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Save Parlington Actiongroup SAVE PARLINGTON ACTION GROUP RESPONSE TO INSPECTORS MATTERS, ISSUES AND QUESTIONS LEEDS 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 Leeds City Council (“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 England. 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. ©SPAG Page 1 of 8 AUGUST 2017 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. ©SPAG Page 2 of 8 AUGUST 2017 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 (Garforth) 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 West Yorkshire 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); ©SPAG Page 3 of 8 AUGUST 2017 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 M1 motorway 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; ©SPAG Page 4 of 8 AUGUST 2017 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. ©SPAG Page 5 of 8 AUGUST 2017 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.
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