Local Development Framework Consultation

LOCAL PLAN LAND ALLOCATIONS DPD


GREEN SPACES SUBMISSION ON FURTHER MAIN MODIFICATIONS AND OTHER CLARIFICATION DOCUMENTS



1 Introduction

The Green Spaces Committee considers this further consultation to be largely irrelevant as the minor technical matters covered do not address the major areas of unsoundness exposed in the Examination Hearings.

The Green Spaces Committee asks the Inspector to find the Land Allocations DPD unsound and to refer it back to South Lakeland District Council for fundamental revision. As it stands the Plan has neither the support of the local community nor the landowners/builders groupings.

2 Further Main Modifications (EX061UU)

The further main modifications proposed do not address the following areas of unsoundness identified in the Hearings:

- The Council’s viability evidence is weak. S106 contributions for housing developments are grossly deflated and zero contributions from developers are assumed in the calculations for employment sites. Despite this the Council’s own study admits that none of the employment/ business park sites in the DPD are viable in the current climate
- Both community groups and builders, from opposite ends of the spectrum, consider the housing targets to be unachievable and undeliverable
- The housing targets cannot be justified in the light of the recent lower household interim projections
- The infrastructure proposals do not represent an infrastructure delivery plan; they are instead vague and aspirational and have little financial foundation. There is no implementation timetable. Many costly infrastructure requirements are deemed as “candidates” for an as yet unadopted CIL Scheme
- The education ‘evidence’ given by the County Council at the Hearings was last minute, complacent, flawed and unconvincing. It was admitted that additional requirements for school places arising from windfall sites had not been taken into account at all (up to 1000 homes during the plan period). There can be no confidence that the additional school places arising from the Plan can be accommodated within existing schools and no sites have been identified for new provision (this is particularly relevant given the national pressures on schools places)
- The minor modifications to the road infrastructure proposed will not prevent a significant worsening of the traffic congestion problems already suffered in the Kendal and Grange areas (with the consequent impact on air quality). The impact of the Kendal Canal Head development is ignored, as are all the strategic schemes which were previously considered essential to cope with increased traffic movements (eg the Kendal Northern Development Route)
- Evidence given in respect of many specific sites illustrated the flawed and subjective selection criteria used by the Council in drawing up the DPD
- There is no community support for the DPD and opposition from a number of town and parish councils

In respect of main modification MM076 (Extra Care Housing), this is a further example of a vague and aspirational statement which does not show how the identified need can be met. The infrastructure draft delivery plan identifies a requirement of an extra 58 extra care units as a direct result of the allocated housing sites (on top of an existing projected requirement of 320 units). It is stated that “a typical new extra care housing scheme with around 40 flats costs around £5.5 million to build …” How will this requirement be financed and where are the allocated sites for such provision?

3 Highways Clarifications Technical Note (EX104)

As stated above these further technical ‘clarifications’ do not answer the major deficiencies exposed at the Hearings in terms of the overall road infrastructure in Kendal and Grange. In detail, the technical note is also flawed as shown in the separate evidence of Kevin Lasbury on site R107M (29 July), which Green Spaces supports. A further example is that on site RN133M (Land West of Oxenholme Road) AECOM has not corrected its error in endorsing an access to the site which is outside the development boundaries proposed in the DPD, despite this being drawn to their attention in the Examination Hearings. There is no evidence that a safe alternative access to RN133M can be found.

AECOM technical notes reveal a laissez-faire approach to safety issues, for example in respect of both Sites E4M and R121M it is stated that the extension of the 30mph limit is not a requirement, leaving it to developers to demonstrate safe access.



4 Additional Information on RPA (EX103)

The additional information in respect of the implications of ‘raising the participation age’ of young people is interesting. However, the net increase of secondary school pupils projected from this initiative must be added to the general increases arising from the DPD proposals (including windfalls) on a catchment area by catchment area basis to understand where the pinch points will be during the plan period. This has not been done. Furthermore it was obvious from the Hearings that no discussions had taken place with Secondary School Heads to plan for the projected increases in overall numbers.

The number of new secondary pupils arising from the RPA agenda seems seriously underestimated in this analysis as it assumes that only 30% of NEETs (16 to18 year olds not in education, training or employment) will choose to attend local authority education. The basis for this 30% figure is tenuous as the comparison is drawn with those currently in education or training who will have different aspirations and financial means.

Furthermore the analysis fails to take account of emerging Government policy to ensure that all pupils achieve C grades in English and Maths GCSEs before they leave school. This paper is yet another example of a ‘seat of the pants’ response, lacking a robust evidence-based approach.







DENNIS REED

Chair, Green Spaces Committee

September 2013