Local Development Framework Consultation

2.3 - 2.15 A Spatial Portrait of South Lakeland

Page 7

Neither support nor oppose - just want to comment

From the perspective of Transition South Lakes we would like to see a baseline carbon audit of the region , maybe mapping of carbon emissions. Such a base line is necessary given the need to monitor the regions progress towards a low carbon ecoomy

Addition of carbon auditing of the region.

Adopted by the District Council

2.18 - 2.27 Spatial Vision for South Lakeland in 2025

Strategic Vision Page 15

Support partly

The visionary perspective for South Lakeland in 2025 needs to define the meaning of sustainable communities to include SOCIAL. ECONOMIC AND ENVIRONMENTAL aspects. local production of energy and food.

There needs to be recognition of the need to develop resiliance in communities and also to recognise the uncertainty that we face. The vision needs to promote a shift towards

2.28 - 2.38 Strategic Objectives

The strategic objective 2.30 over emphasises a growth economy

Neither support nor oppose - just want to comment

The strategic objectives could make mention of the Transition South Lakes Initiative and/or refer to aspects of its vision which could include referencesin each of the objectives, as numbered in the changes suggested below.

1. Low Carbon or carbon neutral housing to address fuel poverty. Higher standards of environmental performance could be expected from buildings.
2. An entrepreneurial culture that supports sustainable practice.
3. Ensure that South Lakeland responds to "Peak Oil"
4. Ensure resiliance of ecosystems and recognise the services that ecosystems provide for us.
5. Identify opportunities to engage with the Transition South Lakes initiative.

3.12 - 3.16 Options Considered: Alternative Locational Strategies: Options 1-7

Option 5 page 32

Neither support nor oppose - just want to comment

A range of comments from the Transition South Lakes perspective options. These comments are developed from the need to ensure that small communities are able to maintain their cohesion and thus retain the ability to respond to inevitable environmental changes resulting from oil and fuel costs and consequent impacts on the local economy.

Option 5 Differentiate the level of development in individual settlements across each level of the hierarchy based on environmental capacity, existing size etc.
We consider that environmental capacity should exclude areas which are in the first level of flooding danger. Building in such areas cannot be considered as sustainable.
Size of development ; new development should not overwhelm existing housing stock in small communities.

Option 6. The grouping of smaller communities into functional areas with Principal or Key Service areas which are then considered as an entitiy making them more able to accommodate development , may be an easy way for planners and developers to arrange their affairs, but smaller communities will be irate if the development overruns the existing settlement. There must be a way of recognizing that communities live in towns and villages, which they would like to be sustainable, and not functional areas. This should be attained by building on brown field sites; green field sites should only be considered for an appropriate level of development to fulfil the needs of and in proportion to the size of the community. Only then could the vision of South Lakeland in 2025 say ‘Towns and villages have been kept distinct from one and other by protecting important green gaps.”

This applies to PO1 Location Strategy page 37. The settlement hierarchy must include building on brown field sites at the top. This should have been an option on the sustainability appraisal and would have answered the problems of natural resource issues without compromising the access to services, biodiversity and landscape

3.44 - 3.51 Policy Context and Justification

46 3.44 PO 2

Neither support nor oppose - just want to comment

We consider that ecosystems services should be mentioned in this paragraph.

Ecosystems services are the services that biodiversity provides to human beings, and include products like clean drinking water and processes such as the decomposition of wastes. Ecosystem services are distinct from other ecosystem products and functions because there is human demand for these natural assets. , Some of these ecosystem services are well known including food, fibre and fuel provision and the cultural services that provide benefits to people through recreation and appreciation of nature. Other services provided by ecosystems are not so well known. These include the regulation of the climate, the purification of air and water, flood protection, soil formation and nutrient cycling (Defra 2007)

see above

3.44 - 3.51 Policy Context and Justification

PO 2 Page 48 3.49

Neither support nor oppose - just want to comment

We consider that “rural diversification” in this paragraph should be changed to “sustainable rural diversification”.

Rural diversification should be sustainable in order to meet the coming challenges of peak oil. A more balanced and sustainable economy in a peak oil future will need to be locally based using local skills, and will help South Lakeland deal with the future where people will have to travel less and use more locally sourced products and services.

3.44 - 3.51 Policy Context and Justification

PO 2 3.51 Page 49

Neither support nor oppose - just want to comment

The vision for jobs, skills and regeneration should seek to encourage the locally produced agricultural products mentioned in this paragraph to be sold within the local area. This would be more sustainable, provide a reduction in the carbon footprint due to smaller distances travelled by products and would be useful in building a robust and resilient local food supply for the peak oil future.

see above

3.58 - 3.59 Options Considered: Alternative Distributions: Options 1-4

PO 3 Page 53- 58 3.59 to 3.67

Neither support nor oppose - just want to comment

PO3 Distribution of Development 3.59
As in PO5 Option 5, we again suggest that the term “environmental capacity” should mean that land highly likely to flood eg flood plains, should be excluded from the development area. This must be a local issue to be considered.
It will affect the development land available in Kendal , Ulverston and Milnthorpe at least and will probably change the percentages of building in areas mentioned 3.61 to 3. 65

3.64 This again mentions the concept of functional areas, which we believe will be unacceptable to the public, who consider themselves to belong to a specific community, not a functional area. We consider that what the document calls flexibility will be interpreted as a licence to impose a disproportionate amount of development on small communities that are unlucky enough to be brought into functional areas. Strong cooperative communities are important for coping with transition situations and we consider it a grave mistake to risk the disruption that this could cause.

Sustainability Appraisal
3.67
The Sustainability Appraisal conducted by SLDC was unfortunately a combination of the UK Government’s Sustainability Appraisal, which includes economic and social issues and the EU’s Strategic Environmental Assessment, which made for a muddled assessment. The issues of disproportionate development in small communities in a functional area must have been overlooked.

see above

3.69 - 3.78 PO4 - Balanced Housing Market - You Told us That & Introduction

Page 59 - 3.69 3.71 and 3.74

Neither support nor oppose - just want to comment

PO4 Balanced Housing Market
Considering Strategic Objective 1 to meet all local housing needs; whilst agreeing that affordability is a priority, we consider that environmental performance is equally important , especially to those in affordable housing. This situation is likely to become more important as climate change progresses. We would like to see the local authority asking for a higher standard of performance than contained in building regulations and note that the new Planning Policy Statement, paragraph 13 states that ‘Where planning authorities wish to require higher levels of building performance, because of local development or site specific opportunities, the expected local approach should be set out in advance in a development plan document. For new homes local standards should be based on the Code for Sustainable Homes” We urge the local authority to proceed as soon as possible to zero carbon development , if possible well before 2016.

3.69 Considering the difficulty in selling properties around the district at the present time, and the general state of the housing market, the total number of houses to be built sounds excessive. Although affordable properties are necessary in this area, this should not be an excuse for excessive building in other categories. This is a total waste of resources. SLDC should ask the RSS to reconsider. Other sources of funding should be available.(also applies to 3.84 to 3.91)
3.71 It is important for extension of development land on to green field sites to be permitted only as a last resort. It is vitally important that biodiversity is allowed to flourish in as many areas as possible. Many of our eco-system services are under stress. Brown field sites must be sought.
3.74 The Housing Market Area underpinned by PO1 and PO3 does not result in a fairer solution for small communities incorporated into functional areas for reasons mentioned in option 6.

3.96 PO5 - Sustainable Economy - You Told Us That & Introduction

Page 76

Neither support nor oppose - just want to comment

PO5 Sustainable Economy.
We notice that ‘sustainable economy’ is not mentioned in the glossary, but sustainable development is; we agree with this as a broad definition. Sustainability Appraisal includes ‘a plan to ensure economic development is in accordance with sustainable development, so we conclude that a sustainable economy does not mean continual growth. We feel this should be made clear, as this is believed to be possible by some.

3.96.
We are delighted that development of appropriate renewable energy installations are mentioned. On-shore wind also needs to be mentioned, as this generates cheaper electricity and should have a place in South Lakeland, to contribute to Cumbria’s renewable energy targets and offer employment opportunities . Off-shore wind does not contribute to the county’s targets

Travelling to work outside Cumbria should be discouraged as this adds enormously to our carbon footprints.

see above

3.97 - 3.102 Options Considered: Alternative Sustainable Economy Options; Options 1 - 5

Option 5

Support

Option 5. We support the use of Shenstone (option 5a) as a freestanding local employment site. This could be developed as a flagship employment site with an environmental focus at eh gateway to Kendal. Wind turbines and reedbed sewage systems could send a clear message of sustainability and at the same time overcome the problems of connection to mains systems at the site.

3.12 - 3.16 Options Considered: Alternative Locational Strategies: Options 1-7

Page 91 Sustainability appraisal 3.122

Neither support nor oppose - just want to comment

Sustainability Appraisal.
3.122 The negative scores focussed on the environment and natural resources should not be ignored. For many people these issues are an optional extra to our lives, but in reality they are what makes life on earth possible. Without the services we receive from our ecosystem, life would not be possible. Just because we do not attach a price to them does not mean they have no value. Indeed a team of researchers from the US has attempted to put a value on eco-system services,based on how much benefit mankind derives from all the services such as soil formation, crop pollination, climate regulation and found that they have much more value than any economy. (Costanza, R.et al (1997) The value of the world’s ecosystem services and natural capital. Nature, Vol. 387,pp.253-260
Some recognition of the value of the ecosystem is given in points 3 and 4 of the Strategic Objectives.

3.162 Alternative Options/ The Preferred Option - PO8 - Accessibility and Transport

Page 106-107

Support

Overall we support the focus on more support for sustainable options such as cycle paths and supporting the transfer of freight to rail. Options for sustainable transport in rural areas, as you recognise need to be considered as resulting from other strategies such as housing.

3.180 - 3.181 PO9 - Sustainable Development Principles - Introduction

P 112 PO 9

Neither support nor oppose - just want to comment

It is disappointing to see that ecosystem services have been omitted from the Sustainable Development Principles put forward in PO9. Ecosystem services are a very important part of sustainability as if they are not protected, environmental problems are more likely to occur. Ecosystem services contribute to economic welfare in two ways – through contributions to the generation of income and wellbeing and through the prevention of damages that inflict costs on society. Defra lays out the importance of ecosystem services in the following document
http://www.defra.gov.uk/wildlife-countryside/natres/pdf/eco_valuing.pdf
and indicates that they should be taken into account when formulating policy

We consider that the importance of ecosystem services should be spelled out in Policy PO9, possibly in point 12

“Safeguarding and enhancing the qualities of the natural and built environment and ensuring that ecosystem services are protected”

3.183 - 3.188 Policy Context and Justification

Page 113

Neither support nor oppose - just want to comment

We disagree with the assertion that an increase in value of the local economy should be a top priority for SLDC. In the coming decade, it is likely that dealing with the arrival of Peak Oil and adjusting to life without cheap and easy access to fuel will be the top priority of SLDC (see http://www.powerswitch.org.uk/ for a detailed explanation of Peak Oil)

SLDC needs to concentrate more on preparing the South Lakeland community for the arrival of Peak Oil and the changes that will come with it. The community will need to be resilient and able to work within an economy where the price of oil and fuel is high and rising.

We suggest that SLDC raises the priority of developing a path of action to reduce South Lakeland’s dependence on fossil fuels. We suggest that the Local Authority works with bodies such as Transition South Lakes to develop mechanisms to enable the community to survive and even thrive in the energy descent. This should include

Exploring and then following pathways of practical actions that will reduce carbon emissions and dependence on fossil fuels.
Building South Lakeland’s resilience, that is, its ability to withstand shocks from the outside, through being more self reliant in areas such as food, energy, health care, jobs and economics.

We consider that it is vitally important that SLDC considers and becomes involved in planning for an oil-poor future.

4.12 - 4.23 Policy Context and Justification

P 130 4.16

Neither support nor oppose - just want to comment

It is not clear from the wording what is being said. One could read from it that the Canal Head project will go ahead even if no way can be found to mitigate against any significant adverse impact on the River Kent SAC. However, if the effects on the Kent SAC can't be adequately mitigated against, then PPS9 states clearly that it cannot proceed, and indeed it would be unlwaful to do so.

The last sentence should read as follows:

As a consequence, it will be imperative that the AAP ensures the restoration of the canal has no significant adverse effect on the River Kent SAC to ensure the viablity of the project.

5.60 - 5.64 PO24 - Sustainable Energy - Introduction

Page 222

Oppose

This is the weakest option of the three and is the least appropriate given the circumstances (detailed below). Furthermore, given the alternative options, and the available evidence, it simply is not credible to suggest that this option strikes the 'best balance'.

l Oil is currently $135 a barrel and most experts forecast this to top £200 before the end of the year. Fuel prices are rising and are expected to continue to rise into the future. Fuel poverty cannot be addressed without ensuring new build housing has significant energy efficiency and on site renewable energy generation.
l Climate change requires immediate and urgent action, not least from housing. A significant reduction in carbon emissions from housing can only be achieved by ensuring on site renewable generation, increased energy efficiency and reducing the carbon costs associated with construction (embedded energy). PO24 makes no distinction between these three key areas and simply lumps them all together. In theory, a developer could construct homes, achieve a 10% reduction in carbon emissions during construction, and yet install little or no energy efficiency or on site renewables. This ensures that the carbon costs of running homes will not be reduced, and also that householders will have to deal with spiralling energy bills. To suggest such housing is 'affordable' is, at best, highly misleading.
l It is suggested on p223 (5.70) that 'placing overly demanding requirements on new housing could jeopardise their viability'. The need to address climate change and fuel poverty cannot in any way be considered 'overly demanding requirements'. More to the point, addressing these urgent concerns must be considered a fundamental baseline of any new housing developments. It is simply not responsible, and indeed is not consistent with 'the main challenge – to limit climate change', to place short term financial gain for developers over the threat of climate change and the need to ensure new homes are affordable to heat.
l No mention is made in PO24 of what baseline will be used to measure a 10% reduction in carbon emissions. Without such a baseline the policy is simply not coherent or effective.
l The threshold of 10 dwellings is not appropriate or consistent with addressing climate change. All new buildings in South Lakeland should be included in PO24, unless it can be clearly shown that the majority of developments in South Lakes are typically of 10 dwellings or more, or greater than 1000m2 of non-residential floorspace

All developments to achieve a 10% reduction in carbon emissions, over and above the regulations in force at the time, over the lifetime of the development. The 10% reduction is reduced accordingly where existing building regulations would leave developers requiring reductions of over 100%.

All new developments should achieve at least a 10% reduction in carbon emissions. The greater portion of this saving should be through energy efficiency measures (include any achieved through the design and layout of the development) and/or on site renewables.

All new developments should incorporate rain water harvesting.