Local Development Framework Consultation

2.18 - 2.27 Spatial Vision for South Lakeland in 2025

Paragraphs 2.22 (page 15)

Oppose

We are objecting to an omission in para 2.22

In para 2.22 the text says "New development is of high quality based on a clear understanding of the local context, integrated with surrounding areas, creating a sense of place"

Cumbria Wildlife Trust wants to see this sentence read "New development is high quality, sustainable, energy efficient, based on a clear understanding of the local context, integrated with surrounding areas, creating a sense of place"

Sustainability of design needs to be emphasised as much as possible throughout this document, and the vision of South Lakeland in 2025 needs to include this right at the start

As indicated above, the sentence should be changed to "New development is high quality, sustainable, energy efficient, based on a clear understanding of the local context, integrated with surrounding areas, creating a sense of place"

Submitted to the Secretary of State for independent examination

Adopted by the District Council

2.18 - 2.27 Spatial Vision for South Lakeland in 2025

Paragraphs 2.22 (page 15)

Oppose

We are objecting to an omission in para 2.22

In para 2.22 the text says "New development is of high quality based on a clear understanding of the local context, integrated with surrounding areas, creating a sense of place"

Cumbria Wildlife Trust wants to see this sentence read "New development is high quality, sustainable, energy efficient, based on a clear understanding of the local context, integrated with surrounding areas, creating a sense of place"

Sustainability of design needs to be emphasised as much as possible throughout this document, and the vision of South Lakeland in 2025 needs to include this right at the start

As indicated above, the sentence should be changed to "New development is high quality, sustainable, energy efficient, based on a clear understanding of the local context, integrated with surrounding areas, creating a sense of place"

Submitted to the Secretary of State for independent examination

Adopted by the District Council

2.18 - 2.27 Spatial Vision for South Lakeland in 2025

2.18 - 2.27 Spatial Vision for South Lakeland in 2025

Oppose

We are opposing the omission of the natural environment from the Vision for South Lakeland in 2025. It is disappointing to see that SLDC does not consider a healthy and thriving natural environment as one of their visions for South Lakeland in 2025.

Cumbria Wildlife Trust suggests that the following statement or something like it is added to the Vision.

South Lakeland has a high quality natural environment with thriving biodiversity and living landscape networks including a year on year increase in populations of protected species and habitats; with healthy and robust ecosystem services contributing to protecting and enhancing the lives of residents and visitors alike.

Adopted by the District Council

Submitted to the Secretary of State for independent examination

2.18 - 2.27 Spatial Vision for South Lakeland in 2025

2.18 - 2.27 Spatial Vision for South Lakeland in 2025 (pages 15 and 16)

Oppose

We are opposing the omission of the natural environment from the Vision for South Lakeland in 2025. It is disappointing to see that SLDC does not consider a healthy and thriving natural environment as one of their visions for South Lakeland in 2025.

Cumbria Wildlife Trust suggests that the following statement or something similar is added to the Vision.

In 2025 South Lakeland has a high quality natural environment with thriving biodiversity and living landscape networks, including a year on year increase in populations of protected species and habitats; with healthy and robust ecosystem services contributing to protecting and enhancing the lives of residents and visitors alike.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

2.28 - 2.38 Strategic Objectives

Page 17 Section 2.31

Neither support nor oppose - just want to comment

Cumbria Wildlife Trust would like to ensure that development on brownfield sites does not take place to the detriment of biodiversity as brownfield sites are often hotspots for protected species and habitats.

A note that brownfield sites are often of very high biodiversity value compared to surrounding agricultural/greenfield land.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

2.28 - 2.38 Strategic Objectives

Page 18 Para 2.32

Support

We are happy to support this paragraph, however we would like to see the word "enhance" rather than "improve" used in the sentence where it says "The council will work with partners and stakeholders (including parish and town councils) to improve biodiversity"

The word "improve" has connotations in land management of making land better for agriculture (i.e. improved grassland for grazing) which is always detrimental for biodiversity. The word "enhance" is more appropriate.

Change the sentence to "The council will work with partners and stakeholders (including parish and town councils) to enhance biodiversity"

Adopted by the District Council

Submitted to the Secretary of State for independent examination

2.28 - 2.38 Strategic Objectives

Page 20 Para 2.38

Oppose

Cumbria Wildlife Trust considers that Strategic Objective 10 "To ensure that new development contributes towards community benefit" should include benefiting the natural environment. The natural environment is of benefit to local communities' health and wellbeing through the provision of ecosystem services (http://www.defra.gov.uk/wildlife-countryside/natres/pdf/eco_valuing.pdf) and as such should be considered as part of the contributions that any new development brings to the wellbeing of the community.

The second sentence of 2.38 could read "... This includes a pleasant and safe environment, a robust natural environment and access to services and facilities."

Submitted to the Secretary of State for independent examination

Adopted by the District Council

2.28 - 2.38 Strategic Objectives

Page 18 Para 2.32 Key Policy Cross References

Neither support nor oppose - just want to comment

The Key Policy cross references should include the Biodiversity Action Plan.

Add Biodiversity Action Plan to the list of references.

Adopted by the District Council

Submitted to the Secretary of State for independent examination

3.44 - 3.51 Policy Context and Justification

Page 47 Para 3.44

Support

We agree with the statement that "It is vital to protect the countryside for its beauty, diversity and natural resources and for its ecological, agricultural and recreational policies"


We would like to add that it is important to protect the countryside for the vital ecosystem services that it provides. Defra defines ecosystem services as "Services provided by the natural environment that benefit people." (information here :http://www.defra.gov.uk/wildlife-countryside/natres/pdf/eco_valuing.pdf and further information here: http://www.parliament.uk/documents/upload/postpn281.pdf) More information from the Defra document can be found below:


II Ecosystem services are defined as services provided by the natural environment that benefit
people. While there is no single, agreed method of categorising all ecosystem services, the
Millennium Ecosystem Assessment framework is widely accepted and is seen as a useful
starting point.


III Ecosystem services provide outputs or outcomes that directly and indirectly affect human
wellbeing, and these considerations can link well to taking an economic approach. The
underlying case for the valuation of ecosystem services is that it will contribute towards better
decision-making, by ensuring that policy appraisals fully take into account the costs and
benefits to the natural environment and by highlighting much more clearly the implications
for human wellbeing, while providing policy development with new insights.


IV 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. These services are not generally considered within policy appraisal at
present and represent an area where a greater and more systematic focus would be very
useful.


V The appraisal of new policies, programmes and projects all require environmental impacts to
be taken into account. The approach to the valuation of ecosystem services presented in this
Guide is not intended to be an additional step within the appraisal process but, instead, a
common methodology that can be used in order to consider the impact of our actions on the
environment. The environmental impacts currently taken into account in policy appraisal can
generally fit well within this broad framework.


VI This broader framework allows a shift in emphasis from a focus mainly on valuing
environmental damage to highlighting the value of changes in the services provided by the
natural environment. 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. Both types of benefits should be accounted for in
policy appraisal. With a broader focus on valuing the benefits provided by ecosystems, policy
options that enhance the natural environment are also more likely to be considered that
demonstrate that investing in natural capital can make economic sense.

We would add ecosystems services to the list of reasons to protect the countryside in the first sentence of the Justification in paragraph 3.44. It would also be helpful to add the definition of "Ecosystem services" to the glossary at the back of the document.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

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

Pg 76 Para 3.96

Support

Cumbria Wildlife trust supports the potential for development of opportunities arising from biodiversity in South Lakeland.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

3.127 - 3.133 PO6 - Town Centres And Retail Strategy - You Told us that & Introduction

Page 92 "You told us that" bullet 6

Support

Cumbria Wildlife Trust agrees with the assertion that Redevelopment of town centres should take into account urban biodiversity and that opportunities should be sought to create open spaces as a part of all development and to incorporate green corridors/stepping stones wherever possible.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

3.145 - 3.149 PO7 - Green Infrastructure - You told us that & Introduction

Page 99 Para 3.145

Support partly

Cumbria Wildlife Trust supports this paragraph. However, the Trust would like to see the concept of ecosystem services mentioned in this section as ecosystem services (which are defined by Defra as "services provided by the natural environment that benefit people") are important in their own right for supporting air and water purification and flood prevention as well as recreation opportunities and food and fuel for people. Ecosystem services need to be factored into the core strategy, as without policies protecting them, the population of South Lakeland could be exposed to increased flood risk, poor water quality and other environmental risks. Information about Ecosystem Services can be found at http://www.defra.gov.uk/wildlife-countryside/natres/pdf/eco_valuing.pdf

The Trust suggests that Ecosystem Services are specifically mentioned in this section of the document and that they are a priority to be protected in the face of a changing climate.

Adopted by the District Council

Submitted to the Secretary of State for independent examination

3.145 - 3.149 PO7 - Green Infrastructure - You told us that & Introduction

Page 100 para 3.147

Support partly

Cumbria Wildlife Trust supports this paragraph, however the Trust would like to add ecosystem services as one of the major contributions of the natural environment to the District (ecosystem services are defined by Defra as services provided by the natural environment that benefit people - more information can be found here http://www.defra.gov.uk/wildlife-countryside/natres/pdf/eco_valuing.pdf)

The Trust is concerned that no mention has been made of the presence of County Wildlife Sites in the District. There are 152 County Wildlife Sites in South Lakeland (outside of the National Parks) and they have a total area of 1958ha and are a very important part of the green infrastructure in the district, acting as corridors and stepping stones between the other designated sites and biodiverse areas within the District.

Add ecosystem services as one of the major contributions of the natural environment to the District. The number (152) and area (1958ha) of the County Wildlife Sites in the District should also be added to the list of elements.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

3.150 Alternative Options/ The Preferred Option - PO7 - Green Infrastructure

Page 101 PO7 Green Infrastructure

Support

Cumbria Wildlife Trust supports PO7. However, the Trust would like to see ecosystem services provided by the natural environment specifically mentioned in the policy (see http://www.defra.gov.uk/wildlife-countryside/natres/pdf/eco_valuing.pdf for more information). Ecosystem services (which are defined by Defra as "services provided by the natural environment that benefit people") are important in their own right for supporting air and water purification and flood prevention as well as recreation opportunities and food and fuel for people. Ecosystem services need to be added into PO7, as without overt policies protecting them, the population of South Lakeland could be exposed to increased flood risk, poor water quality and other environmental risks.

Add another point to PO7 Green Infrastructure which says "Protect ecosystem services which contribute to the economic welfare of the District in two ways – through contributions to the generation of income and wellbeing and through the prevention of damages that inflict costs on the population of the District"

Adopted by the District Council

Submitted to the Secretary of State for independent examination

3.150 Alternative Options/ The Preferred Option - PO7 - Green Infrastructure

Page 101 Policy Context

Neither support nor oppose - just want to comment

The Cumbria Biodiversity Action Plan should be added to the policies listed in the Policy Context box

The Cumbria Biodiversity Action Plan should be added to the policies listed in the Policy Context box

Adopted by the District Council

Submitted to the Secretary of State for independent examination

3.182 Alternative Options/ The Preferred Option - PO9 - Sustainable Development Principles

Page 112 PO9 Sustainable Development Principles 12.

Support partly

Cumbria Wildlife Trust does not consider that enough emphasis is placed upon safeguarding the natural environment and the ecosystems services that it provides in Policy PO9. The Trust considers that point 12 should be expanded to ensure that ecosystem services are mentioned and that they are maintained and enhanced to ensure that they are stable and strong enough to cope with a changing climate so that they can continue to protect the people of the District from possible environmental problems like flooding, soil erosion and water pollution.

We also consider that PPS9 should be added to the list of documents in the Policy Context as PPS9 and the Good Practice Guide specifically mention biodiversity and climate change

PO9 12 should be expanded to "Safeguarding and enhancing the qualities of the natural and built environment, including strengthening ecosystem services to work towards mitigating against the effects of climate change."

Add PPS9 to the list of policies in the Policy Context box

Submitted to the Secretary of State for independent examination

Adopted by the District Council

3.194 Alternative Options/ The Preferred Option - PO10 Developer Contributions

PO10 Developer Contributions point 7

Support

Cumbria Wildlife Trust supports developer contributions for biodiversity.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

4.1 - 4.4 Area Strategies

All of the area strategies - a general comment

Neither support nor oppose - just want to comment

Development in all the potential allocation areas may have an impact on biodiversity. Any area chosen to be put forward for allocation will need to be assessed against the Biodiversity Evidence Base (due to be released mid-June) to ascertain what potential effect they may have on biodiversity found on or off-site (species, habitats, protected sites). This risk will need to be assessed and some sites may not be suitable for allocation due to their biodiversity sensitivity.

Adopted by the District Council

Submitted to the Secretary of State for independent examination

5.44 Alternative Option / The Preferred Option - PO22 - Community Wellbeing

Page 214 PO22 Community Wellbeing

Support partly

Cumbria Wildlife Trust consider that Green Infrastructure should be added to the list in PO22, as access to the natural environment promotes health and wellbeing (CABE 2006, Natural England http://www.naturalengland.org.uk/campaigns/health/default.htm)

The Trust is concerned about the statement "Allow development of open space where there is a surplus in the locality based on set standards and the space is not required to meet a deficiency in any other type of open space". This needs clarifying as loss of open space could be detrimental to both community wellbeing and biodiversity.

Add a bullet point saying Policies in the Core Strategy will support green infrastructure to increase health and wellbeing and access to the natural environment for residents of the District.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

Preferred Option - PO24 - Sustainable Energy

Page 221

Oppose

Cumbria Wildlife Trust is extremely concerned that the recommendations of the Sustainability Appraisal of this strategy have been ignored and that the least effort for reduction in carbon emissions has been chosen as the Preferred Option. The reasoning behind this choice is flawed for the following reasons.

Fuel prices are rising and every development should be looking to incorporate energy efficiency and renewable technologies (especially solar hot water and ground/air source heat pumps) as a matter of course. Whilst oil prices were at $40 a barrel, the extra cost of energy efficiency and sustainability measures may have been offputting for house buyers and developers, but with fuel and electricity costs rising fast, and Peak Oil approaching if not already here with oil at $120 a barrel, a robust approach to installation of energy efficiency measures and small-scale renewables in every development makes total sense.

It's all very well having affordable housing, but if people are unable to afford to heat their houses or their water then the saving made by the developer and the housebuyer is a false economy as fuel poverty is something that will affect more and more people as fuel prices increase.

The Merton thresholds are probably inappropriate in a rural district where the majority of housing developments will not reach the ten dwelling threshold. South Lakeland should be making the effort to make all the new housing stock of the District as energy efficient as possible, both for reducing carbon emissions and for dealing with fuel poverty issues. The thresholds proposed are short-sighted and unlikely to be adequate in light of rising fuel costs.

A 10% reduction in carbon emissions for all developments and a sliding scale (upwards) for larger developments (see below).

All new dwellings or developments over 100 cubic metres should attain at least a 10% reduction in carbon emissions through energy efficiency measures and renewables. A sliding scale for larger developments should be implemented where thresholds of 15%, 20% and 25% reductions in carbon emissions through energy efficiency measures and renewables are implemented for developments over, for example, 10, 50 and 100 dwellings.

All new development should incorporate rainwater harvesting schemes and larger developments (over 10 dwellings or 1000 square metres) should incorporate grey water recycling.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

Alternative options : Options 1 - 3

PO11 Option 1 page 121

Oppose

Cumbria Wildlife Trust opposes this option to regenerate the Kendal Canal Head area as it has not yet been proved that bringing the canal to Kendal will not have a catastrophic effect on the River Kent Special Area of Conservation. Abstraction and discharge of water from and to the River Kent brings the threat of transmission of diseases, pollution and alien species into the Special Area of Conservation.

This option should not even have been included in the Preferred Options document as it has not yet had an Appropriate Assessment carried out to ascertain the level of threat. If there is likely to be a Significant Effect on the SAC, then this option cannot go forward (under the Conservation (Natural Habitat &c.) Regulations 1994 (Habitat Regulations)). This part of the document is therefore unsound and should be removed from the Preferred Options until an Appropriate Assessment has been carried out *and* has found that there will be no adverse effect on the internationally protected site. If this cannot be found then the option of the canal being brought to Kendal will not be available.

The Trust is particularly appalled by the fact that the threat to the SAC has not even been mentioned in the negative side of the options. This is an issue of international environmental law that SLDC do not seem to take at all seriously.

Cumbria Wildlife Trust have made more detailed comments about this option in its Canal Head AAP consultation response.

Delete PO11 Option 1 as it is unsound due to no Appropriate Assessment having been carried out and because the negative impacts of the proposed option have not been given any weight at all in this Option.

Use the canal head area without a canal to allocate as a prime area for housing development.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

4.53 - 4.59 Policy Context and Justification

Table 5 page 160

Neither support nor oppose - just want to comment

There is a Limestone Pavement Order in the South West Grange (Land at Kents Bank) town extension (Preferred Direction of Growth 2). This is to the east of the site and is part of the Wartbarrow & Kirkhead Limestone Pavement Order. Limestone Pavement is protected under the Wildlife and Countryside Act 1981.

This should be flagged as a constraint on potential development

Submitted to the Secretary of State for independent examination

Adopted by the District Council

The Preferred Option - PO13 - Grange-over-Sands Functional Area 2025

Page 156

Neither support nor oppose - just want to comment

Cumbria Wildlife Trust would like to see acknowledgement that Grange-over-Sands is one of the most important settlements in Cumbria for its Limestone Pavement resource; and to ensure that any allocations or proposals for the Grange Functional Area respects the Limestone Pavement Orders which extend into the town in a number of places.

Add some information about the value of Limestone Pavement as a habitat and indicate that it is a constraint on development within Grange and its surrounding area.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

4.12 - 4.23 Policy Context and Justification

Table 3 Page 133 Preferred Direction of Growth 1. North West Kendal

Neither support nor oppose - just want to comment

There is the potential that this site may have an adverse effect on the water quality of the River Kent SAC. A rigorous assessment of drainage matters will be needed to ensure that there won't be pollution incidents from run-off and sewage during and after heavy rain. An Assessment of Likely Significant Effect will be needed to ascertain whether an Appropriate Assessment should be undertaken for this site.

There are also concerns about potential loss of the wildlife found at this site. Although it is not designated as a County Wildlife Site, the local residents have records of a number of valuable plant and animal species, especially in the marshy areas in the east of the fields. The site is also bounded by hedgerows which will need assessing for their wildlife value.

Protected species on or using this site include bats and a number of red and amber listed bird species. A rigorous survey of the site will need to be carried out if any development is proposed, and any development must incorporate biodiversity friendly elements so that there is overall no net loss of biodiversity.

Acknowledgement that the site may be sensitive for its biodiversity or have potential negative effects on the River Kent SAC which will need to be investigated thoroughly.

Submitted to the Secretary of State for independent examination

Adopted by the District Council

4.12 - 4.23 Policy Context and Justification

Table 3 Preferred Direction of Growth, Option 4 South East Kendal

Neither support nor oppose - just want to comment

There is local knowledge that this field is used for nesting by lapwings. Lapwings are a declining species under threat in the UK and loss of breeding habitat would mean that compensatory habitat of a similar or greater size would need to be found if this site were to be allocated for proposed development.

Submitted to the Secretary of State for independent examination

Adopted by the District Council