SAVE ACTION GROUP RESPONSE TO INSPECTORS MATTERS, ISSUES AND QUESTIONS SITE ALLOCATIONS PLAN EXAMINATION MATTER 5

1. MATTER 5 - INFRASTRUCTURE Issue – Whether the necessary infrastructure will be in place to support the planned development.

Question 1. Is the process of identifying the infrastructure requirements arising from the proposed allocations set out in the SAP, as identified in the Infrastructure Background Paper (CD1/35) sound?

1.1 SPAG has analysed the Infrastructure Background Paper (CD1/35) with regards to the site MX2-39. We acknowledge that the paper covers issues with a broad brush approach for (“LCC”) generally, but when assessed for MX2-39 it is apparent that large parts of the CD1/35 are unsound. Below are relevant points from the CD1/35 document with comments. Our conclusion is that the proposed infrastructure for MX2-39 is UNSOUND.

CD1-35 heading Comments 1.2 Purpose of the Page 7 The paper commits to working with communities and through Infrastructure point neighbourhood planning. SPAG contends that LCC has not Delivery Plan 1.3 worked with its communities and can provide evidence of this regarding MX2-39 1.3 Developing the SAP Page 8, The paper states that LCC has consulted with organisations such Infrastructure point as Highways . In March 2017 SPAG met with HE, who requirements 1.5 had no knowledge of the extent of MX2-39. SPAG can provide evidence that this statement is false, and therefore UNSOUND. To date, there is no report from Highways England with regards to MX2-39. 1.4 Developing the IDP Page 8 This was undertaken in April 2013, and LCC’s methodology was point applied to the sites proposed at that time. Whilst it is 1.8 recognised that the IDP is a living document the withdrawal of Headley Hall and its replacement with MX2-39 did not benefit from this process. SPAG has no evidence that this part of the IDP was applied and therefore contends that this makes the allocation of MX2-39 UNSOUND.

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SAVE PARLINGTON ACTION GROUP RESPONSE TO INSPECTORS MATTERS, ISSUES AND QUESTIONS LEEDS SITE ALLOCATIONS PLAN EXAMINATION MATTER 5

CD1-35 heading Comments 1.5 Infrastructure Page The document states that the “most appropriate sites for SAP Delivery – site 10Point and AVLAAP allocations have been proposed having regard to specific plans 1.10 planning, highways, environmental and other considerations. This site selection process has been informed by the consultee comments of infrastructure providers or technical planning consultees. Some allocations contain site specific requirements relating to infrastructure. These set out where sites cannot come forward without delivering infrastructure improvements or contributing land or payments towards locally identified priorities.” SPAG contends that this is not true for MX2-39 and considers the process to be therefore UNSOUND. 1.6 Infrastructure Page 10 The Neighbourhood Development Plans for Aberford and Delivery – Point District Parish Council and for Barwick In Elmet and Scholes Neighbourhood 1.11 Parish Council have no desire for MX2-39. Both NDPs perceive Plans; MX2-39 as a destructive house building scheme that benefits no residents in this part of Leeds. In this regards LCC’s statement in this document is false. SPAG believes that the process is therefore UNSOUND.

1.7 Community Page 10 The CIL should benefit the villages in which houses are to be Infrastructure Levy Points built in SAP. MX2-39 impacts Aberford and District Parish but and S106 1.14 to significantly impacts and dramatically affects Barwick In Elmet Agreements 1.24 and Scholes Parish. Yet the Barwick In Elmet and Scholes Parish Council will receive no CIL money. This is UNSOUND as the proponents and protagonists of MX2-39 intend to use Barwick’s road and infrastructure facilities in this house building project.

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SAVE PARLINGTON ACTION GROUP RESPONSE TO INSPECTORS MATTERS, ISSUES AND QUESTIONS LEEDS SITE ALLOCATIONS PLAN EXAMINATION MATTER 5

CD1-35 heading Comments 1.8 Other Funding Page 14 As MX2-39 was proposed late in the SAP process SPAG believes Sources point that LCC has not allocated funding for infrastructure for this 1.32 to allocation. The stated delivery strands regarding MX2-39 are 1.34 unclear and as this site is located in between 2 ancient villages (Aberford and Barwick In Elmet) and an ancient town () the Parlington site acts to prevent urban sprawl. The infrastructure is already under stress and cannot cope with a large concentration of more people and motor vehicles. SPAG believes that the document is UNSOUND. 1.9 Physical Page 17 The Transport Strategy (EB9/18) states 3 Infrastructure - point objectives: Transport 2.6 1). Improve connectivity and reduce congestion- thereby increasing business productivity and providing access to wider labour markets; 2. Have a positive impact on our built and natural environment -increasing longer term resilience against climate change; 3. Create a 'sense of place' – encouraging walking and cycling for health and other benefits and increasing access in a safe way;

SPAG has received no evidence that LCC will achieve these objectives at MX2-39.

1.10 Physical Page 17 The points on the list are not covered in MX2-39. This site will Infrastructure - point add an enormous burden to all the points listed. SPAG has Transport 2.7 evidence to demonstrate that LCC cannot deliver these and therefore CD1-35 is unsound (with particular reference to the 2nd access road which LCC nor M & G have revealed as at the time of writing this response);

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SAVE PARLINGTON ACTION GROUP RESPONSE TO INSPECTORS MATTERS, ISSUES AND QUESTIONS LEEDS SITE ALLOCATIONS PLAN EXAMINATION MATTER 5

CD1-35 heading Comments 1.11 Physical Page 18 MX2-39 will create a car dependent community reliant upon Infrastructure - point M1 J47 and ancient country lanes. In this regard SPAG believes Transport 2.11 that the document is UNSOUND.

1.12 Public Transport Page 19 SPAG believes that none of these proposals will benefit MX2- Major Schemes point 39; 2.16 1.13 Buses Page 20 The measures listed do not benefit MX2-39 as the site is points approximately 11 miles from the centre of Leeds and the 2.17 to routes to the site are either via the or along 2.19 winding country lanes (some of which are so narrow that motor vehicles must traverse in a voluntary tidal system). The improvements discussed in the document appear to be of benefit to inner city residents. 1.14 Buses Page 20 These schemes are based on the use of motor vehicles from point the houses to the Park and Ride site. In Leeds the Park and Ride 2.19 sites offer no alternative to the use of cars as part of the journeys into and out of Leeds. 1.15 Railways Page 22 Whilst SPAG lauds the proposed improvements to the railways Point systems in and around Leeds, MX2-39 is expected to create 2.20 vast amounts of new commuter traffic. SPAG has evidence to show that MX2-39 is UNSOUND because LCC has not mitigated the increased demand placed upon the local railways infrastructure which are already at overcapacity. In addition to the above HS2 will traverse the land adjacent to MX2-39 and SPAG expects its construction to consume a wide path around M1 J47. We believe that construction traffic fetching materials and removing spoil will be an enormous burden to the M1 and particularly J47 for many years;

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SAVE PARLINGTON ACTION GROUP RESPONSE TO INSPECTORS MATTERS, ISSUES AND QUESTIONS LEEDS SITE ALLOCATIONS PLAN EXAMINATION MATTER 5

CD1-35 heading Comments 1.16 Cycling Page 23 Leeds Core Cycle Network is not planned to extend to MX2-39; point 2.27 to 2.29 1.17 Pedestrians Page 25 This is a very important matter for SPAG. The majority of points ancient country lanes around MX2-39 do not have footpaths 2.30 to and this makes walking and running very dangerous. Before 2.33 committing to MX2-39 we advise LCC to undertake a survey of footpaths and develop a solution to this lack of footpaths. Any widening of roads to build footpaths will consume more Green Belt land. 1.18 Highways Page 26 As at the time of writing this response, Highways England had points not submitted its report about M1 J47. SPAG requests and 2.38 to reserves the right to discuss this at the public examination. 2.42 Based on current information we believe that M1 J47 and its feed roads will require significant mitigation. In addition is the added burden that will be imposed on the M1 and junctions by the construction of HS2.

1.19 Waste management Page 32 MX2-39 would create vast amounts of domestic waste which point will require motor vehicles to frequently and regularly enter 2.67 the site. The network of ancient country lanes around the site will make the journeys to and from the site to Leeds 9 long and slow. If the RCVs are not allowed on the M1, then the route to the incinerator will be negatively impacted for other road users. SPAG believes that LCC will not be able to mitigate this matter and this makes the site UNSOUND.

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SAVE PARLINGTON ACTION GROUP RESPONSE TO INSPECTORS MATTERS, ISSUES AND QUESTIONS LEEDS SITE ALLOCATIONS PLAN EXAMINATION MATTER 5

CD1-35 heading Comments 1.20 Minerals Page 33 MX2-39 will require vast quantities of building materials over point the initial period of building the supporting infrastructure. 2.72 SPAG believes that its infrastructure would have to complete before the first house can be built and then inhabited. This makes the site very expensive for the builder. The materials would have to be delivered to the site using the same road systems as the HS2 construction traffic and any construction vehicles for the house building at Sturton Grange, making this UNSOUND 1.21 Social and Page 34 SPAG can demonstrate that the current infrastructure is not Community Points designed, nor is it developed to cope with MX2-39. All the Infrastructure – 3.1 to points raised above concerning access, and the (recently education, health 3.46 rationalised) blue light services would have to enter the site services and from the M1 (there is no information currently about the 2nd emergency services. access route). As an example of the difficulties for Fire services, the nearest fire station is at Killingbeck, and for a fire tender to get to MX2-39 it would be necessary for it to travel along the M1 to J47. This junction is already allocated for use by the HS2 construction traffic.

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SAVE PARLINGTON ACTION GROUP RESPONSE TO INSPECTORS MATTERS, ISSUES AND QUESTIONS LEEDS SITE ALLOCATIONS PLAN EXAMINATION MATTER 5

CD1-35 heading Comments 1.22 Green Page 45 MX2-39 will comprise 1,850 houses in 114 ha. Infrastructure and point green space 4.1 to This building site will therefore contain 1850/114 = 16 houses 4.19 per hectare or 1,600 houses per sq km. The population density based on 2 occupants of each house = 3,200 inhabitants/sq km The population density based on 3 occupants of each house = 4,800 inhabitants/sq km The 2010 population density of Hull from the Key Statistics data of 2012 reveal that Hull has a population of 264,000, living in an area of 71 sq km yielding a population density of 3,694 people per sq. km. SPAG is greatly concerned that MX2-39 will not offer its residents sufficient green space close to the houses to allow children to play.

1.23 EPOS (East Page 89 Site MX2-39 (Parlington) is believed to require a 2FE school to Partnership of meet demand generated by the site itself during the plan Schools) Villages period (Phase 1). Leading up to that the children inhabiting the South site will be a burden on the local schools in the surrounding villages and towns. (Outer North East/Outer South Additional primary school provision would need to be provided East HMCAs) on-site for any additional development beyond that planned in Phase 1 as part of the comprehensive development brief for the housing estate. The total number of forms of entry required would be dependent on the final agreed capacity of the proposed development. SPAG can demonstrate that this is unsustainable. The problem is compounded by Garforth’s sites and the associated demand there.

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SAVE PARLINGTON ACTION GROUP RESPONSE TO INSPECTORS MATTERS, ISSUES AND QUESTIONS LEEDS SITE ALLOCATIONS PLAN EXAMINATION MATTER 5

Question 2. Does the evidence demonstrate that the necessary critical infrastructure will be provided in a timely manner to support the planned delivery of development?

1.24 Submissions by LCC and the promotor of MX2-39 have not, to date, included any evidence that the necessary critical infrastructure will be provided in a timely manner to support the planned delivery of development. It seems remiss to SPAG that with a scheme of such a size and in such an isolated location, and therefore relying on such an amount of newly developed infrastructure, these details have not been provided since the Publication Draft in October 2016.

1.25 In addition to the table above, gas supplies, water networks and foul drainage are all considered to be necessary critical infrastructure. None of these are currently present throughout policy MX2-39 Parlington. As far as SPAG is aware, there is no evidence to suggest that these have been considered or assessed to ensure deliverability at this point.

1.26 Given all of the above there is no evidence to demonstrate that the necessary critical infrastructure will be provided for MX2-39 in a timely manner to support the planned delivery of 1,850 houses in Phase 1.

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