Local Development Framework Consultation

Thank you for the opportunity to comment on the above document.
The Highways Agency [the Agency] is responsible for managing and operating the Strategic Road Network [SRN] in England on behalf of the Secretary of State for Transport [SoST]. Amongst other activities the Agency is responsible for considering the potential impacts on the safe and efficient operation of the SRN that result from development proposals and initiatives.
Current Government policies towards developments affecting trunk roads stem from the 1998 White Paper ‘A New Deal for Trunk Roads in England’ with the principle of achieving effective integration between land use planning and transport at the national, regional and local level being promoted within Planning Policy Guidance Note 13: Transport [PPG13].
The Government’s most recent policy in this regard is set out further within Circular 02/2007: ‘Planning and the Strategic Road Network’. The way in which the transport implications of land use and development application proposals should be assessed is contained in the joint Communities and Local Government and Department for Transport [DfT] 2007 publication: ‘Guidance on Transport Assessment’ [GTA].
The Agency’s primary responsibility relates to the safe and efficient operation of the SRN; in response to this they are required to examine any proposals with a potential impact at the SRN. These impacts could be direct (i.e. development related trips or enhancing public transport provisions), or indirect (by adopting a sequential approach to location of new developments).
Strategic Road Network in South Lakeland
The Strategic Road Network within South Lakeland consists of the M6 and A590. The M6 is the longest motorway in Britain and runs from central England to the north of Carlisle. The motorway enters South Lakeland around junction 36, and travels north until it leaves the district at junction 39. The M6 provides access to Kendal, Windermere, Tebay, Appleby, Hackthorpe and Penrith.
The A590 intercepts the M6 at junction 36 and travels in an east-west direction to Barrow-in-Furness. The A590 passes close to Ulverston, Grange over Sands and Levens, and provides access to the businesses and residential areas located here.
The M6 is a national strategic route; the A590 is considered to be of regional importance. As a consequence, it is the Agency’s responsibility to take the necessary steps to ensure free flowing traffic movement is maintained on both of these routes and to take responsibility for granting any funding improvements. In addition, the Agency is interested in maintaining the safety of these routes, particularly at junctions with the local road network. The Agency would be concerned if, through land use planning policy, the development intensification creates safety issues and capacity problems on the trunk road network.
The Agency has been invited to comment on the South Lakeland Core Strategy Preffered Options document. This letter outlines the Highways Agency’s response to this document.
Spatial Options
The South Lakeland Core Strategy Preferred Options document states that, “by 2025, South Lakeland aims to be considered an inclusive, sustainable community with a choice of housing for all sectors of the community; a diverse, high value local economy; and a healthy, attractive and safe environment.” To achieve this objective, a preferred spatial development strategy has been developed, which outlines the preferred direction of growth for each service centre.
Sustainable development is outlined as a key theme associated with the growth of each of these areas. PO5 ‘Sustainable Economy’ states that all policies should take the following approach to the allocation of land in line with PO1:
1. Town Centres
2. Existing Urban Areas
3. Sustainable urban expansions.
Although new developments will be spread throughout South Lakeland, the impact of these developments on the strategic road network will be minimised through the effective implementation of this policy. Sustainable development is also outlined as a key requirement of both PO8 ‘Accessibility and Transport’ and PO9 ‘Sustainable Development Proposals’, which state that new developments should be situated in locations which are accessible by a variety of modes of transport, in particular public transport. PO8 goes on to state that sustainable transport options should become an integral part of development proposals, requiring the development of Travel Plans for new developments where appropriate.
The Highways Agency supports these proposals, and encourages the use of traffic mitigation measures to support all new developments. This will ensure that development takes place in the most sustainable way possible, and will minimise the impact of this economic growth on the surrounding strategic road network.
Four core strategies have been outlined within the South Lakeland Preferred Options document, each of which will be addressed individually in the remaining sections of this letter. These include:
· Development of Kendal as a Principal Service Centre;
· Development of Ulverston as a Functional Area;
· Development of Key Service Centres; and
· Development of Local Service Centres.
Kendal Functional Area
Kendal is outlined as an area of significant future growth and development, which will enable the town to be developed as a Principal Service Centre.
The Kendal Canal Head Area Action Plan provides a detailed breakdown of developments in the area, and outlines a ‘Masterplan’ for the town’s future development. The document indicates that the potential impact of the development stemming from the Area Action Plan will be carefully considered in conjunction with Cumbria County Council and indicates the need to consider appropriate mitigation measures to solve any potential problems associated with additional traffic levels. The HA welcome this approach and
recognises the need to carefully consider the potential transport impacts of such development on the surrounding road network. The Highways Agency would wish to continue to be closely involved in discussions as the master plan progresses.
The development and regeneration of land in the town is considered an essential element of achieving a healthy and prosperous economy. Where the opportunity exists, the Agency supports growth in the most sustainable locations so as to avoid developments with few or no public transport links and limited or no access on foot or by cycle. Kendal town centre is considered to be easily accessible by the public and sustainable transport modes, including bus, cycle and train, with Kendal Rail and Bus Station and Oxenholme train station located in close proximity to Kendal town centre. The Agency welcome plans to further enhance public transport links within the town.
However, the close proximity of Kendal to the M6 motorway could lead to an increase in traffic flow at junction 36, and as such, congestion on the surrounding road network. The proposed distribution of 43% of development within this area could result in a significant increase in traffic on the road network, and this should be carefully managed to ensure road safety or junction performance is not detrimentally impacted.
The Agency is in support of policies that see development located within established ‘urban’ areas where there are good public transport links and networks. The Agency is also keen to see brown field and windfall sites developed within town and local centres where good links to services and opportunities already exist. Notwithstanding this, the Agency may still need to comment on subsequent planning applications brought forward within the Kendall Functional Area should it be decreed that a proposed development could have an impact on the operation of the Strategic Road Network
Ulverston Functional Area
Ulverston is the second largest settlement in South Lakeland, and is located in close proximity to the A590 trunk road. The regeneration of Ulverston has already started through the Ulverston Market Town Initiative, but future proposals include:
· The expansion of the Ulverston Functional Area to accommodate an additional 28 hectares of retail and 20 hectares of employment development;
· The designation of the Ulverston Canal Head Area and Canal Corridor as the main employment area;
· The development of a small / medium supermarket and 2300m² companion shopping; and
· To support and enhance tourism within the town, including the development of the appropriate infrastructure to support this growth.
20.5% of housing and employment development within South Lakeland is outlined for Ulverston’s functional area, equating to the development of 48 hectares of land in this area. Improvements to the public transport network, so as to provide a comprehensive sustainable transport network, are also outlined for Ulverston to support this planned level of growth. It is hoped that, through these developments, Ulverston will become the second Principal Service Centre within the region.
These developments will, inevitably, lead to an increase in traffic growth on the A590. To minimise this impact, the Local Development Framework outlines plans to improve the junction between the A590 and North Lonsdale Terrace to support developments at Ulverston Canal Head and the Canal Corridor. In addition, the Core Strategy document outlines the requirement for all developments to be accessed by sustainable modes of transport and to take place in line with sustainable development principals. This should reduce the potential impact of this development, and will ensure that a minimal impact of these developments on the road network. However, the Agency will need to be fully engaged and consulted with regarding any future proposals related to potential improvements of the A590.
Development of Key Service Centres
Grange-Over-Sands, Milnthorpe and Kirby Lonsdale are outlined within the Core Strategy as areas of potential future growth, so as to develop them as a key service centres within South Lakeland.
Again, these proposals outline developments which are likely to increase traffic flow and congestion along the A590. However, the planning requirement to ensure development takes place in sustainable locations, close to the existing public transport infrastructure, should minimise any negative impact which these developments may have on the vitality and viability of the area.
Core Policies
The final section of the Core Strategy LDF document discusses a range of core issues and challenges facing South Lakeland, and outlines a number of key strategies for dealing with each of these. The core policies outlined include those for gypsies and travellers, travelling show people, tourism, education and skill development, community wellbeing, historic environment and sustainable resources. From the above list, the policies concerning tourism are considered to be of most relevance to the Highways Agency.
Tourism Industry
The tourism industry is one of the mainstream activities of the South Lakeland’s economy, it is forecast that tourism is predicted to arise predominantly from a growth in corporate business, conferences, exhibitions and short breaks in the area, and is likely to lead to a growth in traffic on the M6 and A590.
Two options are outlined within the Core Strategy to cater for this forecasted growth in tourism. The first option is to enable unlimited development, including on stand-alone rural areas outside service centres; the second option is to apply a more lenient approach to tourism development, allowing for the expansion and conversion of existing facilities and development of new facilities in sustainable locations only.
Option two is considered more acceptable to the Highways Agency than option one, as it aims to locate the majority of sites in more sustainable locations and is likely to minimise the impact of traffic growth on the local road network. All principal service centres are accessible by a range of public transport modes, which could be further exploited to meet visitor needs and hence provide a more sustainable development.
The Core Strategy LDF document for South Lakeland has allowed the Agency to gain an understanding and appreciation of development proposals to be brought forward in the area. Of primary concern to the Agency will be the development of Kendal and Ulverston, and specifically the potential impact of future developments on the M6 and A590 junctions. As such, any adverse impact on the aforementioned junctions should be addressed, and mitigation measures (if needed) identified and agreed with the Agency at the earliest opportunity. Where options have been identified the Agency would look to these being provided with a sound evidence base in looking if these are in suitable sustainable locations.
There is also the need to begin the development of a robust, evidence-based assessment of the transportation impacts of the Planning Guidance as early as possible in the planning process.
Tourism developments should take place in the most sustainable way possible, so as to maintain the natural and built environment, and to make best use of the existing tourist infrastructure in the area. As a rule, the Agency supports developments which are located in sustainable locations. Developments should have good access to public transport routes and connections; should outline a number of measures to reduce the usage of private cars; should provide a safe environment for cyclists and pedestrians; and should enhance social interaction, providing overall economic growth.
In general terms, the Agency supports improvements to the public transport network. Any improvements which reduce the use of the private car, in particular reduce single occupancy vehicle trips, and encourage greater use of cycling and walking infrastructure will be endorsed. We support connectivity throughout the region by the appropriate management of these measures.