Defence Infrastructure Organisation Base Support Wing Headquarters RAF Brize Norton Carterton, Oxfordshire OX18 3LX

Telephone: Ref: Dishforth/HBC-SA/May19 E-mail:

Gill Ritchie Principal Planner Planning Department – Place-shaping & Economic Growth Borough Council P.O. Box 787 Harrogate HG1 9RW

By email only to: 23 May 2019

Dear Gill,

HARROGATE BOROUGH COUNCIL EMERGING LOCAL PLAN – SUSTAINABILITY APPRAISAL - DISHFORTH

Further to your email dated 13th May 2019 on the above matter requesting comments on the Sustainability Appraisal in respect of the Dishforth site. We thank the Planning Authority for this opportunity to comment and please see below observations made on behalf of the Secretary of State for Defence.

Whilst we have been very critical of the approach taken in respect of the SA for Dishforth, we welcomed the Planning Authorities commitment to work with the MOD to bring forward proposals for the redevelopment of the site. Our comments should therefore be read in that context – to set the tone for the future work appropriately. We have no wish to delay the adoption of the Local Plan whilst such changes are being made / further work is undertaken to revise the SA.

If you have any questions arising, please contact me on in the first instance. Yours sincerely,

Stephen J Barrington Harness Chartered Town Planner, MSc MRTPI FWCMT 20190513 Dishforth Further Sustainability Appraisal work - OC18

Overall

At the earlier stages of the Local Plan preparation we commented that the Sustainability Appraisal did not include a supporting “key” and “definitions” to assist in its scrutiny and interpretation. Again, at this stage the document does not include such information. This unnecessarily opaque approach fetters proper engagement. Why are the scores omitted for many elements without justification? That will bias assessments. Without such definitions, the danger is that an inconsistent approach could be applied between sites unduly penalising some opportunities compared to others. As you will see from the comments below, that appears to have been the case for the Dishforth assessment. No scope for mitigation of any impacts identified appears to have been included in the SA. Such an approach appears to run contrary to the aim of the Local Plan. Such strategic locations, by virtue of their size will have obvious scope to contain elements which will mitigate the impacts identified. Indeed, the Planning Policies contained elsewhere in the existing and emerging Plans would require such provision – for example, the provision of school facilities to accommodate the needs arising from the development. Due to the scale of the Dishforth site, had the MOD been consulted during the preparation of the SA; it would have been happy to confirm that the identified issues in the SA could be mitigated. No account appears to have been taken in the SA of the need to positively plan for the future of this available site and replace the skills and employment being lost to the local economy if the site was to close without a new use having been supported through the Local Plan. As such the assessment will be unduly skewed towards the development of greenfield locations.

At paragraph 1.10:

We would request evidence to support the statement that a “small area of land has been made available”. We would point to the fact that the area of land made available is over 106 Hectares. Bigger than many strategic sites emerging in Local Plans across the country. So by no means could be termed a “small area”. The DF7 site as you will be aware is around 107 Hectares, so the amount of land represents a 100% increase – again not a “small” addition. We suggest that this paragraph should be reworded to represent this being a major strategic level addition and the assessment reflects that throughout.

Page 13 – Dishforth OC18 appraisal

We would welcome greater clarity on why the ”scores” identified for Dishforth do not appear to have been applied consistently when compared to other proposed sites. For example, for SA objective 4, the site has been classed as R due to the perceived “adverse impact on local schools” but that is not backed by any evidence base or consultation with the MOD. No reference to school needs is included for the same SA objective for OC12, but that has not been explained. As stated above, the MOD would expect to provide school facilities to meet the needs arising from any houses being provided on-site. Those would be well related to the houses. The increased provision of housing in this area would mean that access to secondary schooling would become more viable again benefitting the wider community. The score should therefore be DG.

For SA objective 2 a score of R has been included as it “contains features of recreation or amenity value”. That statement is not based on any evidence provided or consultation with the MOD. The site is an Airfield, as such has no public sporting or recreational facilities or public access. Should it be brought forward for redevelopment the MOD would provide for the necessary sporting and recreational facilities needed to support the development in line with Local Plan policies. Due to its scale those could be provided on-site in excellent relation to any houses being provided, also bringing benefits to the local area. The score should therefore be DG.

For SA objective 6: Several scores of R have been included as it is perceived to have “Poor accessibility to all local services”. That statement is not based on any evidence provided or consultation with the MOD. It is unclear what local services are being referenced without any definition. Equally it is unclear why the score has been repeated 7 times with only one objective and only one un-evidenced justification such an approach would add undue weight to that SA objective. It can only be assumed that the same is true for the surrounding housing areas including Dishforth village in the Planning Authorities opinion. If this is an issue locally, the bringing in of additional development at Dishforth could help to address that wider issue due to economies of scale and in line with Planning Policies. In the absence of any evidence or definition from the Planning Authority the score should therefore be DG.

For SA objective 7: A score of R has been included with the justification that the school “is at or near capacity and likely to require expansion”. Due to the scale of the site, should additional housing be provided, there would be scope to provide for school needs either on the site, or as an extension to the existing school supporting its role and the wider community in line with Local Plan policies. The score should therefore be DG. It is unclear why the other scores are left blank against this objective. Recognition should be included in the SA of the positive contribution that could be made through positively planning for the future of this site to support the wider community, jobs, training and skills through a mixed-use development across this strategic site. Without such scores the SA will be unduly skewed towards greenfield sites and will not have fulfilled the role of the Planning Authority to positively plan for the future of available brownfield sites.

For SA objective 8: The MOD provided evidence on the biodiversity of the site as part of the local plan process – it is largely unconstrained due to its use as an Airfield. It is unclear how the Planning Authority has arrived at the scores outlined as we are not aware of them undertaking any site surveys. They can only therefore be assumed to be uninformed desktop opinions and not evidence based. A range of scores nevertheless have been applied against this objective: 1. “Some potential adverse effects on biodiversity but mitigation should enable development” in this score reference is made to mitigation potential – this differs from the approach taken elsewhere in the SA. Given the evidence provided by the MOD and its use as an Airfield, it is unclear on what this statement has been based. The score should be DG 2. “Need not lead to the loss of woodland or trees /potential for new woodland creation” – the site is an Airfield, as such is free of woodland. Provision of new woodland (see below) would therefore be a significant biodiversity gain. The score of DG is therefore appropriate. 3. “Site large enough to incorporate new natural greenspace and add to green infrastructure” again refers to mitigation inconsistent with the SA elsewhere, but appropriate. The score of DG is therefore appropriate. 4. “There are public rights of way within or close to the site” this statement is factually incorrect and inconsistent with the approach taken above. Not only would the development of this site allow the restoration of access across areas not currently publicly accessible (mitigation / enhancement); but would also link public rights of way across this area improving access for the local community. There are a number of public rights of way immediately adjacent and close to the site. Perhaps the scoring person has got confused between designated long-distance footpaths and other rights of way, for example footpaths on Highways Land? 5. “Environment Agency - impacts cannot be predicted at this stage” again without a definition of this scoring approach commenting is made difficult. By reference to the EA we presume that the range of responsibilities of that agency are part of the scoring. The MOD provided evidence in the Local Plan process on the unconstrained nature of the site. The Planning Authority has not provided any counter evidence. As such the score should be DG. 6. Again an unevidenced statement and R is included “High landscape sensitivity - key characteristics vulnerable to change.” The site is flat (an Airfield) and not adjacent to any designated landscapes. Due to its flat topography, distant views of any development could easily be mitigated through the use of landscape features on the edge of the development such as tree belts. Given the lack of evidence, the score should either be ? to accord with the approach taken for the rest of the SA; or G to recognise that the developed site may still be available from distant raised areas. 7. The undefined score of R for “Low landscape capacity - area has limited capacity to accommodate development and few opportunities for mitigation” appears to be a duplication and undue double penalty of the above score. Again it is unevidenced. The site is flat (an Airfield) and not adjacent to any designated landscapes. Due to its flat topography, distant views of any development could easily be mitigated through the use of landscape features on the edge of the development such as tree belts. Given the lack of evidence, the score should either be ? to accord with the approach taken for the rest of the SA; or G to recognise that the developed site may still be available from distant raised areas.

For SA objective 9: Again, several unevidenced scores are included: 1. “Development will result in the clean-up of contaminated land”. Whilst we welcome the DG score it should be noted that the MOD evidence provided did not identify significant LQA issues on the site. 2. “Potential to affect achievement of air quality objectives” – is again an unevidenced statement. The site is not in close proximity to an AQMA. It should therefore be assessed as the same as other sites – either G (as no on-site or walkable train station) or DG. 3. “Some adverse effects on surface water and watercourses - mitigation possible” is stated as a justification for a O score, when the wording itself would imply a G. The site is not crossed by any watercourses, so again the statement is unevidenced. 4. The statement “ Water - impacts in relation to waste water and water infrastructure cannot be predicted at this stage” is inconsistent with the approach taken in the rest of the SA. As the development would “consume its own smoke” in line with Planning Policy requirements and evidence provided by the MOD, there would be no significant impact and should therefore be classed as DG 5. Land is approximately 75-100% previously development land- in line with significant caselaw the whole of the site should be classed as brownfield previously developed land. 6. “Land does not fall within any agricultural classification” so why is that a “N” not a DG? Appears to be inconsistent with the rest of the SA again. 7. “Major road (M) /A168 lies close to the site” is used to justify a R score. This undefined reason presumably relates to either perceived noise, vibration or air quality impacts. No evidence is provided to justify the assertion, or definition of “close”. The site is not adjacent to the . Many other acceptable developments are closer to such transport routes. Design of this 170Ha site could take account of any such issues and avoid impacts on users. So the score should be G.

For SA objective 10: Again, several unevidenced scores are included: 1. “Significant transport problems requiring substantial mitigation” – the site has a dedicated access road and very good low use routes to the A1 junction. It is therefore hard to understand why this score has been derived. It should be DG. 2. “Increased public transport provision and extension of services cannot be predicted at this stage” again unevidenced. Fails to take account of the existing public transport provision. A development at this site would help to make services more sustainable thereby bringing benefits to the wider community. It should be G. 3. “Poor connectivity to existing cycle routes” again unevidenced and not reflecting that the new development would help to improve such links. It should be G. 4. “Some pedestrian access and safety issues but mitigation possible” inconsistent with the statements made in the rest of the SA. Pedestrian access to the site is good. Given mitigation has been found acceptable the score of O is not appropriate. It should be DG. 5. “Severance can be overcome” as above, so it should be DG. 6. “Not located near a railway station” again near has not been quantified or defined. The site is closer to a railway station and on public transport routes to that station than allocated sites in the Local Plan.

For SA objective 11: Again, unevidenced scores are included: 1. “Site not within 400m of bus stop (50+ dwellings)” is not correct. The redevelopment of the site would allow access to existing services by providing more direct links to existing stops and making such services more sustainable. It should be DG. 2. No recognition is included of the need to make best use of a previously developed site and that can help with climate change objectives.

For SA objective 12: Again, unevidenced scores are included: 1. “All new development will increase use of primary resources and increases energy and water consumption and waste” no recognition is included in that statement of the existing resources on the site and the need to re-use those. It should be G

For SA objective 13: Again, unevidenced scores are included: It’s unclear why this is scored as “N” where for other SA objectives the fact that there are “No Conservation Area, designated or local heritage asset” would be lead to a DG score. Positive planning for the future redevelopment of the site should recognise that fact or the SA will unduly bias greenfield sites.

For SA objective 14: Again, unevidenced scores are included: 1. “Demolition of buildings would be required” is used to justify a R score. No account is taken of the fact that vacant unused buildings on the site will not contribute to the built environment. Its redevelopment in line with planning policies would justify a DG score.

For SA objective 15: 1. “Public transport provision cannot be predicted at this stage” is a direct duplication of earlier SA score justifications and therefore penalising the SA twice for the same issue. The redevelopment of the site would allow access to existing services by providing more direct links to existing stops and making such services more sustainable. It should be DG.

For SA objective 16: Is again unevidenced “Provision of employment land as part of a mixed-use scheme will encourage investment and support local business expansion” only scores LG. For such a major site redevelopment and protecting significant employment in the local area the score should be DG.

HBC Summary Summary: This option covers Dishforth Barracks and includes the airfield and associated buildings and structures. The site is to the south of Dishforth village and to the east of the A1(M) and A168. The site includes site DF7 previously assessed through the SA process together with additional land identified by the MOD – This statement is incorrect. HBC failed to consider the two areas appropriately dismissing both as “not being available within the Plan period”. A phased positive planning approach should have been undertaken as part of the Local Plan process for both sites.

Positive social effects occur as within the area of search there is the potential to deliver a development to include a significant amount of affordable housing, to be accessible to an existing play area/amenity open space/outdoor sports facilities and is also large enough to accommodate a new play area as well as providing new green space and adding to green infrastructure – That positive aspect is not reflected in the SA scores.

Negative effects result from the potential loss of existing sporting facilities No publicly available sports facilities exist. If the site closes without an active reuse brought forward all facilities will be lost. Bringing forward a positive planning approach would safeguard and make available any such facilities a positive gain for the community, the school within the area of search being at or near capacity and likely to require expansion, and poor accessibility to local services. The site has the potential for a mixed use settlement that would include some community facilities and local services. Bringing forward a new community would ensure any such impacts were mitigated and access to such facilities was enhanced and sustained not just for the new residents but also the surrounding existing areas.

Positive effects arise from the brown field status of this site and the potential to clean up contaminated land.

Significant transport and/or accessibility problems requiring substantial mitigation but can be addressed through development but adverse effects arise from the poor accessibility to public transport. Again, unevidenced statements and in part factually incorrect – see above.

Significant negative effects arise from the adverse impact on the landscape where there is limited capacity to accommodate development and few opportunities for mitigation. Provision of employment as part of the scheme will have positive effects encouraging investment and local business expansion. Again, unevidenced statements and don’t recognise the detrimental impact of the failure to positively plan for an available brownfield site, or the ready mitigation that can be included in any redevelopment – see above.

DIO Summary: It appears that the assessments made are not based on clear definitions, largely unevidenced, place undue weight on some factors / duplicate issues and are not applied consistently. The scores therefore need to be revisited and amended as suggested above. The MOD would welcome the opportunity to work with the Planning Authority to provide any evidence needed to better inform the assessments. However, we also support the imperative to adopt the emerging Local Plan, so would not wish to delay that process whilst the further work needed on the SA is undertaken. The revised SA could be brought forward as part of the joint working with the Planning Authority to bring forward proposals for the redevelopment of the site.