of the proposals in order to protect the area until more effective local solutions are found.

Localism
SLDC has continued to push this site forward despite considerable local opposition. Localism was supposed to allow for discussion and consultation at a local level but this has not happened. SLDC has ignored its own Town Council’s report and opinion on this sensitive site, along with Cumbria Wildlife Trust, Friends of The Earth and the local RSPB. There is still vociferous opposition and will continue to be at the planning stages should this site be left in. This will cause delays and increase costs. Remove it now and concentrate on more deliverable, less costly sites.

Conclusion
Each of these individual issues has significant weight:-
• The loss of previously designated county landscape special to Kendal, both visual and historical
• The environmental impact on trees, wildlife and specifically Great Crested Newts and the Kestrel breeding ground through loss of habitat and breeding and sheltering and feeding ground
• The potential for worse and significant local run off flooding of roads and houses already suffering
• The potential for changing water levels in the GCN breeding site and damaging the colony
• The site is within the West Coast Line Buffer Zone which will require costly solutions to address visual and audible effects on any homes and gardens built from this increasingly busy freight and passenger line
• The impact on tourists and local well being through loss of a public amenity and attractive urban farmland
• The impact on traffic congestion, light pollution and potential accidents of any new junction on this busy road
• The lack of addressing the real local need for affordable housing through spiralling costs in order to address the local site issues
• This site has had massive objections and will continue to have objections throughout any future planning processes which will further inhibit development and make the site not cost effective. Localism should be taken into account.




Kendal Town Council’s report and previous Inspections acknowledged the difficulties of developing this site and recognised the highly sensitive nature of this site. It was deemed to be the least cost effective and most sensitive site proposed.

We trust that SLDC and the inspector too will finally recognise that each of these is a valid reason on its own merits for not developing R121M. As a combined force these issues provide the strongest argument that R121M is not appropriate for inclusion within the Local Development Framework, now or in the future. Please now finally remove R121M and save this small special piece of Kendal for the future generations of Kendal inhabitants and visitors to enjoy too.

I would also ask in addition that if there was a way possible R121M and the adjacent fields should now be preserved as local community green space by the inspector to save any future arguments.




Fiona Hanlon