The Society’s response to the latest Flood Relief Scheme Planning Application. The Letter we sent to Planning Dept. SLDC 17th June 2022

SL/2022/0163 Waterside and Aynam Road KENDAL: Erection of flood defences along Waterside and Aynam Road. Amendments to Reaches G1, G2, G3 and H1 of the Kendal Flood Risk Management Scheme approved under reference SL/2018/0925.

Object:

Acting with the Friends of the Lake District, Historic England and many other organisations, Kendal Civic Society objected to the original planning application for the Environment Agency (EA)’s flood prevention proposals in Kendal - objections that were overruled.

We were subsequently asked by the EA to enter into discussions about some aspects of the scheme, in particular the details in the Conservation Area. We welcomed this opportunity to comment in order to try to mitigate the damage, but we have not changed our minds on the scheme as a whole. We still believe that it is fundamentally flawed. Common sense as well as the environmental science dictated that the upstream measures should have been carried out first and that the impact of these be incorporated into the computer modelling which has driven the design of the walls and engineering works in the Conservation Area. We believe that this would have meant a less intrusive, more environmentally friendly solution. We noted with interest last year’s (June 2021) change of heart by the EA as regards ‘concrete’ flood defences and their new focus on ‘nature based solutions’ (as widely reported in the press). This would in our view have been the correct way to proceed in Kendal and would have avoided the felling of so many mature trees and the brutal engineering works in the heart of the town. This change of heart at that time should have prompted a review of the Kendal scheme since construction work had not yet started – but no, instead, the EA with the support of SLDC has pressed forward in order to meet an arbitrary funding deadline. Kendal may be one of the last schemes in the country to be approached in this way, something that will, we feel, be a long term source of regret.

We do, however, accept that this argument was lost and we entered into the discussions in good faith to try to limit the worst aspects of the scheme. It is therefore with considerable further regret that we find ourselves having to object again formally to these detailed proposals.

We approached the matter in an objective and consultative frame of mind and attended a number of meetings by zoom and in person. We raised the following general points:

• that traditional details should predominate in the Conservation Area – particularly traditional stone coping details (not thin precast concrete slabs or soldier courses).
• that more suitable walling stone should be used (we find the sample overly neat)
• that fewer metal railings should be used, even if this means slightly higher, properly detailed stone walls
• that ‘printed concrete’ should not be used anywhere in the Conservation Area.
• that any glass insertions should be held in slender frames (not as those in Keswick)
• that the replica Webster railings idea should be abandoned in favour of a less enclosed design at this corner.
• that grassy banks should be used if at all possible rather than walls to preserve the open nature of the riverside.
• that suitable alternative locations should be found for the displaced Rishton railings and the fountain
• that further thought should be given (even at this stage) to arrangements on Aynam Road to allow some of the trees to be retained. In any event, the soft landscaping scheme should consist of planting suitable for a natural river bank (rather than an urban park). We also feel that the new trees should form a regular avenue along Aynam Road, similar to the original scheme for the road.

These comments are founded on good conservation design practice. This is a professionally acknowledged set of skills and attitudes that we feel has been sadly lacking in the design team since the beginning. This is not a personal criticism of the individuals with whom we have dealt who have always heard us politely and courteously. It is a criticism of the professional motivation and design skills in the team and the lack of authority and will to carry through good conservation principles. We take exception to EA’s publicised claim that they are - to quote - ‘preserving and celebrating Kendal’s heritage’. The devastating impact of this scheme is being greatly understated and the harm it is causing is barely referred to. They should be under no illusion but that it is doing immense and irreparable permanent harm to Kendal’s heritage. The measures taken in mitigation of this harm, welcome as they are, are completely inadequate given the scale of these interventions.

Our specific comments on the current proposals are as follows:

 

The glass panel design

It is arguable whether the introduction of glass into the Conservation Area is unequivocally a good thing (the panels at Keswick are rarely clean and look dreadful) but they will enable views, albeit restricted, into the river bank and we acknowledge that the detail of the metal framing is neat. However, this is badly let down by the design of the adjacent stonework, particularly the copings. The chamfered soldier course as seen in the sample is very poor indeed - both the design detail and the workmanship. A better detail would be a thick dressed natural stone coping to articulate the junction between these materials – no doubt a more expensive option, but given the magnitude of the harm being done, this would be a modest price to pay.

The awkward, stepped trapezoidal layout of the panels on Waterside introduces an unattractive modern twist to the whole idea of the glass panels and in this location we suggest that a properly detailed stone wall would be a better approach. The loss of the listed historic railings here with the flood dates inscribed on them, is greatly to be regretted and we are particularly upset that these are being discarded, not relocated.

 

Walling generally

We note that some of the stone walling in the area of the Parish Church has already been completed. The appearance of these high, long, dead straight, monotonous walls is, as many of our committee had feared, adding a distinctly alien looking insertion into the ancient town. The form of the walls contrasts starkly and unpleasantly with the gently curving river, the stonework is not well laid and the wall tops are not finished with traditional natural stone copings in keeping with the large profile copings that predominate on the old bridges and walls in the area. If this is the quality of what can be expected elsewhere we are emboldened in our concerns for the overall appearance of the completed scheme.

In addition, the use of ‘printed concrete’ in the Conservation Area is greatly to be regretted and we note that it is being used despite assurances to the contrary given in previous presentations.

 

The proliferation of railings

We regret the extensive use of new, close-centred metal railings throughout. This is not a characteristic feature of the Conservation Area. We understand the safety issues that arise given the height of the walls but we also believe that alternative approaches could be taken such as the grassy banking in the area of the arched entrance near the Parish Church. We note that in a few places the stone walls have been increased in height to avoid the need for such railings and generally welcome this. We believe that with creative thought and a proper consideration of the risks involved it would be possible to design out the railings in many other locations.

 

The replica Webster railings

We have been unable to find a coherent rationale in the application documents for this design approach. If this is what is meant by ‘celebrating Kendal’s heritage’ it is a completely misplaced and naïve misapprehension. It is not good conservation practice to replicate historic fabric in new materials in this way and here, of course, it introduces yet more new railings into the scheme. The effect is to further enclose the river bank and it will create a completely contrasting impression in comparison with the open nature of this corner at present. It is an unnecessary and inappropriate intervention. A less intrusive approach would be preferable (and less expensive), retaining as much of the open character as possible.

We were also concerned to note that there is no mention of repairing the short section of existing low railings on this side of Miller Bridge. These railings are an important part of the listed fabric and it is important to retain them.

 

Rishton Railings and Fountain

We note the intention to re-site some of the Rishton railings in the area between the new walls and the river and we generally welcome this. It is a pity that many will nevertheless be discarded.

We also note the intention to relocate the fountain in the wall near to its current location. Given its historic interest, we hope that a more appropriate location in the town can be found for this.

 

The flood gates

We note that there are to be many large, blank metal floodgates located in very prominent parts of the Conservation Area, some normally closed and some left open when not in use. These are illustrated as black painted steel which we do not consider is a suitable response to the harm they inflict. We look forward to seeing a more sympathetic treatment, perhaps incorporating some artwork, either in relief or painted. We note that this is under active consideration and welcome this.

 

Landscaping

The planting plans proposed between the river and the walls adjacent to Aynam Road include extensive informal shrub planting and an informal layout of the trees. This will tend to restrict the views of the river from the road, particularly if they are not regularly maintained by SLDC. We would favour a more formal scheme including a more regularly spaced avenue of trees, in line with the original layout of Aynam Road as seen in the historic aerial photographs. This could perhaps be combined with a low key planting scheme suitable for a natural river bank with an emphasis on providing the maximum biodiversity.

We welcome the new path in the area between the wall and the river which will be a popular route and we hope that the finish and details will be as natural as possible consistent with providing safe access for wheelchairs.

In conclusion, we are very disappointed to be in the position of formally objecting again to these proposals. Despite the various meetings, our views have not been taken into account – the EA has pushed through the scheme based on their own understanding of the principles of design in a Conservation Area which fall far short of what should be expected given the immense harm that is being done. A higher quality and more sensitive approach could reasonably be expected. Acknowledged conservation values have not been properly applied but, rather, the scheme is still led, as it has always been, by the flood engineers who have other priorities. The devastating impact of these proposals in the Conservation Area always required - and still requires - a more conservation based approach where serious, prioritised attention is given to the finished appearance to minimise the harmful impact.

 

Trevor Hughes

Hon. Sec. Kendal Civic Society