Local Development Framework Consultation

I oppose area 5, “ land behind Ullswater Road” being identified as a preferred direction of growth for Kendal, in particular for housing.a) I am not convinced that 400 houses per year are needed in South Lakeland, or that there is adequate evidence that it would reduce house prices. (demand from long distance commuters and retirees is practically unlimited).b) The proposals fail to take account of the embedded carbon in new building and the addition to the districts carbon emissions in the development phase. c) The proposals fail to take account of the likely economic downturn from fossil fuel depletion.d) However if national and regional policy force the issue, the detailed flood risk in and around Kendal should have been taken into account to reduce the proportion of housing in Kendal, or to direct it to areas that would neither flood nor cause flooding elsewhere. e) If the evidence of the SFRA and the SA had been considered properly, land in the Stock Beck catchment area should have been excluded. Flood events have occurred 3 times in the last 6 years, with the last one just held by the barely completed Stock Beck alleviation scheme. No spare capacity for increased run off, or increased storms due to climate change have been built in to the Potters Tarn balancing reservoir, and no evidence has been presented to say that it has. Over spill from the flood defence bund would have serious and even life threatening impacts on the houses below.
f) In addition to surface water run-off, groundwater flooding occurs in the Stock Beck catchment area. The SFRA says “Groundwater flooding may be an issue in and around Kendal due to the limestone geology of the area. Within such geological locations, flooding can occur where the water table reaches the surface, usually in localised depressions. However, seepages and springs can appear anywhere” It is locally well known that in very wet weather springs appear on the fields and adjacent to Ullswater Road, and ground water caused a significant need to dewater during the tunnelling for the Stock Beck scheme.g) The plan appears to rely on using development control principles to mitigate flooding through SUDs schemes, although there is no evidence presented to say that these can deal adequately with the extreme conditions from surface and ground water on the steep slopes to the east and west of Kendal. Also Development Principle P3 states that “Preference should be given to development on sites with no/minimal flood risk, ensuring that sites requiring mitigation measures are chosen as a last resort.”h) The alternative option of reducing or even removing “green gaps” has not been properly considered as an alternative to building up the fellsides around Kendal. Green “edges” may be more important to the character of Kendal in landscape terms. It has not been shown that area 5 is actually the “last resort”.i) Other impacts include: visual amenity for local residential areas - difficult to mitigate given the topography of the site; the viability of the farming units – contrary to the aim of supporting agriculture; loss of biodiversity – new housing (and the pets) would threaten the biodiversity of the railway “green corridor”; loss of informal recreation space – children play by the beck, and residents walk dogs across the footpath/fields.I therefore consider the Preferred Option to be unsound – as not coherent, nor having considered all the alternatives, or founded on a sound evidence base.

The fields between Ullswater Road and the main west coast railway line should be excluded from the Preferred Option, both the figure and the table. If other Preferred Options around the total number of new houses in the plan area cannot be reduced, or the distribution changed to reduce the need to develop within Kendal, then green gaps may need to be reduced, and “green edges” incorporated to create a green infrastructure through and around the town.