Local Development Framework Consultation

SUMMARY
The following detailed comments on the South Lakeland Local Development Framework Core Strategy Preferred Options Document will show that:
The process itself is flawed, and fails any soundness test, because, despite assurances within the document and from staff, specific sites are considered and given preferred status without the benefit of the full range of assessments.

The Preferred Strategy is flawed, and fails any soundness test, because it proposes such a high percentage of the intended growth within Kendal without any acknowledgment of the limitations on infrastructure and facilities. The Strategy is also flawed as it states that the proposals are sustainable when clearly they are not.

The Strategy is further flawed, and again fails soundness tests because the published document is inconsistent, assessments are incomplete and contain incorrect statements of fact.

The proposals for Kendal are flawed and unsound because they ignore the limitations of the facilities available - or capable of being provided - within the existing town, are based on erroneous data and demand unacceptable flexibility in respect of Green Gaps. That flexibility would be unnecessary if the growth figures were realistic and if other sites without that “status” were included within the Preferred Strategy.

The proposal to include the North West Kendal site within the Strategy is flawed and unsound because any limited assessment has been based on wrong information; safe access to the site would be difficult to achieve and it would intensify traffic usage on a totally inadequate and substandard artery into Kendal; the location does not have good access to key facilities, as claimed; does not meet any sustainability criteria; requires unnecessary and unacceptable encroachment into a Green Gap; and is premature and prejudicial to the Kendal Relief Road proposal.


I will show throughout that, in all respects, the Strategy fails any “soundness” test and should be given more considered thought before the final Strategy is prepared




The Preferred Strategy is flawed, and fails any soundness test, because it proposes such a high percentage of the intended growth within Kendal without any acknowledgment of the limitations on infrastructure and facilities. The Strategy is also flawed as it states that the proposals are sustainable when clearly they are not.



The Strategy is further flawed, and again fails soundness tests because the published document is inconsistent, assessments are incomplete and contain incorrect statements of fact.



The proposals for Kendal are flawed and unsound because they ignore the limitations of the facilities available - or capable of being provided - within the existing town, are based on erroneous data and demand unacceptable flexibility in respect of Green Gaps. That flexibility would be unnecessary if the growth figures were realistic and if other sites without that "status" were included within the Preferred Strategy.



The proposal to include the North West Kendal site within the Strategy is flawed and unsound because any limited assessment has been based on wrong information; safe access to the site would be difficult to achieve and it would intensify traffic usage on a totally inadequate and substandard artery into Kendal; the location does not have good access to key facilities, as claimed; does not meet any sustainability criteria; requires unnecessary and unacceptable encroachment into a Green Gap; and is premature and prejudicial to the Kendal Relief Road proposal.



I will show throughout that, in all respects, the Strategy fails any "soundness" test and should be given more considered thought before the final Strategy is prepared"



From this summary you will see that I believe both the process and conclusions to be flawed in many respects. Whilst I could have addressed these comments solely to Miss Psillidou I feel that the issues here are of sufficient importance to require that their exposure to senior officers and Members at the earliest opportunity.

I apologise for the overall length of the comments but I do hope that you will take time to read them and ideally take an early opportunity to influence the further development of the Strategy before it is finalised for submission to government. I also hope that you will encourage any Inspector to allow public oral representations at any subsequent Examination of the Strategy.
SUMMARY

The following detailed comments on the South Lakeland Local Development Framework Core Strategy Preferred Options Document will show that:

The process itself is flawed, and fails any soundness test, because, despite assurances within the document and from staff, specific sites are considered and given preferred status without the benefit of the full range of assessments.

The Preferred Strategy is flawed, and fails any soundness test, because it proposes such a high percentage of the intended growth within Kendal without any acknowledgment of the limitations on infrastructure and facilities. The Strategy is also flawed as it states that the proposals are sustainable when clearly they are not.

The Strategy is further flawed, and again fails soundness tests because the published document is inconsistent, assessments are incomplete and contain incorrect statements of fact.
The proposals for Kendal are flawed and unsound because they ignore the limitations of the facilities available - or capable of being provided - within the existing town, are based on erroneous data and demand unacceptable flexibility in respect of Green Gaps. That flexibility would be unnecessary if the growth figures were realistic and if other sites without that “status” were included within the Preferred Strategy.

The proposal to include the North West Kendal site within the Strategy is flawed and unsound because any limited assessment has been based on wrong information; safe access to the site would be difficult to achieve and it would intensify traffic usage on a totally inadequate and substandard artery into Kendal; the location does not have good access to key facilities, as claimed; does not meet any sustainability criteria; requires unnecessary and unacceptable encroachment into a Green Gap; and is premature and prejudicial to the Kendal Relief Road proposal.


I will show throughout that, in all respects, the Strategy fails any “soundness” test and should be given more considered thought before the final Strategy is prepared

Introduction

All of the following comments consider the “soundness of the plan” as requested on page 5 of the document. They are divided into comment on the soundness of the overall process itself; on the soundness of the overall Preferred Option; on the soundness of the plan in respect of the Kendal Functional Area; and on the soundness of the plan in respect of the North West Kendal housing and Green Gap proposals.

I will show throughout that, in all respects, it fails “soundness” and should be given more considered input before the final Strategy is prepared

The Process itself.

The Draft Strategy is flawed “in process” from the start because it purports to show principle and policy and states “it is important to stress that the Council is not outlining specific sites which will need to be finalised in the Allocation of Land DPD – the symbols do not denote a specific site but a broad location”. And yet that is exactly what the document does, in so many locations. And it does so without full environmental, traffic and other appraisals.
Staff also emphasised the “broad locations” at the exhibition in Kendal. However within the document there are many comments about the suitability for development of various “broad locations” which actually refer to specific sites. These comments are shallow, some are ill founded, some are wrong, there are many inconsistencies and, equally, many omissions. The Draft Strategy has been prepared and identifies these “broad locations” without the benefit of the Employment and Housing Land Search Study, which is not yet complete (Page 90).
This would mean that if adopted the Strategy would give a “broad location” planning status that it may not warrant if/when tested fully and properly. That could put long term delivery of the Strategy at risk. Perhaps more importantly, it would also put any interested party at a distinct disadvantage when individual development proposals are brought forward for detailed consideration.

The Strategy fails the “soundness” test on those general principles alone.

The Overall Preferred Option

1 Kendal as a Principal Service Centre

Whilst it is accepted that it is correct to identify Kendal as a Principal Service Centre, it cannot be right to concentrate such a high proportion of the growth in that one tightly constrained urban area where the infrastructure and facilities are already inadequate.
The Draft Strategy Preferred Option is to concentrate 43% of residential and commercial/employment development growth in the town – together with expecting Kendal to act as “an employment zone for National Park residents”. That means that Kendal population will grow by in excess of 27% (on the basis of only 2 people per new household on a base population of 28398) as well as accommodating “commuting” employees from elsewhere within the area and from the National Park. The degree of commuting expected from the National Park over the Strategy period is unknown as the Lake District National Park has yet to publish their Preferred LDF for consultation
Challenges to “the soundness” are :

a. Kendal’s transport infrastructure is fully stretched at present. The maintenance, development and enhancement of that infrastructure are in the hands of the County Council. The Strategy states that the District Council relies on “partners” delivering their contribution but Cumbria County Council have failed miserably to deliver in full their most recent strategy for Kendal – pedestrianisation was intended to be but one part of an overall strategy – and I have been told no further work will be done to address issues such as Lowther Street, where Air Quality is a cause for concern now. The opportunity for capacity enhancement within the town is very limited.
Because of the size of the town and the nature of the surrounding area there is a finite limit that any Council can do (both physically and financially) to increase public transport and thus increase sustainable travel. The Draft Strategy acknowledges that Park and Ride in a town such as this is uneconomic – I go further – it is impractical because of the lack of “economies of scale”. There is therefore little opportunity for the infrastructure within Kendal to accommodate the travel patterns of such a large population increase and increased volume of commuters from the National Park;

b. The Draft Strategy makes selective reference to the County Council’s Local Transport Plan, quoting many extracts from the LTP but it omits any reference to the Kendal Northern Relief Road which is stated as being the County Council’s second priority for capital investment. The fact that the project is not included within Regional funding priorities before 2017 does not preclude its relevance to the timeframe of the Draft Strategy. A Strategy that will lead to a LDF has to contain reference to another local authorities’ prioritised capital project. That would not preclude the District Council, in developing its Strategy from having a policy of its own on this capital project – is it important to the achievement of the Strategy, in which case why is it not mentioned and why is the District Council not persuading the County Council to do further work on the project to further its case with the regional bodies; or does the District Council not want a Relief Road pursued. In either case the “soundness” of the plan is flawed by omission.
c. The document acknowledges the importance to the district of the M6 and recognises that many residents use that corridor to access employment. A higher proportion of appropriately sized developments should be located close to this corridor in places such as Crooklands, Holme etc. Similarly, within Kendal itself the location of this transport corridor should be recognised when allocating growth areas – the Preferred Strategy has three employment areas to the north, which means traffic serving those sites would have to pass through the town.

d. Kendal does not have a fully functioning hospital, and policies are to allow the existing facilities to become more run down or more “specialised”. At present Westmorland General Hospital A&E does not deal with cases which are much more than routine – with patients having to be sent to Lancaster or Barrow. This in itself points to changing the Strategy emphasis towards marginal increases in development in places such as Milnthorpe, Crooklands (proximity to M6) and a higher concentration in Ulverston which not only has a limited hospital of its own but also enjoys good access to full hospital facilities (at Barrow).
Also on the health front, this area suffers more than most from the absence of National Health dental facilities.
e. There is no reference in the document to the ability of schools, collectively or individually to accommodate such a potentially large increase in population.

e. Such a large increase in employment/housing would have a dramatic impact on the foul sewage system in Kendal. There is no comfort in the document that the system and the waste water treatment plant have the capacity to accommodate such an increase. Similarly, such extensive development will inevitably increase the volume and rate of runoff of surface water. There is no evidence that this can be accommodated without additional flood risk, particularly bearing in mind the fickle nature of the River Kent catchment area.

2 Canal Head

It is quite obvious throughout the document the importance the District Council places on the Canal Head development. It is a major element of the Draft Strategy and yet there must be major risks and questions over it ever being delivered. Reopening the canal through to Kendal will be expensive and, like many such major capital projects those costs could escalate, its cost effectiveness must be increasingly open to question and the ability to attract funding must be questioned. That such a high profile, high risk project forms a major plank without any discussion of risk and alternatives again challenges the “soundness” of the entire plan.

Whilst all of the above deal specifically with Kendal issues, they are sufficiently fundamental to the whole and thus cast further doubt on the “soundness” of the whole Strategy.

3 The Long(er) Term

Having stated that Kendal’s infrastructure cannot accommodate the increase proposed within this draft Strategy, it is also incumbent on the Council to give some thought beyond the timescale of this LDF. There are clearly no grounds for optimism that Kendal can grow beyond that timescale. This LDF should therefore acknowledge that, show some longer term thought process, decide where a future Principal Service Centre should be established and set that process in hand within this LDF.

Kendal Functional Area

The following comments refer in more detail to the “soundness” of proposals for Kendal itself.

a. All of the above general comments apply.

b. There are two points within the Report which indicate that the overall demand for development land in Kendal could be reduced. – para 3.111 states that 10% more industrial land is needed “whereby existing sites in inappropriate locations are replaced by new sites”. Presumably a % of those sites so replaced, being “brown field”, would be available for housing – reducing the demand in Kendal by up to 8.8 hectares. Para 3.117 mentions 5.05 hectares of industrial land in Milnthorpe not being included in the table “as it could undermine the supply in the Strategy” (whatever that means). The “soundness” of this statement is challenged – that reduces the demand for land in Kendal by a further 5.05 hectares
So even if the basic assumption about Kendal is maintained, the overall need for land is reduced by up to 13.85 hectares.


c. Comments on Option 3 Alternative Directions of Growth (page 123).

This section purports to assess 23 “broad locations” for development and contains superficial, sparse, inconsistent and incorrect comments – and many do look very site specific indeed. Presumably those comments/superficial assessments were considered relevant and used when the Council came to conclusions on the Preferred Strategy. They do however need some considerable additional work before being an acceptable part of the process –

1 –potential development may be restricted, but the area could still be given positive assessment – the recreational facility (soccer field) could be relocated the other side of Rather Heath Lane without prejudicing any other policies.

2 – There is no comment here at all. So is there any viability here? It must be remembered that Burneside is incorporated within Kendal Functional Area in the Draft Strategy despite, confusingly, also having Local Service Centre status.

3 - On what basis is the statement “access is significantly constrained” made.

4 - Is the implication that the Green Gap between Burneside and Bowston is of more importance than the Green Gap between North West Kendal and Burneside. Again what is the substance for the access comment.

5 and 6 - there seems nothing here to detract from minor additional development

7 – visibility from footpaths seems to be of importance in some places, but irrelevant elsewhere. What assessment has been done to determine whether the drainage concerns are not insurmountable

8 and 9 – Just how important is visibility of developments and why is it particularly relevant here. A65 is some distance from Natland and “wider landscape” is bound to be affected by most of the potential sites

10 - there are a few pockets here to be included.

12 – is potential scale of controversy to be the controlling factor in deciding the Strategy

13 and 14 – at last areas that are acceptable

15 – this ignores totally the fact that discussions have been ongoing with both Kendal Cricket and Rugby Clubs for their facilities to be acquired for development with a purpose built replacement being provided elsewhere in the town. Such sites could be ideal for employment, but bearing in mind the small residential developments along Shap Road, some housing could also be accommodated.
How does the character of the area limit development potential

16 – This states that Hallgarth is all 19th century estates. This area started to be developed in the 20th century and contains relatively recent developments. A new access bridge has NOT been built over the railway from Hallgarth. An existing bridge has been strengthened by Network Rail to ensure it can continue with its original function – accommodation and footpath bridge, not to provide access to housing development. These two erroneous statements cast doubt on all other aspects of this assessment. The statement that there is potential to build new access roads is unacceptable without a proper environmental and traffic assessment – more in detail below.

17 – what does this mean – does it give this “broad location” a positive reaction or what – there is no comment about suitability of access, potential to build new access roads etc.

20 – this appears to give favourable assessment to development in this location

22 – the comments in this item are potentially the most outrageous within this section and fully demonstrate the lack of “soundness” in the approach. A new access would be needed which may increase development costs!! Virtually all “broad locations” considered would need new accesses and many would require extensive infrastructure. “The existing housing consists of large detached houses – which may limit the potential for locating housing”!! This wording is a cause for particular concern about “soundness” and equity.

23 – receives very positive, if tightly constrained comment.

Comment was made above about the rugby and cricket grounds. The process also fails the “soundness” test in connection with the livestock market site off Appleby Road. It is recognised that the process for its replacement may be at a difficult stage but the Strategy is flawed if such large potential is ignored – in the same vein as comments about Canal Head above, the document should discuss this site’s contribution in a balanced but non prejudicial manner.
No mention is made within this Option of the two areas of fields off Sedburgh Road in the vicinity of Castle Green Hotel. The fields to the west of Sedburgh Road are most suitable for housing. Part of the fields to the east are very steep but there has to be scope for some additional housing here.

The Preferred Strategy (for Kendal)

There is no commentary on how this Preferred Strategy was arrived at; nor why the order of the locations changes so dramatically between Option 3 and Table 3.

The Preferred Strategy does contain some illogical and unexplained proposals. For example, and deliberately distant from North West Kendal, area 23 in Option 3 received positive comment about suitability for knowledge based employment development – and yet it is excluded from the strategy. Area 22 in Option 3 is suggested as being suitable for housing, albeit with the questionable caveat that the size of the existing houses may limit the potential for new housing. Yet the Preferred Strategy suggests that there will be no apparent problem in locating Mixed Employment/Housing here.

Para 4.12 makes a wholly unsubstantiated comment that development areas (“urban extensions”) included in the overall Core Strategy are sustainable. On what basis – the information given in Option 3 and in Table 3 is inadequate for such an assertion. No environmental or traffic assessments have been done – how can sustainability have been proven. Indeed below I argue that sustainability is far from achieved.
Green Gaps
The definition of a Green Gap is that it cannot be built on and therefore has greater protection than other green field sites. The original reasons for this definition were quite clear and there is no reason for any change of direction. The Strategy document has not made any case for the flexibility now desired in respect of some Green Gaps. It also seems to favour sites within Green Gaps over some areas that do not at present enjoy that designation. Those “broad locations” within the Preferred Strategy that require such Green Gap flexibility should be withdrawn.

Table 3

The variation in depth of assessment of individual “broad locations” is clearly demonstrated by the Achievability comments in respect of service provision – for example sites 1,3 and 4 mention possibility of off site mains reinforcement whereas sites 2c,8,9 and 10 give details of all services in the vicinity. This inconsistency again fails the “soundness” test.

The Preferred Strategy for the Kendal Function Area fails the “soundness test” as a consequence of all of the above points.

North West Kendal – “broad location”

Because the boundaries of this site are clearly drawn, along with the proposed modification to the Green Gap, it cannot be denied that comments on the site’s inclusion in the Preferred Strategy are anything but very specific. This site should not be included in the Preferred Strategy because many issues fail the “soundness” test.
The comments in Table 3 are challenged in their entirety as they are weak, flimsy and not, in themselves sustainable. Option 3 comments on this site have been shown to be wrong.

Suitability

a. “good accessibility
bus stop 100 yards from site” – presumably this refers to the stop at Carus Green at the extreme north west corner of this “large site”– 1 bus each way an hour!!!! How many people in affordable, or other housing will use that. Most people will drive as they do now from Briery Meadows and existing properties on Burneside Road.

“Oxenholme Station 4.8km away” – what is that supposed to mean in terms of accessibility /suitability/sustainability of sites in Kendal – to access Oxenholme from this site requires travel through Kendal Centre --- by car to do so in a sensible timeframe.
At this stage in the process it is essential to assess how the site would be accessed by road borne vehicles – service vehicles, owner’s cars etc? This is not mentioned. Is the expectation that the alleged new bridge over the railway is used to gain vehicular access from Hallgarth. If so that totally fails the “soundness” test.

Is a new access proposed onto Burneside Road – if so why is this not mentioned in line with comments about other sites. Or is it intended to access this “large site” through the existing Briery Meadows estate. If so that still requires a new access and there is no mention of it in the document – further “soundness” issues.

If either are proposed then it will be demonstrated below that neither access point is acceptable. This would be proven within any Traffic Assessment for the site.
At this stage in the process it is essential to assess how the site would be accessed by road borne vehicles – service vehicles, owner’s cars etc? This is not mentioned. Is the expectation that the alleged new bridge over the railway is used to gain vehicular access from Hallgarth. If so that totally fails the “soundness” test.

Is a new access proposed onto Burneside Road – if so why is this not mentioned in line with comments about other sites. Or is it intended to access this “large site” through the existing Briery Meadows estate. If so that still requires a new access and there is no mention of it in the document – further “soundness” issues.

If either are proposed then it will be demonstrated below that neither access point is acceptable. This would be proven within any Traffic Assessment for the site.

b. “clarification of culvert required” – what is this comment doing in something so allegedly broadbrush.

c. “environmental assessment required” – so how can the District Council proceed with this “site” as a fundamental element of your core strategy without an environmental assessment having been done. And how can the Strategy make claim in para 4.12 that all sites are sustainable.
d. “travel assessment/travel plan – at developers expense”!! I know that officers will state that it is too early in the process for detailed assessments but that cannot be so in respect of this large site. How can this be a core part of a Strategy which claims to be sustainable without a traffic assessment having been done at some level. It will be shown below that there are major traffic/road safety issues in respect of this site that will prevent it being developed. That has to be tested before the site is included within the Strategy otherwise the entire exercise is futile - utterly failing the “soundness” test.

Overcoming Constraints

a. Flexibility required over Green Gap – already mentioned above. But there is a possibility that the Council expects even more flexibility over/encroachment into the existing Green Gap if access is to be proposed from Burneside Road – see detail below.

b. Again this mentions a Traffic Assessment may be required. No one can propose a development of this size without a traffic assessment so why should that not be tested at this stage. The Preferred Strategy is very site specific and not broad brush here, as it may be elsewhere.
In fact the entire strategy should be subjected to a traffic assessment before it is finalised and submitted to government/Ministers.

c. Confirmation has been received from both the developer of Briery Meadows and from United Utilities that the sewage system on the existing Briery Meadows estate does not include any spare capacity for discharges from further development. Extensive drainage works would therefore be required, which would seem to far exceed the “off site mains reinforcement” mentioned in the table.
d. No mention in here about the Kendal Northern Relief Road, which is a priority for the County Council. There is no information about its alignment etc but at present it could be built within the timeframe of the Strategy. There is a possibility that the route could cross Burneside Road in the vicinity of the development. It is reasonable to suggest that this development, or access from it could prejudice the relief road scheme. Inclusion of the site in the Preferred Strategy would therefore be both premature and prejudicial in respect of a firm proposal that has been County Council policy for several years. On that basis alone this North West Kendal site again fails the “soundness” test.

Detailed comment on access to the North West Kendal site.

a. Burneside Road. Wherever the new site is accessed from –more below – it would significantly increase traffic on Burneside Road, one of the least acceptable corridors into Kendal. It contains:
a difficult pair of junctions into Briarigg and Kentrigg not far south of a crest with inadequate visibility when exiting from Briarigg;
a very narrow restricted height railway over bridge with the carriageway edge directly against a totally unprotected abutment and one narrow footway – actual carriageway width 4.4 m, 14.4 ft; minimum footway width 1 m, 3.28ft; effective carriageway width only about 13ft;
a difficult junction with Sparrowmire and Horncop Lanes, which itself is at a crest with very poor main road forward visibility;
a further difficult junction with the totally unacceptable access to the Courts and Dockray Hall industrial estate (mentioned in the Strategy as having scope for more development); parking within the side road often causes great difficulty for right turning lorries; visibility to the right is limited but usually reduced to zero by parked vehicles;
other junctions with existing housing and the new Riverside estate;
a difficult junction with Busher Walk where visibility to the south is severely restricted by the left hand bend.
All of these inadequacies are exacerbated by both the authorised and uncontrolled parking, much of which reduces the road to single lane.
The junction with Windermere Road is controlled by traffic signals where queue lengths on Burneside Road are constrained by parking on the approach to the signals.
The road is used by bus services to Burneside and Hallgarth, by every permitted size of goods vehicle to both Dockray Hall estate and to the paper mill at Burneside.
The road is crossed on foot by many pupils heading for Queen Katherine School on Shap Road, the majority of them in possibly the worst place between the crest with poor visibility and the constrained railway bridge; and having to use the very narrow footway through the railway bridge.
Any intensification of use –over that from development at the industrial estate – must be resisted on road safety grounds.



b. Access to the site. (note in this context that page 133 Achievability section talks about “the site’s large size”)
Access directly onto Burneside Road.
From Figure 21 the “obvious place” to access this site is at the point where the existing footpath/farm access joins Burneside Road, where the proposed development site meets the proposed, “flexibly” revised Green Gap boundary. That position is clearly unsafe being on the inside of the sharp bend at the bottom of a fairly steep hill where visibility to both left and right is severely constrained (about a quarter of recommended standards). It would also be opposite the access to the well used Carus Green Golf Course.
Any access point here would have to be taken further to the north, perhaps as far as midway between the two existing sharp bends. This would effectively add this further field to the development area – encroaching even further into the Green Gap and having a disastrous impact on the visual amenity of The Todds from the south. Even so the alignment constraints and vehicle speeds here suggest that it may be very difficult to site a junction of adequate and safe standard.
Access through the existing Briery Meadows Estate
This can not be considered seriously by anyone as, in strict planning terms alone, it would introduce a material disbenefit to the amenity of the entire existing estate.
It would introduce significant road safety concerns on the estate, require the compulsory purchase of land from several properties at the end of Briarigg to make the access road of adequate width, would do away with a prime open space and formal childrens’ play area.
The estate infrastructure is of inadequate alignment and width to accommodate intensification of use, bearing in mind the natural intensification that is occurring/will occur as existing families mature and offspring acquire vehicles of their own - there is on street parking now.
The existing junction with Burneside Road is inadequate for any further intensification of use. The standard of this junction is arguably unacceptable for the traffic using it now, with visibility from the junction falling some 30% short of recommended standards accompanied by high traffic speeds on Burneside Road. Clearly these are issues of concern now but the junction is totally incapable of safely accommodating any further intensification of use of the side road.
On that basis, it cannot safely accommodate any deliberate intensification of use of the main Burneside Road either.

It is obvious that no further progress should be made in considering this site without the benefit of the full range of environmental, traffic impact and safety assessments.

Indeed the many issues associated with this site mean that it should be withdrawn from the Strategy.
Conclusion

The overall document raises more issues than it answers and fails “soundness” throughout – in process, in policy considerations, and in their application to Kendal.

The amount of growth directed at Kendal needs to be reduced to a more realistic and sustainable level; and areas where growth is proposed need to be located in more appropriate and sustainable locations.

The proposed North West Kendal Site fails any logical “soundness” test on many issues –
inadequacy of assessment;
distance from facilities and lack of sustainability;
unacceptable and unnecessary flexibility in respect of the Green Gap;
prematurity and prejudice of Relief Road proposal;
environmental impact;
drainage issues;
adequacy and safety of access, both direct and in respect of additional traffic on Burneside Road.
This site should therefore be removed from the strategy as it is finalised for submission to government.

Two issues have come to my attention since I submitted my formal comments on this document. I believe both warrant further comment and both further demonstrate a lack of “soundness” within the LDF Preferred Option process.

The two issues are – the origin of the population growth figures; and
traffic assessments.

Population Growth figures

The LDF states that the emerging Regional Spatial Strategy recommends a net annual rate of 400 dwellings to be built ….. It goes on to state that that ensuring accessibility to services and determining the best pattern of provision are amongst the most challenging spatial issues which the Council needs to address.

The implication from these statements is that such a high growth rate, which translates within the Preferred Option to a 30% increase within Kendal, is disseminated from “on high” i.e. from the Regional Assembly and ultimately from central government. That it is something the District Council are charged with coping with.

However, I understand that this annual growth figure is actually the result of lobbying by the District Council and represents a requested increase of 56% over the previous growth requirement of 256 dwellings per annum.

I fully accept that growth is required in the district and that addressing affordable housing needs is a very high priority.

It is, however a failure in LDF process and “soundness” that this is not openly disclosed by the Council and that there is no explanation of the origin of, or justification for, this significantly increased figure.

Traffic Assessments

I made several assertions within my main comments that the Preferred Option had been developed without the benefit of the appropriate level of traffic, environmental and other assessments – and that “soundness” was not achieved as a consequence.

I am now aware that the District Council are, at this time, preparing to appoint consultants to undertake traffic assessment of the Preferred Option. Needless to say, I contend that this work should have been a major contribution within the development of that Option, not promoted at this belated stage where opinions have already been formed.