HDF Hull Development Framework

Core Strategy Volume 2: HDF report on engagement Hull Core Strategy issues-options October 2008 1

Report on engagement on the Hull Core Strategy 7. Views have also been sought from a series of ‘road show’ issues/options stage events which included a mobile exhibition involving a short DVD presentation at 4 venues across the city at East Park, 1. Purpose Queen Victoria Square, Pearson Park and North Point generally targeted to cover north, central, west and east Hull, 2. Purpose of this report is to inform others about the progress including over weekends. A number of local ‘drop in’ events made and feedback from the community, in developing a new also took place including a mini-exhibition and ‘looped’ DVD at broad plan for the city. It carries forward a report on all the Customer Services Centres across the city, which engagement (completed in June 2008) which is separately introduced the main issues, objectives and options. available and content of which has been taken into account in drafting the issues/options report and wider implications taken 9. At these recent events over 2,500 leaflets (with into account in the next draft ‘preferred approach’ stage. questionnaires) were distributed to individual members of the public which prompted discussion and debate along with 3. Key significant issues raised over a six week consultation written feedback. period undertaken in August/September are outlined below, along with the Council response to these as outlined in italics. 10. Over 1,000 Core Strategy issues/options documents were These, along with other detailed matters raised, are being also circulated to key stakeholders asking for their views and considered as part of the next draft ‘preferred approach’ plan preferences from the options raised. making stage. 11. With the help of Yorkshire Planning Aid, we also engaged 4. Approach with a number of specific community groups, including:

5. Community engagement on the Core Strategy • young people; issues/options document has been a good mix of general • older people; engagement and more targeted group work. • ethnic minorities; and • disabled people. 6. The document was presented at the HDF Forum on the 10 July including group workshop sessions on core objectives 12. We also engaged with key stakeholders including holding and options. Appendix 2 summarises the results of workshops separate meetings with: on the proposed objectives and options which also asked stakeholders to determine preferences. • Kingswood Development Company • Hull University

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 2

• Gateway – consultants delivering the Area Action Plans period. Appendix 1 to this report details each of the comments • Centre for Architecture and the Built Environment made by organisation or individual. The numbers outlined in • Building Schools for the Future brackets to this section refers to individual comments made in • Hull Forward Appendix 1. • East Riding of Yorkshire Council • Environment Agency B. Local Area response – records, in summary form, those • Government Office for Yorkshire and the Humber comments made following local ‘road show’ events and further discussions at Customer Service Centres. Appendix 2 details • Regional Assembly for Yorkshire and the Humber the results of this work. • Hull NHS

C. Stakeholder meetings – records, in brief, the main 13. This report should also be read alongside other comments and points for discussion, arising from views made consultations previously carried out prior to the development in written form. Appendix 3 details the discussions of the issues/options stage dated June 2008. This is in undertaken. Appendix 4 also details the feedback from events addition to Area Development Framework consultation carried facilitated by Yorkshire Planning Aid. Appendix 5 details out by Gateway in 2004 and wide ranging consultation carried feedback from key stakeholders in relation to the out by the Council on the Community Strategy in 2006. A full Sustainability Appraisal. report on more current involvement is available from Planning

Services. 16. Broad summary of results

14. This engagement has been carried out in accord with the 17. We have met with over 2,500 people within the city and Council’s Statement of Community Involvement. Early stages received over 450 individual responses from around 45 of the plan making process have involved continuous organisations or individuals. Most of the feedback we received engagement including regular stakeholder meetings and was positive, largely in support of the ‘stepped approach’ presentations/workshop sessions with key community although there were concerns about the nature of options put representatives, in developing the evidence base and through forward and the overall scale of change proposed. Further Hull Development Framework Forum events. consideration of these matters is required especially in

relation to the current local impact of the economic slow down. 15. The report is split into three sections covering the following: 18. The broad essence of comments received from the Core

Strategy issues/options report (published in June 2008) are A. Community response – records, in summary form, the numbered below along with the City Council’s response in content of formal written responses during the consultation italics. These include:

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 3

A. Community response – (numbers in brackets references future directions for change across the city for competing land representations made in Appendix 1) needs. These outline a number of potential future’s for the city, although it is appreciated that forecasting is not an exact General comments on Scenarios and development needs science. It has been concluded that the Council, working with sections (pages 26-32) and other general comments its delivery partners, should set a realistic future trajectory rather than an aspirational one. We need to provide evidence Comment 1 - Stepped approach as a way forward is broadly which demonstrates what we are proposing, can be delivered, supported. (36, 44, 68, 69, 73, 94, 96, 87, 130, 143, 178, 180, having regard to potential resources and investment over the 229, 252, 308, 309, 313, 315, 384, 385, 400 – 404, 412 and plan period. A ‘stepped’ approach is suggested over the long 450) term so we can more readily and efficiently manage change in a planned way rather than causing blight or not unduly raising A1.1 Support is welcomed although there needs to be a expectations. clearly defined view about a future long term development trajectory for the city and how this can be realised. This has A2.2 RSS is predicated on achieving a high growth agenda. and continues to be considered through preparation of Policies are also couched in terms of being indicative in evidence base information including a Strategic Housing Land setting broad directions of change but these can also be Availability Assessment, Employment Land Review, Retail reviewed through more local and possibly more accurate (and Assessment and Sustainability Appraisal, developed in more up to date) evidence base gathering. RSS is likely to be conjunction with key specialist stakeholders. the subject of early review for Spring 2009, so what we have completed provides us with useful information to inform that Comment 2 - Realistic options in terms of approach to be review, especially concerning housing numbers. outlined in the Core Strategy including robust local evidence base versus application of RSS requirements – which one is A2.3 Delivery of housing numbers in the city will be more realistic, deliverable and appropriate trajectory in terms considered as part of a SHLAA which will involve engaging of housing, employment and retail numbers for Hull? RSS net home providers, land owners and the neighbouring Authority. housing figures also need to be applied in the Core Strategy. This will help determine where, when and who will deliver (34, 36, 40, 45, 48, 52, 69, 71, 73, 78, 81, 92 - 94, 97, 103, housing across the city and outside it, but within the Hull 113, 118, 128, 130, 141, 143, 158, 178, 180, 186, 199, 229, Travel to Work area. It will also flag sites that have housing 230, 235, 276, 273, 308, 313, 315, 352, 357, 361, 381, 382, development potential but require intervention to realise this. 384, 385, 400 – 404, 412, 450, 453 and 460) A2.4 The Retail Assessment, prepared in 2003 and reviewed A2.1 The Council has progressed considerable evidence base in 2006, provides a guide to the retail strategy for the city and studies to underpin its planning documents in setting out advises on broad spending capacity. This is applied to the

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 4 different centres across the city. Out of centre development is that Kingswood, as an existing urban extension, is completed ruled out as most new shopping should be directed to these as a priority. These will also have to be agreed between the centres, although spending capacity will be kept under review. Authorities and taken into account as part of the RSS review.

A2.5 The Employment Land Review provides details A3.2 The emerging Core Strategy will consider the wider concerning future land requirements along with a degree of influence of the City on the Travel to Work Area in terms of flexibility in accommodating market needs. the wider sub-regional role. This will include reference to the A2.6 Net housing requirements will be confirmed in the next wider Regional City as set out in RSS which acknowledges draft version of the emerging Core Strategy. Net requirement that links between Hull and parts of East Riding should be refers to those people needing a house derived from an integrally planned. assessment of future population change. Account is then taken of vacancy rates and houses to be demolished which Comment 4 - Some objectives are too generic (e.g. have to be replaced to accommodate expected households. A sustainable development). (291, 274 and 278) gross requirement is then determined which takes account of the number of households needing a dwelling and those to be A4.1 A locally distinctive vision statement and objectives, replaced. along with the role of sustainability,will be more thoroughly embedded throughout the next draft document as it Comment 3 - How does this realistic approach play out in progresses to ‘a preferred approach’. terms of general locations for new housing and employment including possible urban extensions and how the city fits into Comment 5 - Options should be mutually exclusive and as the wider sub-region. (67, 156, 278, 398, 404, 438, 447, 448, currently stated are more like statements of intent or fact. 452 and 460) Most options appear to be desirable or necessary - how much choice is being offered? (101, 202, 263, 278, 436, 438 and A3.1 Further details in terms of housing land supply and 454) locations will be considered along with development options across the sub-region, as part of the SHLAA. Urban A5.1 Further work will be needed following completion of the extensions and/or economic development outside of the Hull evidence base, including the SHLAA and Open Space Audit, City administrative boundary are being considered with ERYC to help underpin further spatial options covering the long term as part of our respective Core Strategy work and in development of the city. These will be available for comments addressing RSS requirements in an integrated way. Urban in the emerging ‘preferred approach’ document. However, a extensions will need careful consideration, especially in great deal of what is suggested is governed by existing relation to sustainability and urban concentration priorities set commitments either through the grant of planning permission in national and regional planning policies along with ensuring or by physical or other constraints, such as flood risk or the

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 5 tightly drawn administrative boundary, national and regional prepared in conjunction with ERYC colleagues including ELR, policy. The Council makes these constraints and limitations HMA and SHLAA. We are also aware of each other’s clear in the document in terms of restrictions on choices of emerging development strategies. development patterns. A7.2 A Joint Core Strategy was ruled out following A5.2 Once completed, the SHLAA will provide a better basis discussions at the time of the new Planning Act. This was to inform real development options for housing. The Open largely on the basis of ERYC having to prepare a document Space Audit will also provide a better basis on which to apply which would include several functioning areas. The Authorities local standards and show broad areas for protecting open also have separate Community Strategies. space. These studies were not completed at the time of the Core Strategy issues/options report but will be more fully Comment 8 - Document should consider waste and minerals considered in progressing the document to its next stage of policy. (265, 291, 393, 438 and 456) development. A8.1 The intention is that a broad, but locally specific policy, Comment 6 - Need to consider the structure of document - will be transferred from the Joint Waste and Minerals DPDs each section and what it aims to achieve. (291) currently under preparation, to the next draft version of the Core Strategy. A6.1 The current structure of the document results from the main challenges facing the city and themes outlined in the Comment 9 - How will the emerging strategy evolve in Sustainable Community Strategy. Further consideration to addressing current Core Strategy shortfalls, so it meets the structure will be given, but no alternatives have been offered tests of soundness? (66 and 438) by others, in place of what currently exists. A9.1 The next draft of the Core Strategy will include a mix of Comment 7 - Wider reference and regard to the influence of options and a suggested preferred approach. This will enable planning beyond the city boundary is needed to ensure an further discussion and agreement on approach and ensure integrated approach to development across the two local robust delivery, prior to the Pre-submission and then authorities. (241, 352, 398, 404 and 438). Submission draft stages. However, there seems broad consensus about working toward a ‘stepped approach’. A7.1 The Council is working with ERYC in preparing its Core Strategy. We have previously prepared a Joint Structure Plan Comment 10 - How will recent changes to PPS12 take covering the area of the city and ERYC. Our LDS account of strategic sites? (262, 282, 438 and 439) programmes are aligned. Planning Officers have attended numerous HDF Forum events. Evidence base work is

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A10.1 The next draft of the Core Strategy will consider how draft Key Diagram, as required. Some of the detail currently best to take forward strategic sites, perhaps in terms of their shown will be transferred onto a draft Proposals Map that will relative importance to delivering the spatial strategy. To some relate to an emerging Site Allocations DPD. extent, the Spatial Options Map already flags what might be considered as important to the delivery of the strategy, Comment 14 - Emphasis should be given to sustainable including those areas defined by AAPs, key employment sites transport modes, locating service hubs adjacent to transport and the University of Hull. hubs, protecting former rail corridors for potential future use for light rail/guided bus and A63 Castle Street improvement Comment 11 - Need to clarify PPS12 requirement of Core referenced as a priority. (225). Strategies to evidence physical, social and green infrastructure to enable the amount of development proposed A14.1 Public transport improvements will be added in the next for the area, through an Infrastructure Assessment. (47, 51, draft document but this is largely a commercially driven 80, 107,117, 149, 176, 191, 326 and 459). enterprise so is influenced by the location of existing and new development potential. Transport projects will be included in A11.1 An infrastructure Assessment is being prepared by the the next draft document if there is some commitment to City Council. resourcing their delivery. It may be an option to protect the line for a guided bus way (previously shown in the Local Plan) Comment 12 - Each of the Core Strategy suggested provided this does not cause blighting or there is no preferred options should indicate a target and baselines so commitment to funding in the relevant LTP. However, not the effectiveness of policy can be considered. (37, 237, 266, reserving this line would rule out its potential long term 278 and 333). delivery. Most former rail corridors already have protection as green corridors and cycle/ pedestrian routes. A12.1 It is agreed that there is a need to include indicators and targets in the next draft of the emerging Core Strategy. A14.2 The A63 Trunk Road improvement is a priority transport Work on the Sustainability Appraisal will be reflected in terms project as already recognised in the issues/options report but of baselines and targets. We will tie in reference to Local Area further emphasis will be given to this scheme in the next draft Agreement targets. document.

Comment 13 - Relative detail of the Spatial Options Map (63, 140, 147, 296, 323, 342 and 446).

A13.1 The Spatial Options Map is detailed but it will become more diagrammatic or conceptual when it is translated into a

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Comments on guiding principles section (pages 44 – 66) of better ‘place making’. (91, 100, 116, 157, 159, 160, 172, 242, 324, 332 and 356). Comment 15 - Greater regard to natural environment and the environmental capacity of the city in terms of real options A16.1 We are considering how these assets can be more including considering impacts of development along the readily recognised in the developing the preferred approach, Humber estuary or River Hull Corridor. There was a concern including addressing high quality design along with the that there should be reference to creating a network of green retention or improvement of the environment. Consideration spaces which include biodiversity value as well as references will be given to introducing a ‘strategic design policy’ approach to water resources and water quality. (91, 109, 111, 116, 155, in the next draft Core Strategy document. 324, 327, 332, 337 – 339 and 379 – 380). Comment 17 - Capacity of the highway network and A63 A15.1 Nature conservation is being assessed as part of an called into question. (204, 226 and 232). Open Space Audit. The results of this work will be more fully represented in the emerging draft Core Strategy. A17.1 Road network capacity is a key challenge for the city. Environmental constraints are being considered as part of the The East/West A63 Trunk Road route is limited and there are Sustainability Appraisal which will include details of likely capacity issues mainly at other junctions across the city. It is impacts of suggested policy proposals and suggested important that a growth strategy for the city is not constrained development patterns. by lack of highway capacity. The City Council has prepared a Local Transport Plan and is working with the Highways A15.2 Reference will be made to the strong links between Agency to consider improving capacity including major protecting/ creating a green space network and climate infrastructure projects (A63 Castle Street improvement), change (water holding areas), biodiversity (wildlife), junction improvements, moving more freight from/to the Port accessibility (walking/ cycling), leisure (recreation) and health by rail, park and ride schemes, green travel plans and other (exercise). Reference will be made to conserving and junction improvements. A transport model is also being maintaining quality of natural resources, including land, water prepared that will help in advising on mitigation measures and and air. other future transport options will have to be considered. Other alternatives include greater use public transport. The A15.3 The environmental importance of the estuary and River alternative is to manage congestion, not dissimilar to what is Hull will be emphasised in the next draft version of the happening in other northern England cities. document. Comment 18 - Uncertainty over regeneration priorities - areas Comment 16 - Greater recognition and protection of the city’s identified and what regeneration is seeking to achieve. (17, built and natural heritage assets is needed including delivery 35, 39, 40, 42, 77, 112, 142, 185, 314 and 383).

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A18.1 The regeneration priorities largely stem from physical Comment 21 - Extent infrastructure will be taken into account. initiatives taking place across the city. The City does not have (47, 51, 80, 117, 149, 191 and 459) an integrated regeneration strategy but the Core Strategy attempts to draw inference from initiatives and link these to A21.1 The full extent of infrastructure needs are not able to be areas of need or stress. Current initiatives are focussed on taken into account as part of realistic options until details of housing market renewal, economic transformation, reducing Community Infrastructure Levy from Government are known health inequalities and school/education improvement. They or a local study is completed. Government advice is to plan for are cognisant of high deprivation areas occurring within the the introduction of CIL. When it is finalised, any necessary inner city and outer estates. There are real challenges about adjustments will be made. the location and definition of regeneration along with establishing a performance monitoring framework. The next draft of the Core Strategy will clarify areas of change linked to deprivation but also those of opportunity.

Comment 19 - Need to adapt to climate change as well as mitigate it (e.g. green infrastructure, tree planting). (101, 148, 181, 190 and 310).

A19.1 It is agreed that the Core Strategy should say more about how the city should adapt to climate change and due consideration will be given in the next stage of plan production.

Comment 20 - Extent Hull should not avoid, but have regard to, national policy explained in PPS25 and how the Strategic Flood Risk Assessment has informed the spatial option. (18, 46, 79, 104, 115, 135, 182,192, 205, 221, 234, 254, 320, 335, 370, 373, 374, 376, 377, 359, 391, 409, 411 and 457).

A20.1 The city has very little land that is not within a high risk flood area. The next draft version will highlight the particular circumstances of Hull along with how the SFRA has influenced development potential.

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Comments on the Quality of life section (pages 70-119) Comment 25 - Lifetime Homes and Code for Sustainable Homes should be introduced in accordance with Comment 22 - Need for informed assessment of the viability Government’s target dates to ensure schemes can remain and practicability of proposed affordable housing targets viable and competitive. (14, 41, 50, 74, 83, 99, 121 and 144). particularly in light of market conditions in Hull. Need to consider lower requirement set out in HMA. Reference is A25.1 The approach is to improve the standard achieved in made to the Blyth Judgement. (50, 57, 83, 121 and 183). new housing design. The actual timescale to implement the standards will need to reflect the viability of achieving them on A22.1 Regional Assembly recommend setting a target based sites. on local evidence from the HMA. It may not be appropriate to provide affordable housing in some parts of the city. If high Comment 26 - Need to consider the needs of gypsies and targets affect investment and delivery of development this travellers to address the identified shortfall of provision in the could fundamentally affect the economic and social region. (362 and 463). aspirations of the plan. A26.1 A recent local assessment of need concludes that Comment 23 – Applying rigid housing densities might further new provision is required but there is more immediate compromise design quality and development viability. More need to improve existing facilities on four sites within the city. variety should be provided. (50, 57, 83 and 121). Comment 27 - Brownfield land, while a priority for A23.1 The Strategic Housing Land Availability Assessment development should be recognised when left for long periods (SHLAA) will, through its assessment of sites, make some of time, can provide habitats of nature conservation judgement as to suitable densities that can be achieved on importance. Developments should seek to retain this interest sites. Through this process a more localised approach to or incorporate it into any proposals for a site. (108 and 330). densities will inherently be a part of the plan. A27.1 Brownfield land is seen as a priority for development Comment 24 - Should ensure the provision of homes for a rather than using Greenfield land. Where Brownfield land has mix that reflects the needs of an area, including homes for been left or has been purposely turned over to being a habitat families. (57, 352 and 415). for nature conservation then it might be appropriate to retain A24.1 Recognition is given to the need for a greater mix of it, depending on what exists. housing types in the city, particularly the need for more larger Comment 28 - Proposals to demolish and rebuild should houses for families. The approach of Gateway is to rebalance consider the energy implications based on energy ‘embodied’ the housing market by providing a better mix of housing in within existing buildings - where possible policy should areas of intervention. A more balanced housing market is encourage reuse and promote most efficient use. (163). seen as a key building block in helping to promote economic A28.1 Most efficient use – especially based on today’s growth in the city. requirements to create sustainable buildings – may in the

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 10 longer term, involve redevelopment. Proposals to demolish counted as outside of the administrative boundary and and rebuild will generally be in areas where there are therefore not be a part of Hull’s Brownfield / Greenfield split. particular problems with buildings or with street layouts or Comment 30 - Use of previously developed sites, while there are wider social benefits that, alongside longer term reducing pressure on Greenfield sites can also make best use environmental benefits that will outweigh the impacts of of transport infrastructure, reduce the number of vacant and clearance. derelict sites in the city making it a more attractive place. Comment 29 - Brownfield targets should take account of the (258). large greenfield allocation at Kingswood and therefore a lower A30.1 It is agreed that where brownfield sites are located target at the beginning of the plan period is supported. Priority within an urban area the likelihood is that they will generally should be given to achieving the required rate of housing be well related to existing transport infrastructure. In some development even where this means greenfield development. circumstances redevelopment of a brownfield site may lead to Evidence needs to be provided to outline how 60% target can an ‘overload’ to infrastructure. Some notable brownfield sites be considered realistic for the city. (53, 85 and 123). in Hull are held back because of the impact they will have on A29.1 Kingswood is supported as a location for future housing the highway network, particularly the A63. growth. Other locations within the city are also located as priority locations for achieving housing development and will predominantly represent Brownfield development. As we move to later phases of the plan we will need to source further land from within the city’s administrative boundary, particularly some areas of potential change. These also will be predominantly Brownfield sites. There is therefore potential to increase the percentage of Brownfield development occurring in the city over the plan period. Where there may be a situation of more Greenfield development to support the housing requirements of the wider city region is when we are unable to identify an adequate supply within the city’s administrative boundary. This will require a readjustment of the allocation of housing numbers through the Regional Spatial Strategy, and essentially involve more of Hull, in the wider sense of a Regional City, providing housing through urban extensions. Where this occurs such numbers would be

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Comments on the Jobs and prosperity section (pages Comment 32 - Site specific concerns include potential of 124-142) Clough Road for more than just B Use Class because there already is retail and offices, along with potential at Birds Eye Comment 31 - Clarify the role of office and other employment and Kingswood being so limited. The operational Port area development across the sub-region as successful City should also be identified. (186, 188, 194, 295 and 365). Regions offer both city centre and out of centre products. (442 and 443). A32.1 Clough Road (south), former Birds Eye site and the existing employment allocation at Kingswood, have been A31.1 National and regional planning policy makes clear the identified in the Employment Land Review, as having role of pure A1 and B1a office development and sequential significant employment potential. This should not be lost to approach should be accordingly applied across the sub- other uses particularly as no further need for large scale region. This approach is put forward in the City Centre Area shopping and offices, beyond those sought for the city centre, Action Plan which includes city wide policies in advance of the is proposed. The Eastern Port Area will be highlighted as Core Strategy. However, the policies do not cover the wider ‘operational dock’ as part of the next Core Strategy document. East Riding of Yorkshire area, where as Regional Spatial Strategy does. Comment 33 – Clarify the role of District Centres given they will be a key driver of the integrated regeneration framework. A31.2 A vibrant and vital city centre is crucial for the long term (59). growth of the city and wider sub-region. Dispersing activity across a wider area will not bring benefits associated with A33.1 There is a distinction made between ‘service hubs’ and much needed ‘critical massing’ objectives. Other City Regions a retail role, particularly given the differing sizes and potential do have elements of both vibrant city centres and out of to support physical expansion of identified centres. centre business parks. Hull does not have a mature retail or Comment 34 - Greater emphasis should be given to planning economic base, already has a degree of dispersed activity positively for growth and expansion of centres. Service hubs and is does not have very large population catchments like should not just be a focus for services investment, but also other City Regions. continued retail investment. The hierarchy should only be used to provide a broad indication of appropriate uses and A31.3 There is a concern that advancing complementary individual proposals should be assessed against individual offices or other employment uses in East Riding will cause circumstances. (72, 122, 133 and 432). displacement from the city centre and wider area, causing A34.1 The hierarchy provides a guide for the type of provision ‘hollowing out’ which is contrary to wider sustainability and within a centre and be in scale with the role and function of regeneration objectives. the centre, as required by PPS6. The different service hubs

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 12 present varying opportunities for further physical development major schemes would be supported by expenditure normally and expansion. It is therefore not appropriate to use a spent in other competing centres – an element of ‘claw-back’. standard approach to all centres. It is important to achieve a A36.2 An allowance was made therefore as to how new base level of retail and service provision to ensure access for centres could be accommodated. PPS6 is due to be revised all neighbourhoods across the city. This may involve further imminently and this may present an opportunity to provide a retail development as well as service development, where this further update to the Retail Study. This may be particularly is appropriate. timely also given the current economic situation. The Retail Comment 35 - Identification of the City Centre at top of the Study is considered to be conservative in terms of the shopping hierarchy as the prime focus for shopping in the city projected growth requirements for the city so as not to lead to and into the wider catchment. (321). an overprovision. It is perhaps appropriate to maintain a cautious approach to future growth rates prior to more A35.1 The city centre, particularly through the City Centre certainty as to future economic fortunes of the retail industry. Area Action Plan is clearly positioned as the central focus for Comment 37 - While there is a positive focus on development major retail development, particularly for non food. to support the future of local centres, particularly the nine Comment 36 - Suggested shortcomings of the Retail Study ‘service hubs’, the evidence base used to underpin the Core undertaken by NLP, particularly regarding assumed growth Strategy does not support this position, instead suggesting a rates and forecasting methods used. Question of whether the reduced market share for local centres at the expense of the household survey is still appropriate as the foundation of the City Centre. The future market share of District and local retail study given potential changes in shopper behaviour post centres should reflect at least a constant market share, with a St Stephens opening. Whilst allowance is made for increased possible increase. Question of how the non food shopping retention rate the study may still be open to criticism and needs floorspace is arrived at – table 4.2 of the options therefore kept under review and updated as the Core Strategy document. (72, 122 and 432). is progressed up to Submission stage. (129, 308, 314, 345, 346 and 350). A37.1 The NLP Retail Study has apportioned an element of projected future floorspace requirements in the city to be A36.1 The NLP study, originally prepared in 2003 is kept provided in district and local centres. While the plan puts under review. It was updated in 2006 to take account of forward the concept of hubs to focus future provision of local changes in the approach set out in PPS6 to retail shops and services, these will not necessarily involve assessments, and to update some of the key data. The significant expansion through shopping development. household and shopper surveys are a significant undertaking Comment 38 - Service hubs should not be the only focus for and at 2006 it was questionable whether significant shifts future investment. (72 and 432). would have occurred in peoples shopping habits. An allowance was made of the degree to which new floorspace in

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A38.1 They will not be the only focus for investment but serve extension. It is also questionable whether the centre is easily to build a network of accessible services as well as shops that accessible by foot. Para 2.54 of PPS6 refers to how, unless will serve all neighbourhoods of the city. They will also serve identified as centres in relevant development plan documents, to direct investment of limited public money in regeneration existing out-of-centre development, comprising or including projects to support this network. Other investment in facilities main town centre uses, such as shops, shopping centres, in local centres will continue to be promoted where it is of a leisure parks or retail warehouse parks, should not be scale that is appropriate to the centre, and does not regarded as centres. undermine or divert investment inappropriately from other Comment 40 - Reference to how Kingswood is made up of centres. more than the retail element containing a significant leisure Comment 39 - Concern of definition of ‘Retail Parks’ and element which should be considered as part of the centre and what is seen as suggested preclusion of further retail therefore boost the mix and potentially the status within the development in these locations. Particular reference made to centre hierarchy. (124). Kingswood. (349 and 350). A40.1 The leisure element was not originally defined as part if A39.1 The Core Strategy does not say there will not be further the retail centre – originally allocated for employment uses development in these locations but says they will not be a and developed largely as an out of centre largely car served ‘focus’ or priority for such development – i.e. for the purposes leisure outlet. It is therefore slightly spurious to now regard it of the sequential approach to locating future development as a part of the retail centre, especially given the lack of they will be the least preferable location. The centres connection between the two elements. identified as ‘retail parks’ do have a limited range of shops or Comment 41 - Allowance should be made for the provision of services generally catering for car borne comparison retail floorspace based on site specific catchments and shopping, often presenting a range of outlets of national detailed analysis relevant to that catchment. (314 and 345). retailers, and not therefore for local everyday needs. They do not operate as local or district centres serving local access to A41.1 This can give undue weighting to specific proposals facilities. Kingswood was identified in the Local Plan as an and often precludes a city wide view retail need. The NLP Important Local Centre but it has not developed as such so it study has provided an objective view of needs across the city would not be appropriate to maintain this definition as the as a whole and therefore should provide a guide to where and basis of continuing as a focus for retail development. If the when future proposals might be appropriate. current provision at Kingswood was reconfigured with smaller Comment 42 - Definition of supermarkets and superstores in units and a wider range of shops and services then this could the characterisation of the different types of centres does not potentially promote its role as the local centre to serve the accord with the PPS6 definitions. (345). housing at Kingswood. It is however constrained by development around it which would preclude its further

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A42.1 The characterisations are based on the sizes of A44.1 Reference is made to service uses within centres, facilities already existing within centres. It might be particularly ‘service hubs’. By their nature retail centres are appropriate to increase the threshold of the supermarket deemed to include a range of uses other than pure floorspace to that of PPS6. The superstores that exist in convenience and comparison shopping. In terms of the larger centres are typically of the magnitude stated so the lower role of financial services – they are considered in terms of the threshold is not really relevant. contribution made to the wider employment future of the city Comment 43 - Definition of ‘service hubs’ is too narrow in and provision is made for future floorspace development meaning. These centres are neither just shopping centres nor under the Jobs and Prosperity chapter of the I&O document. service centres. Therefore the definition should reflect the Comment 45 - The document should provide sufficient overall role of the centres as ‘hubs’ with an enhanced role in protection to ensure continued theatre use within the city, meeting shopping and service needs. (76 and 138). particularly where such uses are not protected by listing or conservation policy and may be affected by proposals that A43.1 The description of centres as ‘service hubs’ does may come forward for development. (193). suggest a priority for services and it might therefore be appropriate to use a more generic term. The term ‘district A45.1 Significant investment has been put into facilities in the centre’ as put forward through the One Hull Spatial Strategy city centre with the development of new facilities for the leads to confusion due to PPS6 definitions of what a ‘district Albemarle Centre in the city centre. A new venue for the Hull centre’ should consist of and the capacity of all of the nine Truck Theatre is also nearing completion. The Hull New proposed centres to become a centre that meets this Theatre remains in the city centre. definition. It might therefore be appropriate to use a term such Comment 46 - Need to make developments fully accessible. as ‘city hub’ to reflect how they will act as a focus for Hull could promote itself as a fully accessible city. Support for neighbourhoods around the city. A definition of a city hub can clustering facilities in centres. (13, 17 and 43). then be provided that is separate to the PPS6 definitions, based on a specific and enhanced role to provide a minimum A46.1 Accessiblity is a key objective for the Core Strategy as level of provision necessary to support a neighbourhoods a whole and will be reflected in policy – potentially as an needs. overarching policy rather than within more detailed policies. Comment 44 - Specific reference should be made to the role Comment 47 - The Core Strategy should look to locations that financial services retailers have in contributing to the outside of the City Centre for major uses where these uses vitality and viability of the centres. Such services should also can bring demonstrable and major regeneration benefits – be afforded the opportunity to expand and improve their particular reference to the KC Stadium as such a location. position. (304). (150).

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 15

A47.1 Proposals in such a location would need to be 49.1. The City Council is working with East Riding of assessed against a sequential approach that considers City Yorkshire Council and other stakeholders in terms of potential Centre sites as well as a range of other appropriate sites. The future development options, which may involve urban Newington and St Andrews Area Action Plan puts forward extensions, the suitability of which will be considered in due land adjacent to the stadium as being suitable for ‘stadium course. related uses’. Recent proposals for a rail halt suggest its status may be elevated. The strategy for the city centre is well Other feedback understood and has been set out through the City Centre Area Action Plan. Clearly significant investment is happening A50. Yorkshire Planning Aid has played a significant role in and is planned for further projects which should not be working with ‘hard to reach’ groups including the young, undermined and put at risk by trying to spread investment too elderly, disabled and ethnic minorities people. The results of thinly. The sequential approach to locating such uses might workshops held with these groups are detailed in Appendix 4. ultimately suggest a phasing of development in this location. What follows is a summary of this and Council response is outlined in italics.

Comments on the Education, learning and skills section A51. Young people focussed on a range of issues facing the (pages 144-152) future city although a great deal of matters raised were not

planning or land use related. In broad terms young people Comment 48 - More account should be made of education were concerned about the following commonly occurring facilities in the document including the important role of themes: Further Education and the University of Hull, on the local economy. (88 and 343). A52. Tackling problems of anti-social behaviour and need for

local facilities to divert problems caused by youths including A48.1 The current issues and options version is considered to well maintained play space, pitches, youth clubs, skate parks, adequately reflect the role of education on the local economy and other sporting activities like tennis or baseball. although it is difficult to be specific without supporting evidence. A52.1 The Core Strategy will address need for new facilities

A49. Hedon Town Council also made comments on the Core across the city which will help reduce anti-social behaviour, Strategy issues/options document, although these were although local people, the Police and Community Wardens received after the formal deadline for comments. The play an important role in minimising anti-social behaviour. comments where concerned with potential loss of character to A53. Need good access to jobs via affordable public transport the town if the city expands. particularly in the city centre.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 16

A53.1 The Core Strategy places the city centre at the heart of A58. There should be more affordable housing and it’s not the local economy because this is accessible to many people. clear why there is a need for so much more housing when Major investment is to be encouraged and steered here. people are leaving the city.

A54. Concern about the city centre becoming non-inclusive A58.1 Our Housing Market Assessment identified the growing and mixed views about the impact of St Stephens. disparity between low wages and rising house prices and recommends that 20% of new stock be affordable. Much of A54.1 The city centre is planned to become a more inclusive the existing stock is affordable. part of the city. A58.2. Technical assessments are needed to determine future A55. Need for a good mix of housing and re-use more of what housing needs. We make estimates of future population exists. including ageing, migration, births, deaths and size of households. New houses will be required to meet changes in A55.1 The Core Strategy puts forward greater mix of house the nature of the current and anticipated population. types although there is a need for more family sized dwellings in balancing this with the stock that already exists. A58.3 Outward migration, especially of the more mobile and mid-affluent, is of particular concern because these people A56. Need to effectively tackle crime and fear of crime. underpin the wealth and viability of the city. Continued loss of people to East Riding of Yorkshire might significantly harm the A56.1 The Core Strategy will put forward policies about future city. ensuring mixed communities and designing out crime. A59. Avoid building in flood risk areas. A57. Too many takeaways fuelling obesity problems. A59.1 The Council has assessed flood risk and has identified A57.1 The Core Strategy suggests reducing takeaways within those parts of the city where building should be avoided. a certain distance of schools but this will not fully address the issue of obesity. Policies suggested in the Core Strategy to A60. Elderly people focussed on similar common themes to steer the development and location of new sporting facilities young people. In summary the main points included: and to protect open spaces should improve physical activity. More concerted action is needed to combat obesity issues A61. Tackling problems of anti-social behaviour and improving including people taking more care of themselves. facilities for local youngsters along with encouraging good neighbourliness.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 17

A61.1 The Core Strategy will seek to ensure more mixed A63.3 Difficulties encountered by people accessing health sustainable communities which include having good local services outside the city are compounded by low car facilities. High quality design principles are also to be included ownership levels in the city. The Hull PCT is working to in the Core Strategy in combating anti-social behaviour and develop more local facilities serving north, west and eastern good neighbourliness. parts of the city, reflected in the Core Strategy issues/options document. A62. Lack of local facilities including shops and open spaces but should limit takeaways especially near schools. A64. Need for housing to meet everyone’s needs including for elderly and the disabled people including homes which are A62.1 It is recognised that local facilities are needed to affordable and energy efficient. support local neighbourhoods including access to shops, health facilities and open spaces although the drive toward A64.1 The Core Strategy looks to address all future housing large out of centre stores has not helped. Constraining the needs and puts forward ideas about how this might be supply of takeaways within a certain distance of schools may achieved. help improve the health of young people but there is a need to tackle obesity issues by taking a more holistic approach. A65. Play areas are needed for children which are well designed and relate well to housing. A63. Public transport is poor (and should be free) and roads are congested at peak times and there are difficulties in A65.1 The Core Strategy puts forward suggestions about the getting to health centres including Castle Hill. importance of high quality design which includes principles of play. This reaffirms the current policies as detailed in the A63.1 Public transport is a commercial enterprise so services Local Plan and related Supplementary Planning Guidance are reliant upon patronage to make routes viable. Service Notes. improvements can occur of development results in additional patronage. A66. Support for new health care facilities.

A63.2 Bus routes which lead to the city centre need improving A66.1 Support for this as explained in the Core Strategy, is to make them more free flowing and a cheaper alternative welcomed. than using the car and paying for parking. The Core Strategy will promote development which seeks to improve bus A67. Support for all Park and Ride sites proposed. patronage. A67.1 Support for this as explained in the Core Strategy, is welcomed.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 18

A68. Flood risk approach is supported including using open A72. Disabled people also commented on the issues/options spaces as areas to absorb water and open drains/culverts report and made the following comments, summarised as should be re-opened. follows:

A68.1 Support for the approach to flood risk as explained in A73. Designing new places should be accessible to all the Core Strategy, is welcomed. Further work is needed in including 20% of the population who are disabled people. terms of considering the future role of city drainage. A73.1 There will be a broad policy in the Core Strategy which A69. The city has expanded several times since the 1940’s will require development to be accessible to all, although there but there is limited land to expand further within the city is no evidence to substantiate that one-fifth of the city especially in fitting 24,000 new houses. population is disabled.

A69.1 The previous growth of the city is recognised and A74. Housing should be made accessible to all (with a details concerning potential locations for new housing are minimum standard of 20% of new stock) and be in locations being considered as part of the housing land assessment. It near shops, services and transport. might be that land outside the city is needed to accommodate housing which best serves its future interests over the long A74.1 There will be a broad policy in the Core Strategy which term, although all efforts should be used to re-use and recycle will require development to be accessible to all, although it is existing housing stock. unclear how the suggested minimum standard has been derived. An evidence base would be needed to help support A70. Council should have a vision for its area. such an approach which does not currently exist.

A70.1 A spatial or place related vision for the city is outlined in A75. 100% of new housing should apply lifetime living the draft issues/options report but this is being reviewed. A standards as a key element to sustainability. new draft vision is to be put forward. A75.1 The principles outlined in the Lifetime Homes standards A71. The Council should work in conjunction with East Riding are intended to apply to all new housing development. to benefit all people in the area. A76. There should be a policy requiring a design and access A71.1 The City Council is working with East Riding of statement including more than simple requirements which Yorkshire in developing planning strategies for its respective meet Building Regulations and wider consideration of possible areas. conflict with flood risk issues.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 19

A76.1 Design and access statements are already a A81. Meeting Building for Life standards is different from requirement of the Planning Regulations (Circular 01/2006) so Lifetime Home standards in terms of meeting Disability there is no need to duplicate this by having a specific policy. Discrimination Act duties. Design issues in places at high risk of flooding in relation to buildings being accessible, need more careful consideration. A81.1 These are different standards but both are as equally important in their application on the ground. A77. A general ‘design guide’ is needed in advising on treating public realm in meeting disabled people needs. A82. Ethnic communities and faith groups also commented on the issues/options report and made the following A77.1 It is considered that the current SPG on improving comments, summarised as follows: design for disabled people needs reviewing. A83. New large community centres are needed and made A78. Parking standards for the disabled are needed. accessible, serving large groups of over 200 people with crèche which ought to be taken into account in the Core A78.1 The Local Plan already has parking standards which Strategy. will need reviewing as part of the LDF but is not being progressed as part of the Core Strategy. A83.1. The need for community centres across the city needs examining as part of the Infrastructure Study. A79. Public toilet facilities are needed in the city centre that are accessible to all. A84. Facilities in the city have been outgrown eg. central mosque, so more land to expand or new facilities to reflect A79.1 It is agreed that this needs further consideration, growing ethnic community is needed. probably by reference in the City Centre Area Action Plan, although this is at an advanced production stage. A84.1 Further analysis and consideration to additional facilities serving the changing pattern of the city population is A80. The Core Strategy needs to be clear about what is needed prior to identifying future land and building needs. expected of all other new plans/strategies occurring across the city. A85. Bus services are limited and expensive as well as difficult to move across the city on one bus so need a tram A80.1 The Core Strategy will provide a context for other plans, system or cheaper bus services. strategies and programmes that will be developed over the next 15 years or so. A85.1 Bus services are a commercially run enterprise so services generally cater for highly patronised routes. A tram

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 20 system in Hull has been considered before and found to be B2. Economy cost prohibitive. • Do more to realise the benefits of technology

A86. More and better shops are needed. • Need to integrate and bring about change to the city rather than ad hoc approaches of the past. A86.1 The City Council is encouraging new shops within the • Linkages between ABP and the railway. right locations of the city including existing centres. • More jobs A87. Need more action in relation to providing cheaper • Graduate jobs. charges for new sports centres and tackling demand for unhealthy food which is cheaper than healthy food. Sports • Apprentice schemes centres should cater for differing needs of customers including • Hull too constrained by its tight administrative women or men only classes. boundary.

A87.1 The Open Space audit for the city along with a Facilities • Attract more high value employment opportunities Plan being prepared by the City Council’s Leisure Services to the city section, points to additional facilities being required over the B2.1 The Council agrees that the city needs to make more plan period of the Core Strategy. Further consideration of from opportunities arising from new technology and the port. charges and classes will be considered as part of operational The Core Strategy and other DPDs will provide a context for requirements. What the Council can do as a Planning new economic investment. Authority for these matters and other aspects relating to healthy eating, are limited. B3. Housing • Quality – energy efficient • Funding to support improvements B. Local Area responses • Family friendly B1. We undertook a number of local consultation events • Need for access to affordable housing – truly based at the Councils Customer Service Centres and ‘road affordable – shared ownership show’ events in different parts of the city. The feedback from these events proved useful albeit most were not of strategic • Housing stock improvements necessary significance. These are reported in summary form below, • Houses as well as flats in the centre – too many along with the Councils response in italics. Appendix 3 details flats are being built and not occupied. the actual responses by location.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 21

• Houses that meet people’s needs today and at • Improve public transport provision some point in the future. • Better disabled access to rights of way. Vacant houses should be filled rather than build • B4.1 The City Council recognises all the issues raised and new ones. intends to plan for improvements through the application of • More provision of facilities for Gypsies and suitable policies in the LDF along with effective working with Travellers – more encouragement to use to prevent delivery agents, such as Hull Forward and the Highways illegal camps Agency. A Light Rail system has not yet been proven as a reasonable alternative to other more affordable means of B3.1 The City Council recognises all the issues raised and travelling around the city. intends to plan for improvements through the application of suitable policies in the LDF along with effective working with B5. Open Space & Sports and Leisure facilities delivery agents, such as Gateway. • Need for facilities and security B4. Transport • Need more ‘play space’ not just open space • Should be coordinated and accessible – including • Need facilities to suit a range of ages for mobility impaired. • Need to accessible to disabled children • Need to reduce congestion • Big parks provide valuable spaces • Need for cycle provision – including off-road cycle paths • More diverse range of facilities needed • Quality of routes into the city are important • Youth Clubs – activities to reduce ‘trouble’. • Greater priority to bus lanes • Young Peoples facilities – play areas – teenagers, e.g. The Warren • Parking a real problem • Lack of accessible community facilities – need to • Connections with areas to the east of the city need travel across the city to use larger facilities. improvement • Improve sports facilities, play areas and open space • Light rail system could alleviate congestion problems • Major leisure facility needed in the city centre. • Improvements to M62 and Castle Street • Create more facilities for older people. • Improve Park and Ride sites.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 22

B5.1 The City Council recognises all the issues raised and B8. Quality of environment intends to plan for improvements through the application of • Quality of streetscape and materials important. suitable policies in the LDF along with effective working with delivery agents including those which are Council services. An • Some key characteristics of the city need to be open space audit has been completed which details what and retained – should be seen as part of its uniqueness where improvements should be made. A more detailed sports and what makes it an attractive place – e.g. tree infrastructure study is being developed to consider the cost lined approaches, city parks, landscaping. and need for future opportunities. • Better approaches to the city

B6. Education • Need to remove significant areas of dereliction • BSF Consultation important • Need to tackle fly tipping. • Shared use of facilities could be appropriate • Fear of crime and making people feel safe are important. • University is good B8.1 The City Council recognises all the issues raised and • Need primary school at Kingswood intends to plan for improvements through the application of B6.1 The City Council recognises all the issues raised and suitable policies and proposals in the LDF along with effective intends to plan for improvements through the application of working with delivery agents including Citysafe and suitable policies and proposals in the LDF along with effective Humberside Police. working with delivery agents Hull University and developers at Kingswood, where a planned primary school has yet to be B9. Shops & services provision triggered by housing completions as part of the wider • Appropriate locations development of the area. • Need to retain essential shops and services, B7. City Centre especially locally. • Need for better ‘nightlife’ and café culture – • Worry over churn and displacement of shops although potential conflicts with city centre living. leading to vacancies, particularly with the opening of large schemes in the city centre. • Need to retain the public transport loop • Should be fully accessible by public transport and B7.1 The City Council recognises the issues raised and is within reasonable distance. working with Hull Forward and Hull Bid to improve the city centre evening economy and public transport provision.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 23

• Need to ensure linkage between new facilities – not B10. Regeneration developed ad hoc and in isolation • City needs greater ambition. • Post Offices should be retained • Targeted to appropriate locations. • Disabled access to shops is terrible. • Should not be in isolation. • Balance of uses within centres – improve mix of • Better rail connections. shops. • Look beyond the gloss of big projects. • Restrict permissions for takeaways to promote healthy living. • Tackle areas of ‘slum’ housing. • More off street parking near shops • Create successful neighbourhoods across the whole. • Need to improve services and facilities in the rest of Hull, not just the city centre – some centres • Areas subject to demolition need improving in the especially poor. short term. • Need an anchor supermarket at Northpoint • Buildings are important but population mix needs to change to make a difference. • Need supermarket to serve the area near Pearson Park. B10.1 The City Council recognises all the issues raised and intends to plan for improvements through the application of • Support places of worship including identifying sites suitable policies and proposals in the LDF along with effective for expansion working with delivery agents. Regeneration is currently B9.1 The City Council recognises all the issues raised and focused on different parts of the city including the city centre, intends to plan for improvements through the application of Nasa and Holderness Road Corridor, where major physical suitable policies and proposals in the LDF along with effective change is expected and is being led by key delivery agencies. working with delivery agents. In particular, the City Council will designate a shopping hierarchy which focuses B11. Flood Risk development and investment toward different centres across • Need more flood protection. the city, used in decision making when assessing • Improve drainage systems. development proposals. Other investment opportunities in centres are being considered as part of an investment B11.1 The City Council recognises the issues raised and programme, funded by Yorkshire Forward. intends to plan for improvements through the application of suitable policies and proposals in the LDF along with effective

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 24 working with delivery agents, including Yorkshire Water and B15. Health the Environment Agency. • Promote health living

B12 Renewable Energy B15.1 The City Council recognises all the issues concerning tourism, conservation and health raised and intends to plan Need to harness tidal power in the Humber. • for these proposals through the application of suitable policies • Need more wind turbines in the city. and proposals in the LDF along with effective working with delivery agents. B12.1 The City Council recognises the issues raised and intends to plan for these proposals through the application of suitable policies and proposals in the LDF along with effective C. Stakeholder meetings working with delivery agents, including Hull Forward.

C1. Following comments received from the issues/options B13. Tourist Attractions stage, a number of further meetings with key stakeholders • Appropriate facilities – e.g. toilets. occurred. Details of the conclusions of these meetings are • Family friendly facilities. outlined below:

• Disabled access to buildings and facilities should • Highways Agency, 1.9.08 not be ignored. • More facilities. C2. Transport Impact Model and potential mitigation measures discussed. KHCC agreed to collate and input data • Provide a Youth Hostel. in this model so impact on the PRN could be assessed and • Need designated ‘quiet areas’ in the city where loud mitigation measures considered in more detail. The model music, mobile phones etc. are discouraged. extends across the region so consistent data is used. Further discussions will determine how/when development over the long term can work so as not to unduly affect the network. B14. Conservation Perhaps there is a need to plan for circumstances were A63 • Retain historic buildings. Castle St is or is not completed by 2018. Likely that • Conservation areas are important. improvement will only provide up to 5 years additional capacity and beyond that we will be into managing • City Centre has great Architectural Heritage. congestion. Capacity for the City Centre is already committed • Should make more of Hull’s historical areas. in terms of additional development planned for. Further discussion are needed between Hull, ERYC and HA in

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 25 resolving the approach and avoiding ‘first past the post’ in C5. Vision needs to be more locally specific and reflective of getting planning permissions or LDF’s in place. the big challenges the city faces in the future. KHCC confirmed that vision would be more upfront in the next draft • Kingswood Development Company, 4.9.08 plan and be more specific.

C3. Discussions about the status of the Masterplan for the C6. Discussion about the structure of the document, use of area and details concerning scope of permission, affordable generic options and need to make them locally distinctive, housing requirement, open space requirements and triggers concluded that changes would be made in the next version to for community facilities, along with progress to date, took reflect these matters. Other Councils had used illustrations place. KPDC keen to pursue principle of employment re- within the document to show broad areas of change and allocation to housing and confirmed they wanted us to meet concepts about how these areas might be adapted in the long higher RSS housing requirements, although they agreed a term – so making the document more dynamic was key. stepped approach. There will be flood risk issues to overcome and EA concerns. Pace of development was programmed for C7. GOYH confirmed a need to work in conjunction with review post 2011. Open space provision needed further ERYC in preparing more realistic housing options. KHCC discussion in terms of reviewing requirements. KPDC are confirmed the SHLAA would provide a useful context for this content with a 15% affordable homes requirement. Code for and would be completed prior to release of next draft CS. Sustainable Homes also being reviewed but KPDC have Some concern raised by KHCC about monitoring resource already agreed to Level 2. This is also subject to review. within the Council to ensure effective performance appraisal. Position of the Retail Park was affirmed as per the current position but KHCC are not intending to show this on the Key C8. KHCC told to wait for the revised PPS6 before Diagram, only the proposed new local centre. commissioning a Retail Update, should the Council consider this necessary. • GOYH, 15.9.08 C9. In terms of process, GOYH confirmed LDS would not C4. GOYH gave overall support for the document including need to be reviewed given the ‘submission stage’ equates to being content with the progress being made on the evidence the ‘publication draft’ under the new regulations. GOYH base, with the SHLAA and Infrastructure Study being expects 4 months between publication and submission programmed to be completed. The SHLAA is important in versions. terms of exploring deliverability and how sites beyond 5 years could be brought forward. C10. ‘Strategic locations’ potential inclusion in the CS was discussed including definition and potential difficulties in terms of showing detail on a Proposals Map. GOYH explained that

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 26 the new Proposals Map should be a ‘layering’ of saved and C15. Green infrastructure needs to be more strongly reflected new proposals. Council’s will have to demonstrate which in the CS. KHCC explained this would come after the Open policies from the saved plan are being superseded including Space Audit was completed, expected shortly. those on the Proposals Map. C16. What was critical for Hull was demonstrating an investment package and how this was phased over time. C11. GOYH confirmed they wanted more regular meetings KHCC agreed that CS was aiming for this and initial thoughts with KHCC. They also outlined reasons why they do not had already occurred including a Geographic Investment attend the HDF Forum but welcome minutes, presentations Programme, although this was largely focused on economic etc and agenda from these events. initiatives.

• Regional Assembly, 15.9.09 • Building Schools for the Future, 15.9.08

C12. Discussions about the format of the document but in C17. Discussions about the programme included application general were supportive of approach and reference to RSS. of BSF Strategy (requested by Planning) based on a 10 year The links and relationship with ERYC in demonstrating population projection, including 17% gain in secondary school common understanding of issues/solutions to be put forward attendance. BSF requested that the ‘once in a lifetime’ as housing options need to be stronger and demonstrated in opportunity to improve facilities, education and health, should terms of an audit trail. be made more explicit in the document, if only to promote the likely outcomes. The significance of the programme to the C13. Clear evidence base was needed to explain why we wider integrated regeneration of the city was needed. were moving away from RSS employment and housing numbers. It was accepted by RA that RSS allowed room for • Cabe representative, 17.9.08 being flexible on numbers and any local evidence base would help in RSS review. There were clear messages in RSS about C18. Discussions occurred about the best approach to stepping up housing growth in Hull and reducing numbers in achieving ‘high quality design’ in Hull. A range of design ERYC. related matters was discussed including application and appropriateness of current design policies, potential priority C14. Likelihood is that housing on the edge of the city will not areas for design, accessibility challenges, secure by design, be prevented in the long term but there was a need to link urban greenspaces, housing density, heritage etc. It was contributions sought here to regeneration in Hull. thought a workshop series could help explore these matters and achieve some positive results/outcomes, including a strategic design map for the future city.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 27

C19. A further meeting with Cabe (28.11.08) concluded the xiv. Undertake “Place Check”: What do you like? What don’t following: you like? How can you improve it? xv. Focus more on the idea of waterfront living and making the i. Good summary about why you are producing an LDF – most of your natural assets. Understand your natural assets simple language that the public will understand. and how you can build on them. ii. Need a clear vision. Where is it? Context. At present it is xvi. If you want to change the character of a city in terms of generic. design, you need a stronger, more robust approach to iii. Have the confidence to communicate what you know about policies. Unless you have a clear direction, you will not get the city. Your presentation today was excellent and should be what you want. put into your DPD. xvii. Think about using Building for Life as a benchmark for iv. Scenario building – is the economic scenario, a scenario at quality. all? Look at comparisons and comparatives e.g. other xviii. Look beyond your boundaries – diagrams and maps waterfront cities with constraints such as yours. shown in today’s presentation need to be put into the v. Waterfront is distinctive and needs to come across in the document. document. xix.Try mapping ped sheds and space syntax. This type of vi. Phased / stepped approach to development excellent. Next modelling will help you take the document through to the next to each stage of phasing, would be great to see details of stage. what is needed to improve open space, infrastructure, how xx. Use your Architecture Centre as a neutral vehicle to help many houses / community facilities / schools etc. enable discussion. vii. A number of the options listed are not options – they are givens. • University of Hull, 17.9.08 viii. Need to see the linkages on a map between the areas. There are a series of conflicts at the heart of the options that C20. University meeting held to further explore dialogue about need to be brought out. future intentions at Cottingham Road site. A masterplan for ix. Try and benchmark Hull against the rest of the country. the site was presented and discussion included reference to x. Understand where it is underperforming and performing as need for University to present empirical background work a city region. Discuss quality of place. setting out a broader strategy, multiplier effects, jobs provided, xi. How will you implement your vision? student numbers etc. KHCC considered proposals (largely re- xii. Address the statement on page 113 regarding high quality modelling within the site) did not constitute a ‘major area of design in visible areas. High quality design should cover all change’ but we would amend the document to reflect the areas. significance of the facility for the city. More detailed xiii. Cycling and open space needs to be discussed in the discussions on local impact, greenspace provision and design document. were needed, that would follow.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 28

infrastructure planning was fully integrated as part of the • Gateway Pathfinder, 18.9.08 development of the Core Strategy. C21. Meeting was to discuss any matters of concern from the issues/options document arising from comments received. • Environment Agency, 23.9.08 Main issues focused on extent the CS could better embed Area Action Plans into the document (including outlining the C25. Core Strategy issues/options document discussed in wider impacts across the city and that they would be the detail, including broad support for the content but outline of catalyst for other investment), housing numbers need firming concerns included better ‘state of the city environment’ report, up through the SHLAA and AAPs process including demolition flood risk application of the sequential approach (although figures, and housing mix. There was discussion about further fully supported the SFRA), waste issues being more fully potential areas of change based around the outer estates of referred to, environmental designations being referred to the city. along with greater regard to natural resources such as ground water protection. KHCC confirmed these matters would be C22. Neighbourhood profiles may help in identifying key picked up in the next version of the document. KHCC criteria/needs in different parts of the city that could be readily requested EA prepare a background paper on city drainage used as part of the monitoring process. It was agreed that and SUDs application along with potential for applying a 30% there should be more thorough reference to this in the next reduction in water run off to be applied to major development draft CS. schemes. EA also concerned about re-allocation to housing of existing employment land given the rapid inundation risks C23. Planning contributions would need to be considered as from a breach in the River Hull. part of the Core Strategy rather than AAPs along with establishing the regeneration priorities’ evidence base. • PCT, 25.9.08

• Hull Forward, 22.9.08 C26. Did not take up offer of a meeting although subsequent discussions through a Strategic Needs Assessment work C24. General discussions concluded there was scope to plan have confirmed the need to tackle health and well-being and for a future city and potential for economic regeneration based link this to a planning strategy for the city. around the port, the city centre, renewables cluster and other economic clusters. There was a need to ensure that

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 29

Appendix 1 - Detailed responses made to the Hull Core Strategy issues/options document, June 2008. These responses reflect the details submitted to the City Council.

Comments from stakeholders: 14/10/08

Company / Section Section City Council ID Your response Organisation number title response PPS12 ‘Local Development Frameworks’ notes that the core The need for strategy development plan document should set out broad locations prisons in Hull for delivering the housing and other strategic development needs will be kept under such as essential public services. Paragraph 4.1 encourages early review but it is involvement of government agencies in the preparation of LDFs considered there while paragraph B3 requires local planning authorities to develop a is sufficient strategic approach to infrastructure provision (including community national facilities) when preparing local development documents. guidance to help determine future Circular 3/98 ‘Planning for Future Prison Development’ highlights suitable National Offender the continuing overcrowding within the prison estate and the need locations.

305 Management to replace outdated and inadequate facilities. Specifically there is a Service need to identify more sites for new prisons. The Secretary of State expects that local planning authorities will work together with the Prison Service to identify land for new prisons through the development plan process. The Circular advises that in order to enable authorities to make provision for prisons within their development plans the Prison Service will consult with authorities about likely areas of future need (paragraph 7).

Circular 3/98 recognises at Paragraph 2 that there should be guidance in development plans on community facilities and infrastructure requirements and also that they should take account Response to the Hull Core Strategy issues and options report, June 2008 October 2008 30

Company / Section Section City Council ID Your response Organisation number title response of the need for new prison developments, which should be identified through the planning system.

The Circular notes that in identifying potential prison sites, the Prison Service has to take account of local and regional requirements for additional prison places, the court catchment areas served and the relationship of the site to nearby population centres. It goes on to specify a number of other site development considerations and also recognises that the objectives of sustainable development and in particular the need to reduce unnecessary travel should apply to site selection. Prisons should not be located too far from the centres of population they serve and there should be reasonably good accessibility to public transport services.

The Circular also recognises that new prisons have potential for a substantial and beneficial impact on the economy of a local area. New jobs are created on site (both during construction and permanent jobs), goods and services are purchased in the community and extra local income is generated as a result of the disposable income of prison staff.

In recent years there has been a significant increase in the prison population. In the 1970’s the prison population in England and Wales was in the order of 40,000; in July 2005 that figure had risen to 76,538.

The prison estate is experiencing serious overcrowding. NOMS is doing everything it can to maximise capacity at existing prisons by bringing buildings back into use through refurbishment, new house Response to the Hull Core Strategy issues and options report, June 2008 October 2008 31

Company / Section Section City Council ID Your response Organisation number title response blocks, temporary units and ‘ready to use’ units. However, many prisons are already operating at capacity and there is limited potential to significantly increase the number of places at existing prisons. The prison system is therefore heavily dependent on new prisons to provide the additional places.

While there are no specific proposals for new prison development in your district at present nor specific sites identified, in line with Government guidance NOMS requests that you consider the inclusion of a criteria based policy to deal with a firm prison proposal should it arise during the plan period. I would be pleased to propose a detailed policy for inclusion in your Development Plan Document and would welcome your views on how this proposal should be taken forward.

The economic benefits of prisons are recognised in Circular 3/98. Prisons provide significant permanent employment opportunities across a range of skills. Consequently, the Hull City LDF should acknowledge that HMPs Hull, The Wolds and Everthorpe are important community facilities serving local needs and which should generally be protected. In addition, a policy should be included to support the need for expansion where this can be justified. Similarly, along with other community facilities there should be a presumption against the loss of a prison use unless it is demonstrated to be surplus to requirements. Yorkshire Water supports the proposed stepped approach. This will Support Yorkshire Water allow time for the necessary assessments into the various known welcomed (see 252 Plc constraints facing Hull to be undertaken, for example looking further A1.1) at a multi agency approach to flood risk management in Hull. This

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 32

Company / Section Section City Council ID Your response Organisation number title response will ensure development can be co-ordinated with the necessary infrastructure over the lifetime of the LDF. Comments are considered Government Appended to this document is our ‘commentary’ (Table A) on useful and these Office for issues including reference to use of generic objectives and will be 291 Yorkshire and the structure of the document along with potential omissions including considered in the Humber reference to waste and minerals. next draft stage. See A4.1 and A6.1. General comments These comments will be reflected 1) The document could usefully include additional explanation on in the next draft how Hull fits into the wider sub-region. For example, an introduction (see A3.2 and to the relationship between Hull and the East Riding and where A7.1) relevant the East Riding’s evidence base would be helpful (e.g. the East Riding Housing Market Assessment and Needs Survey and Employment Land Review both identify a strong relationship between Hull and the East Riding of Yorkshire). It should also East Riding of 438 provide a more extensive reference to the Hull and Humber Ports Yorkshire Council City Region and the evidence base for the City Region Development Programme. There is no reference to the fact that those East Riding villages to the west of Hull form part of the wider Regional City as set out in the Regional Spatial Strategy. It must be acknowledged that the links between Hull and the East Riding are a two-way process.

2) It is of great concern that many of the references to the role of See A2.1 – A2.6 East Riding of Yorkshire Council in helping to deliver the proposed

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 33

Company / Section Section City Council ID Your response Organisation number title response strategy for Hull have not been formally tabled with the Council. On this basis it is inappropriate to identify a preferred approach at this stage that involves East Riding delivering on certain expectations. East Riding of Yorkshire Council would welcome the opportunity to discuss these concerns further in order to avoid the Core Strategy containing any policies that are not deliverable (and hence may not pass the examination process).

3) Good practice relating to the preparation of Local Development See A2.1 – A2.6 Frameworks indicates that as far as possible options should be and A5.1 – A5.2 mutually exclusive (i.e. if one option was implemented, the others could not also be implemented). In most instances the options presented within the document are not mutually exclusive and do not consider differing approaches to the key issues. They are more like statements of fact or intent. This is illustrated by the fact that in all but one of the 22 policy options put forward in the document, the preferred option is a combination of all the options. It is a concern that if the document does not put forward meaningful options it may not satisfy the requirements of the planning system to consider and engage with stakeholders on all the options and reasonable alternatives.

4) The document does not identify how the minerals and waste See A8.1 policy framework will be considered in the Core Strategy. It would be useful if the document set out how the strategic elements of minerals and waste are being developed initially through the Joint Minerals and Waste DPDs and will be included within later versions of the Core Strategy (this is the approach that was previously agreed between the two authorities and will be consistent with the East Riding Core Strategy). Response to the Hull Core Strategy issues and options report, June 2008 October 2008 34

Company / Section Section City Council ID Your response Organisation number title response

5) Each set of options is accompanied by a list of suggested ways See A2.1 – A2.6 to measure the preferred option. It would be helpful if the document made reference to how these will be measured and what will be the targets. At the moment it is not possible to comment on whether these measures are realistic or not. For example, what is the target for the reduction of greenhouse gases or the percentage of sites with on-site renewable energy sources?

6) As a result of the above comments, East Riding of Yorkshire See A9.1 Council believes it is important that Hull City Council publishes and consults on a further Preferred Options document. This will allow proper consideration of the matters and help demonstrate that the preferred approach will be deliverable before the publication of a Pre-Submission consultation (which only considers representations relating to soundness).

Natural England believes that the following elements and issues See A15.1 – should be included in the Core Strategy policy document. Site A15.3

379 Natural England Protection, Sustainable Construction, Local Distinctive Habitats, Natural Resource Protection, Protecting Urban Fringe Resources, Incorporating the Natural Environment and Delivering Biodiversity.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 35

Company / Section Section City Council ID Your response Organisation number title response

* Sustainable Construction

Natural England would like to see firmer policies in relation to encouraging more sustainable and innovative construction approaches - including for example sustainable drainage systems, green roof construction and use of local construction materials and techniques.

* Locally Distinctive Habitats

Natural England would like to see more detailed policy relating to the protection and enhancement of locally designated sites of nature conservation importance, and emphasising their role as green infrastructure assets (see above).

* Natural Resource Protection

Sustainable development needs to have regard to the protection of natural resources – including air, water and soil. The Core Strategy needs to include polices for protecting water resources and water quality, as well as quality measures within proposed development scenarios (Section 3.6).

* Protecting Urban Fringe Resources

Natural England would like to see a policy within the Core Strategy which provides for the effective protection and enhancement of urban fringe natural resources alongside development needs. The aim should be to facilitate sensitively planned sustainable urban Response to the Hull Core Strategy issues and options report, June 2008 October 2008 36

Company / Section Section City Council ID Your response Organisation number title response extensions, whilst at the same time protecting and enhancing public access, wildlife and landscape features.

* Incorporating the Natural Environment

Wherever possible, new development should seek to retain and enhance existing features of biodiversity and landscape value within site layouts. The overall design of new developments should aim to achieve a good ‘fit’ within their local and wider landscape setting, informed by an appropriate Landscape and Visual Impact Assessment.

* Delivering Biodiversity

Natural England would like to see a policy commitment in the Core Strategy to the delivery of Local Biodiversity Action Plan targets through the planning system, linked to planning contributions where appropriate. We will in due course be submitting comments on the Approriate See A15.1 – Assessment under the Habitats Regulations which we understand A15.2 are being prepared by Scott Wilson. We do however have some comments below that need to be taken into consideration when preparing the assessment.

380 Natural England The main Core Strategy document should be such that plans and projects (which come forward at a later stage under the auspices of the Core Strategy) do not have the support of the Core Strategy if they could have an adverse effect (alone or in combination) on the integrity of the Humber Estuary SPA/SAC/Ramsar site. This would

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 37

Company / Section Section City Council ID Your response Organisation number title response mean further Habitats Regulations assessments being made of these plans or projects, where relevant.

We consider the following sections and objectives/options are relevant for inclusion in the assessment;

• the "Broad Guiding Principles" section,

• objective/option 7 on flood risk,

• objective/option 8 on transport,

• objective/option 10 on future housing provision,

• objective/option 12 on development of brownfield land,

• objective/option 13 on shopping provision,

• objective/option 14 on tourism, objective/option 20 on sport and active recreation,

• objective/option 21 on employment land,

• objective/option 22 on education provision,

• Section 6 the "Suggested spatial vision for the city",

• Section 8 "Plan delivery and performance",

• the Spatial options map. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 38

Company / Section Section City Council ID Your response Organisation number title response The City Council has not allowed sufficient time for consultation and The City Council there are numerous spelling mistakes in the draft document. is enabling new The paragraph 'Hull in context' contains some potentially interesting forms of analysis which remains disappointingly cursory; greater depth might community have led to a stronger strategy. engagement in developing the I detect the usual despondency about Hull's declining fortunes in LDF to allow this strategy and there should be greater emphasis to highlighting significant ‘buy- its strengths such as the New Theatre. in’ from stakeholders.

It is not the experience of APPRA that 'urban green spaces and See A16.1 other valued places have been protected from potentially adverse Avenues and development.' Sanderson's Field is now built on, despite all the Pearson Park 356 arguments against covering the green part of the site with houses; Residents' we feel that, in the end, money beats conservation and greed wins Association against moderation and design. If the planning system can be rendered more open and accountable, we would perhaps become less cynical. We need, in the Avenues, to believe that the area is valued by the City and is not going to be subject to random decisions in the future. I wish, again, that I could believe in the City's pride in its history; but in practice, historical awareness seems partial.

If the facilities are there, they will attract people and retain the disaffected Hull residents, reversing the trend and the patronizing Old Labour philosophy of the post- war twentieth century. They will 'promote Hull as a good place' to live and work in, and to visit. Build on Hull's assets.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 39

Company / Section Section City Council ID Your response Organisation number title response General comments. The Core Strategy needs to be seen as a key These comments driver of regeneration, providing the planning framework for will be reflected delivery, as well as providing the policy framework for planning in the next draft applications etc. It does not yet show how it will achieve this. version. See also A18.1 The AAP process is really not well embedded in this document (and presumably they should be) e.g. boundaries shown inconsistently, no attempt to identify future AAP's beyond the current three (unlike on spatial strategy which also included North Hull and 'Inner Core'). 39 Gateway 1. Introduction Also the document does not properly explain how AAP's will be used to manage and drive change in the city.

It needs to acknowledge that the profile of what gets built in areas of change will alter over the regeneration period. The change won't all happen at once, would expect to see smaller cheaper, dwellings in the early years, with an infrastructure to create demand for the area. This needs to somehow be captured in the trajectory of change. General comments and introduction. Natural England’s role is to See A15.1 – conserve and enhance the natural environment, for its intrinsic A15.3 and A16.1 value, the well-being and enjoyment of people and the economic prosperity that it brings.

91 Natural England 1. Introduction Natural England has defined four strategic outcomes that will be used to focus our activities and resources, and our advice on the current consultation is set in the context of these outcomes:

A healthy natural environment: England’s natural environment will be conserved and enhanced;

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 40

Company / Section Section City Council ID Your response Organisation number title response

Enjoyment of the natural environment: more people enjoy, understand and act to improve the natural environment, more often;

Sustainable use of the natural environment: the use and management of the natural environment is more sustainable;

A secure environmental future: decisions which collectively secure the future of the natural environment. General comment responding to all objectives and options. These comments will be reflected I feel that all 22 options need to be considered as part of a regional in the next draft strategy which includes education, employment and economic version. Local resident 156 1. Introduction factors.

To attract the modern wealth creating industries to the area we need a suitably educated workforce to man it. The housing strategy will then fall into place. The Port of Hull is a gateway to both Hull and the wider region, These comments which plays a vital role in the local and regional economy, will be reflected promoting economic competitiveness and encouraging investment, in the next draft as well as being a significant employer in the area. As such, ABP version but the requests that their existing operations at the Port of Hull are role of the port is Associated 297 1. Introduction protected in the Hull Development Framework Core Strategy. ABP fundamental to British Ports also request that flexibility is provided, allowing for any future the future of the expansion, particularly at Alexandra, Queen Elizabeth and King local economy. George Docks.

Notwithstanding the above, ABP are currently considering the

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 41

Company / Section Section City Council ID Your response Organisation number title response future for Albert and William Wright Docks, as these facilities might not be as economically viable for port related activities in the long term, due to the vessel size restrictions under which they operate. As such, it is possible that part, or even the whole, could become available for redevelopment in the next 5 to 10 years, given a suitable redevelopment opportunity. ABP therefore request flexibility is provided by the Hull Development Framework Core Strategy, to allow for the possible redevelopment of Albert and William Wright Docks for a residential led mixed use scheme. There are numerous typos in the document or lack of clarity. One There is always way to reduce the carbon footprint of new buildings is surely to potential for maximise the use of locally source materials, not that such use policies to pull in should be “limited” (58). And what are we to make of the suggestion different that current priorities could be undermined by “not allowing directions. The proposals which may threaten their success” (55)? intention is to provide a policy You often cite as desirable aims which are contradictory: for framework for 197 1. Introduction Local resident example, “improving street design so they are pedestrian friendly” decision making is incompatible with “kerbside parking” (53): a street lined with which allows for parked cars is not pedestrian friendly. Encouraging employment local discretion. opportunities “especially along the A63 corridor” (48) is not compatible with the considerations of A41 (56–57): if it were possible, it would increase car journeys; and it is also undesirable because of the risk of economic displacement draining the City (cf. 4.14, page 36). The Highways Agency’s primary interest in the LDF process is in See A17.1 Highways respect of a Council’s planning policies and proposals as they 204 1. Introduction Agency might have a material impact on the safe and efficient operation of the Strategic Highway Network (SRN). To this end the Highways

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 42

Company / Section Section City Council ID Your response Organisation number title response Agency’s role in the planning process is set out in DfT Circular 02/2007: Planning and the Strategic Road Network.

The Highways Agency will be pleased to be involved in the preparation of the documents and provide advice in respect of the Strategic Road Network (SRN) which, in the case of Hull, relates to the A63 and A1033, as firmer options emerge.

Background

As you will be aware, the A63 and A1033 are part of the SRN in Hull. The A63 is ‘Core’ Trunk Road, meaning it is of national strategic importance. The Agency acknowledges the A63 has a key role in attracting investment and growth to the Hull and Humber City Region area, as it provides a link to the city region from the rest of the region and country as well as providing connections within the city region itself. The A63 and A1033 also form part of the Trans-European Network connecting Eire with northern Europe. Thus they form an important corridor to the port of Hull.

The Agency recognises that improvement measures and schemes will be of importance to the growth of Hull. Indeed the M62 Route Management Strategy (RMS), which commenced in 2002, is still being used to inform the way we look to improve, manage and operate the M62 and A63.

The A63 is highlighted as an area of particular concern in the Highways Agency regional network report 2008, between A1034 and A1033 in both directions, the observed delay in this location in total vehicle hours (2006) was over 125,000. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 43

Company / Section Section City Council ID Your response Organisation number title response

At present the A63 Castle Street, Kingston upon Hull is a constraint to any large development within the city or its hinterland that would have a traffic impact on that section of the SRN. The Highways Agency are currently reviewing scheme options for improvements for Castle Street for inclusion in the Regional Programme. In the interim a package of short term measure have been agreed between the Highways Agency and Hull City Council to enable some development to proceed in central Hull.

The Highways Agency has reviewed your Core Strategy Issues, Options and Preferred Option Document and would wish to comment on those issues that are relevant to the interests of the Agency. The Agency’s key concern is to protect the primary role of the Strategic Road Network and to ensure its safe and efficient operation.

The Highways Agency will be pleased to assist you in evaluating the likely impact of contending development sites, particularly for employment and residential use and advise you on which sites could be accommodated by the SRN, which may need some form of mitigation and which would be opposed by the Agency. The Highways Agency is also working with East Riding of Yorkshire Council on their emerging core strategy and would be keen to help both authorities understand the cross boundary issues associated with your plans and the joint impact of the plans. We have a number of analysis tools which will help provide an evidence base for sites likely to have a material impact on the SRN. 439 East Riding of 1. Introduction Para 1.3. This paragraph states that individual sites will not be See A10.1

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 44

Company / Section Section City Council ID Your response Organisation number title response Yorkshire Council allocated in the Core Strategy. However, recent changes to PPS12 identify that Core Strategies may allocate strategic sites for development. Does the City Council intend to reconsider this matter? If so, it may be necessary to prepare a further Issues and Options consultation document to consider this issue. One of the key issues is the relationship with East Riding, See A3.1 – A3.2 especially in view of the replacement of JSP by 2 separate core and A7.1 – A7.2 strategies. Whilst both working to the RSS there is a real danger that co-ordinated thinking will be completely lost. How will both 398 Hull Forward 1. Introduction authorities work together? What protocols are in place regarding relevant development proposals in the East Riding? How are these being reviewed, updated, implemented and enforced? How will policy EC1 of JSP be carried forward into ERYC’s new core strategy? As you know, the Planning and Compulsory Purchase Act 2004 Support introduced mechanisms to help ensure that Development Plan welcomed Documents (DPDs) drawn up by local authorities as part of the Local Development Framework (LDF) are in general conformity with the Regional Spatial Strategy (RSS). The intention is to ensure that DPDs are contributing to the delivery of the RSS and that the Yorkshire and two strands of the Development Plan for an area (the RSS and 354 Humber 1. Introduction DPDs) are mutually supportive and not in conflict. Assembly

There is a need to set out the need for the Core Strategy to be in general conformity with the RSS, which for clarification is now The Yorkshire and Humber Plan (Regional Spatial Strategy to 2026) and was published on 21 May 2008. The Assembly also welcomes references made throughout the document to RSS (May 2008).

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 45

Company / Section Section City Council ID Your response Organisation number title response Government Para 1.3. The Core Strategy (CS) can allocate strategic sites, see See A10.1 Office for What is a Core paragraphs 4.6 – 4.7 of (new) PPS12. This may be relevant for you 262 Yorkshire and the Strategy? given the possibility of ‘urban extensions’ as detailed at Option 2 (2) Humber p.37. Para 1.9 refers to the production of a preferred options document. See A5.1 – A5.2 You should be aware that following the amendments to the 2004 Regulations this milestone no longer exists. However, you may Government What is this wish to explore how you anticipate the evolution of the document Office for 263 document through the rest of production stage – is there not some overlap Yorkshire and the about? between this and a ‘preferred options document’? You will Humber presumably need to address whether the LDS is up to date and accurate; and consider how much choice is actually being proposed – see comments below re. section 5 and options. Para 1.20. Suggests that the CS will not be concerned with waste See A8.1 Government or minerals matters. You may wish to reconsider – the CS is the What is the Office for overall spatial strategy for the area, as such it will need to address 265 ‘new’ planning Yorkshire and the all relevant matters and show how they interact and form a whole. system? Humber Our comments in previous e-mail correspondence with you about the Joint Waste DPD are relevant. Paras 2.1-2.8. See A15.1 – A15.2 and A16.1 The RSPB would like to see a paragraph setting Hull's environmental context. This needs to convey the following:

324 RSPB 2. Hull in context Hull lies adjacent to the Humber Estuary Special Protection Area (SPA), also designated as a Ramsar site, Special Area of Conservation and SSSI. The SPA is designated for its migratory and wintering waterfowl and breeding Annex 1 species such as Avocet, Bittern, Marsh Harrier which are afforded special Response to the Hull Core Strategy issues and options report, June 2008 October 2008 46

Company / Section Section City Council ID Your response Organisation number title response protection.

Several SPA bird species are known to rely upon agricultural land surrounding the estuary for roosting and feeding at high tide (when mudflats are submerged temporarily making the estuary unavailable to them). These areas may be functionally linked to the SPA and as such, the birds using them should be afforded special protection.

Birds afforded special protection under the Habitats Regulations include SPA waders that roost on man-made structures and brownfield sites along the Hull frontage at high tide. It is essential, that all potential impacts of the Core Strategy on SPA birds are fully identified and relevant policy changes made to ensure that the integrity of the internationally important site is not affected. Potential impacts include direct and indirect habitat loss and disturbance. The Highways Agency would like to include a statement regarding This reference the state of the Strategic Road Network in the context statement. will be included Suggested wording: in the next draft document. “The M62/A63 corridor forms a vital link between the strategic road Highways 222 2. Hull in context network, Humber Bridge and the Humber ports. The daily traffic Agency flow on this road is very high, the Highways Agency Regional Network Report highlights the M62/A63 as an area of high levels of stress on the Strategic Road Network and forecasts that there will be considerable pressure on this section of the network in future years.” Government We feel that setting out the issues in such a way is helpful, i.e. Support 266 2. Hull in context Office for establishing local contexts as drivers for change. This should be welcomed. See

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 47

Company / Section Section City Council ID Your response Organisation number title response Yorkshire and the reflected as the CS progresses with such issues all addressed by also A12.1 Humber the objectives, strategy, policies to deliver etc, with appropriate area emphasis. This will be Hull & Humber Para 2.2. The port certainly is of national importance - as recognised in the 298 Chamber of 2. Hull in context acknowledged in paragraph 2.7 next draft Commerce document. Policies in RSS seek to focus development on the region’s town Support and city centres. The Core Approach (Policies YH1-YH9) makes it welcomed as clear that most new development, and high trip generating uses, well as wider should be focussed on Regional Cities and Sub-Regional Cities recognition of the and Towns and that away from these sufficient development should role of Hull as a be permitted in Principal Town to enable them to fulfil their role as Regional City service centres. alongside the good fit of the The Assembly welcomes the reference to the identification of Hull Core Strategy as a Regional City in RSS (paragraph 3.2). Policy YH4 of RSS with RSS. Yorkshire and provides for Regional Cities to be the prime focus for housing, 355 Humber 2. Hull in context employment, shopping, leisure, education, health and cultural Assembly activities and facilities in the region. More specifically, Policy HE1 A provides for plans, strategies, investment decisions and programmes for the Humber estuary to transform the role of Hull as a Regional City, particularly through remodelling the city centre to provide more and better jobs, shops, services, public spaces and homes, and transforming residential areas to create a better mix of housing and quality environments.

It will be important for the Core Strategy to set out the context provided by the sub area policies and the relationship that Hull has

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 48

Company / Section Section City Council ID Your response Organisation number title response with the rest of the sub area, in particular with the East Riding.

Policy YH4 identifies Hull as a Regional City in the Humber Estuary sub area, with Scunthorpe and Grimsby/Cleethorpes as Sub Regional Towns. Policy YH5 identifies Driffield, Beverley, and Goole as Principal Towns.

Policy HE1 A the relevant sub area policy provides for plans, strategies, investment decisions and programmes for the Humber estuary to transform the role of Hull as a Regional City, particularly through remodelling the city centre to provide more and better jobs, shops, services, public spaces and homes, and transforming residential areas to create a better mix of housing and quality environments. The role of Scunthorpe and Grimsby/Cleethorpes as Sub Regional Towns, particularly through town centre renaissance and housing renewal and growth. Also the roles of Beverley, Driffield and Goole should be supported as Principal Towns.

Policy HE1 E states that most development in the Humber Estuary sub area should be focussed on Hull, Scunthorpe and Grimsby/Cleethorpes, with development promoted at Goole, Beverley and Driffield to strengthen their service centre roles and where necessary aid regeneration or provide more affordable housing. Yorkshire Water suggests that rather than having a sentence The City Council Yorkshire Water Big issues regarding flooding for the majority of the sub-areas in Hull it is notes this 247 Plc facing Hull instead identified in the big issues section or within the introduction comment. to local issues.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 49

Company / Section Section City Council ID Your response Organisation number title response Para 2.10. “provides a snapshot of key issues facing the city”. It is Agreed and will noted that there is no reference to environmental issues, in be reflected in Environment Big issues 386 particular Flood Risk and Climate Change which we consider to be later draft Agency facing Hull significant issues facing Hull now and in the future and should be documents. included within the list on page 15. Page 18 onward. Doesn’t mention AAPs as vehicle for determining See A18.1

35 Gateway Local issues what happens in the areas of change mentioned here. Princess Royal site should surely refer to AAP as determining its future? Para 2.13. The Core Strategy must be based on a full See A9.1 understanding of the potential planning issues facing each of the city's areas. It is recognised that the issues listed at paragraph 2.13 are not intended to be exhaustive. That said, the most important issues should be listed and the Core Strategy should follow from them.

In this context, the issues listed under North Carr (and the elements Support Wildmoor (Hull) 66 Local issues of the Core Strategy that relate to them), should include the welcomed for Ltd. continued growth and development of Northpoint as a district centre reference to and service hub, as a focal point at the heart of this community, and North Point as a in providing shopping and public and private services at a highly District Centre. accessible location.

Any Core Strategy text setting out the key issues facing the different areas of Hull should make reference to the importance attached to the continued growth and development of Northpoint. Within the analysis of local areas across the City (para 2.13) Noted and Wrenbridge Land reference should be incorporated within the Core Strategy to both detailed 142 Local issues Limited the Kingston Communications Stadium and Anlaby Road. comments are being considered Response to the Hull Core Strategy issues and options report, June 2008 October 2008 50

Company / Section Section City Council ID Your response Organisation number title response Whilst paragraph 2.6 of the Core Strategy recognises that the City as part of the has been transformed through exciting new developments, Nasa AAP. See including the KC stadium, the further potential of the stadium within also A18.1. the Newington and St Andrews area should be recognised.

Granted planning permission in December 2000 the stadium attracts a large number of people to the City, with a current capacity of 25,400 and permission to expand this. The important role of the stadium, linked to the surrounding community through a series of educational, sporting and community functions, including Hull College's Learning Zone, should be fully recognised in the Core Strategy, alongside the emerging Newington and St Andrews Area Action Plan "NaSA AAP".

Indeed, the NaSA AAP recognises that the Anlaby Road and West Park area including the stadium, is a main route into the City, 'the area's shop window and action is needed here to ensure it puts its best on display' (para. 8.1.2). This approach reflects the original rationale for granting planning permission for the stadium in this location and should be acknowledged within the Core Strategy given the strategic importance of the stadium to the City.

Similarly, the emerging NaSA APP recognises that Anlaby Road is a main route into City as well as being an important local centre and community hub. Accordingly, the AAP envisages this as being a central area of change, and a key gateway into the city, which should be recognised at the Core Strategy level. The Clough Road area, and the National Grid site specifically, are Noted. See also 185 National Grid Local issues identified within the text (para 2.13) as providing the potential for A18.1

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 51

Company / Section Section City Council ID Your response Organisation number title response regeneration through mixed use development. National Grid support the general encouragement for regeneration contained within the HDF, and the recognition that regeneration should take the form of a mix of uses. Para 2.13 sets out potential planning issues facing each of the Support Tesco Stores 307 Local issues city’s Areas and in relation to the Northern area it states ‘re- welcomed. Limited establish a centre for Orchard Park’, we strongly support this. The Highways Agency suggest the following wording be inserted Issue of highway Highways into the potential planning issues facing West, Riverside and Park: capacity in these 223 Local issues Agency locations is “Capacity issues on the Strategic Road Network” noted. Para 2.13. East Riding of Yorkshire Council supports the Comments suggestion that ‘making more of the link with nearby Cottingham’ is noted. a planning issue for the northern area committee boundary. It is particularly important to reflect the need to link with the emerging employment proposals in that area (on Dunswell Road and North East Riding of 440 Local issues Moor Lane). Yorkshire Council

Transport/highway constraints should be identified as an issue for the Park Area committee boundary. This is especially the case if the area is to accommodate an expansion of manufacturing and warehouse uses on Hedon Road. The locally specific issues in paragraph 2.13 identify flooding issues Agreed and this in 5 out of the 7 local areas, saying that there is an impact on wider issues will Environment “perception for people moving to the area”. Flood risk is an issue, be addressed in 387 Local issues Agency not just a perception, that affects a large percentage of the city and the next draft is not restricted to specific areas. We suggest that this is another document. factor in adding flood risk to the list of issues on page 15. We

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 52

Company / Section Section City Council ID Your response Organisation number title response consider it is inconsistent for flood risk not to be included as significant issue. Para 2.16. The East Riding Local Development Framework and Agreed and will accompanying evidence base should be identified in this section as be referred to in East Riding of Other policies 441 an important local plan/strategy. This is an important omission the next draft Yorkshire Council and strategies given the subsequent references in the document to the East document. Riding of Yorkshire. We will await the Para. 2.16. 2.16 – just to note the Integrated Regional Framework draft document in Other policies 399 Hull Forward (precursor to Integrated Regional Strategy) published by the considering its and strategies regional assembly may also be relevant. significance for Hull. Para 2.23. There is no mention of equality of access, many people The Community Hull Access Community are restricted by their physical disadvantages from taking part in the Strategy does

43 Improvement Strategy as a economic life of our city simply because of oversights in planning not refer to this. Group starting point and design. The Core Strategy is an excellent vehicle to address See also A46.1 this problem. Hull Access Sustainability Agreed and will Para 2.26 Bullet point 5 change wording to read “equality of 12 Improvement Appraisal revise this. opportunity for all” and not “support equity for all”. Group Framework The way this is written suggests interventions in Holderness Road Preparatory work Corridor won't start until after 2014, which isn't the case. for this period Future pace of begins around 37 Gateway 3. change – city General comment. No Quality of Life monitoring framework is 2008/9. scenarios proposed. How will we know if the stepped approach is on the right See also A12.1 course to meet economic/demographic change? Wrenbridge Land Future pace of Wrenbridge Land Limited ("WLL") considers that the Core Strategy See A2.1 – A2.6 141 3. Limited change – city for Hull should be based on a strategy which seeks to deliver high Response to the Hull Core Strategy issues and options report, June 2008 October 2008 53

Company / Section Section City Council ID Your response Organisation number title response scenarios economic growth in accordance with the Regional Economic and Spatial Strategies.

Through a growth based economic strategy more jobs and investment will be attracted into the City increasing the pace of economic growth. Currently, as recorded in the emerging Core Strategy, Hull's employment rate is significantly lower than the national and regional averages; the Core Strategy should plan to address this.

To achieve this growth, as the emerging Core Strategy records (para 3.12), it is agreed that there is a requirement to make sure sufficient, readily available land and premises are identified to meet both short and longer term requirements.

Further, through enhanced educational opportunities, there is potential to increase educational attainment thereby increasing the prospects of Hull's residents, as recognised in the Core Strategy. Combined, this approach will assist in reducing the levels of deprivation across the City which, it is understood, is currently ranked 11th most deprived of all 354 authorities in England. It is, therefore, crucial the Core Strategy and Local Development Framework is predicated on a positive, ambitious growth strategy. As already recognised by the Council, any divergence from this approach would dilute the positive impact.

However, it is of note the recently finalised Yorkshire and Humber Plan: the Regional Spatial Strategy to 2026 ("RSS") has identified, from 2006, the potential annual job growth in Kingston upon Hull as 910 jobs per annum (see table 11.1). Accordingly, by 2026 the RSS Response to the Hull Core Strategy issues and options report, June 2008 October 2008 54

Company / Section Section City Council ID Your response Organisation number title response projections would result in an increase of 18,200 jobs. This is significantly higher than the 8,000 jobs envisaged in the emerging Core Strategy and already indicates a Core Strategy that is potentially diluting or constraining the potential positive impacts of economic growth, out of conformity with higher tier planning policy. WLL request that this be addressed in future iterations of the Core Strategy and a more positive growth scenario be adopted in accordance with RSS. The HDF presents a number of alternative City (growth) Scenarios, See A2.1 – A2.6. ranging from (i) maintaining the current trend (including population See also A32.1 and commercial decline), through to (iii) high economic growth in Future pace of both housing market renewal and employment generation. 186 National Grid 3. change – city Objective 1 of the HDF is “…to work towards a high growth future scenarios for the City over the long term”. National Grid support this objective, and in doing so promote their Clough Road site as being a suitable location for assisting sustainable economic growth within the City. para 3.8: This is not just "aspirational" but totally unrealistic. A more See A2.1 – A2.6. plausible approach would be to try to step up to Scenario B, and if successful (this looks to be long-term), a new framework by then Future pace of Friends of could incorporate Scenario C. 230 3. change – city Pearson Park scenarios para 3:18: For Scenario C to be even remotely successful, the attitude and behaviour of many of Hull's citizens would have to change. Para. 3.12. To achieve high growth there are likely to be negative A15.1 – A15.2 Future pace of impacts on natural resources (e.g. water) and the environment. It is 327 RSPB 3. change – city essential that the Core Strategy include strong sustainable policies scenarios and environmental protection to ensure that growth does not exceed the environment's capacity to sustain it. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 55

Company / Section Section City Council ID Your response Organisation number title response Para 3.3. Reference to the current economic climate is useful. The See A3.1 – A3.2 Future pace of document should also set out that it needs to provide a realistic and East Riding of 447 3. change – city flexible response to wider economic influences, but in the context of Yorkshire Council scenarios the need to continue to develop the city’s competitiveness as a place to live and do business. Para 3.8. ‘unprecedented growth in service and financial sector See A3.1 – A3.2 Future pace of East Riding of economy’ is a misleading précis of the CRDP. Its jobs and outputs 448 3. change – city Yorkshire Council figures are based on econometric projections, i.e. take account of scenarios precedented growth across a spectrum of sectors. Objective 1 should be rephrased to read, "To work towards a high See A3.1 – A3.2 growth future for the city over the medium to long term." The option Wildmoor (Hull) Objective 67 to achieve this objective should be to consider what is needed to Ltd. 1 move away from Scenario A; deliver Scenario B as a minimum; and follow an accelerated programme towards Scenario C. A key element in the delivery of Objective 1 will be the creation of a See A16.1 high-quality environment – particularly (as Paragraph 3.8 states) if it English Heritage is intended to attract more middle-income families into the City. Objective 157 Yorkshire and This need to be achieved not only through major redevelopment 1 Humber Region projects and investment in the public realm but also through safeguarding and investing in those elements which make the City distinctive, especially its wealth of historic buildings. Henderson Objective Support 311 Working towards a high growth future for the city is supported. Global Investors 1 welcomed. Objective will be Objective RSPB would like to see this objective amended to "to work towards 328 RSPB amended 1 a high level of sustainable growth". accordingly. Objective Objective 1: “to work towards a high growth future.” The kind of See above 198 1 growth needs defining: not all growth is sustainable; much growth in suggested Response to the Hull Core Strategy issues and options report, June 2008 October 2008 56

Company / Section Section City Council ID Your response Organisation number title response fact is by definition not sustainable. It would be preferable to limit change. aims to Option 1, or a stepped approach. Objective 1 should be rephrased to read, "To work towards a high See A2.1 – A2.6 growth future for the city over the medium to long term." The option Dransfield Objective 381 to achieve this objective should be to consider what is needed to Properties Ltd 1 move away from Scenario A; deliver Scenario B as a minimum; and follow an accelerated programme towards Scenario C. Having regard to RSS policy, we support ‘Scenario C’, supporting See A2.1 – A2.6 high economic growth, whilst accepting that this will be a challenging and aspirational agenda. RSS policy, HE1, places an onus on Hull City Council to plan for growth, stating: “Plans, strategies, investment decisions and programmes for the Humber Estuary sub area should … Transform the role of Hull as a Regional City, particularly through remodelling the city centre to provide more and better jobs, shops, services, public spaces and homes, and transforming residential areas to create a better mix of housing and quality environments.”

34 Barratt Homes Options 1 Policy HE1 requires the City Council to work towards a high growth scenario. We object to the alternative scenarios as we consider that Scenario A, to follow current trends, and Scenario B, to plan for low economic growth, would be inconsistent and out of step with policy HE1 of the RSS. We consider that Scenario C, which plans for a population increase of 11,300 and job increases of 8,000 is most in line with the RSS.

Moreover, in respect of the identified scenarios we object to the general approach taken. We consider these to pose leading options, as the alternatives are unrealistic. Scenario A, entitled

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 57

Company / Section Section City Council ID Your response Organisation number title response ‘follow current trends’, identifies that the Council currently act in a reactive manner to the identified issues of environmental deterioration, deprivation and economic decline. There are currently a number of planning initiatives taking place in the City, such as Gateway Pathfinder and a number of City Centre developments which identify that the Council are acknowledging the need for proactive planning. We therefore feel that Scenario A is a leading option which does not reflect current Council strategy or reality and as such no one would wish to select this option. In respect of Scenario B, ‘Low Economic Growth’, the prospective growth figures identified within the scenario (namely housing) are below that identified within the adopted RSS. We therefore consider that Scenario B identifies a negative development strategy which will ensure the City continues to under perform when assessed against adopted planning guidance. Finally, Scenario C, ‘High Economic Growth’, is misleading in that it simply proposes a level of development that would practically meet the identified objectives for the City within the adopted RSS. This is evident in respect of housing as Scenario C identifies that by 2026 new dwellings in the City are proposed to increase by around 23,100, where as the adopted RSS proposes a requirement of 24,000 additional dwellings to be provided within the City by 2026.

As stated above, we therefore support ‘Scenario C’ as the level of growth identified within it sets out an aspirational agenda for the City which is more in line with the identified objectives of the adopted RSS. Hull Access A stepped approach is fully supported as being the most sensible, it See A1.1 44 Options 1 Improvement provides an ultimate goal with the inbuilt flexibility to adapt to

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 58

Company / Section Section City Council ID Your response Organisation number title response Group changing needs. In broad terms, a combination of the three options is appropriate, in See A1.1 and a stepped manner, but they should be cast in a more positive light. A2.1 – A2.6.

It is of course necessary to consider what is required to move away from Scenario A (Option 1.1). It is also necessary to deliver Scenario B (Option 1.2), but not as, "the most realistic way Wildmoor (Hull) 68 Options 1 forward". This scenario only reflects low economic growth, and Ltd. should be regarded as cautious, not "most realistic".

Scenario C (Option 1.3) is challenging, but greater emphasis should be placed on it in planning positively for the future, and in particular with encouraging a more rapid pace of change that will help to deliver the level of growth it anticipates. Options 1 sets out three scenarios for the most desirable scale and See A2.1 – A2.6 type of future growth to 2026. Scenario A reflects current trends with a total housing requirement of 15,800 dwellings. Scenario B seeks low economic growth with a total housing requirement of 19,600 dwellings, whilst Scenario C sets out high economic growth with a housing requirement of 23,100 dwellings.

71 Kayterm Ltd Options 1 Having regard to RSS policy, we support ‘Scenario C’, supporting high economic growth, whilst accepting that this will be a challenging and aspirational agenda. RSS policy, HE1, places an onus on Hull City Council to plan for growth, stating: “Plans, strategies, investment decisions and programmes for the Humber Estuary sub area should … Transform the role of Hull as a Regional City, particularly through remodelling the city centre to provide more and better jobs, shops, services, public spaces and

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 59

Company / Section Section City Council ID Your response Organisation number title response homes, and transforming residential areas to create a better mix of housing and quality environments.”

Policy HE1 requires the City Council to work towards a high growth scenario. We object to the alternative scenarios as we consider that Scenario A, to follow current trends, and Scenario B, to plan for low economic growth, would be inconsistent and out of step with policy HE1 of the RSS. We consider that Scenario C, which plans for a population increase of 11,300 and job increases of 8,000 is most in line with the RSS.

Moreover, in respect of the identified scenarios we object to the general approach taken. We consider these to pose ‘leading’ options as the alternatives are unrealistic. Scenario A, entitled ‘follow current trends’, identifies that the Council currently act in a reactive manner to the identified issues of environmental deterioration, deprivation and economic decline. There are currently a number of planning initiatives taking place in the City, such as Gateway Pathfinder and a number of City Centre developments which identify that the Council are acknowledging the need for proactive planning. We therefore feel that Scenario A is a ‘leading’ option which does not reflect current Council strategy or reality and as such no one would wish to select this option.

In respect of Scenario B, ‘Low Economic Growth’, the prospective growth figures identified within the scenario (namely housing) are below that identified within the adopted RSS. We therefore consider that Scenario B identifies a negative development strategy which will ensure the City continues to under perform when assessed against adopted planning guidance. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 60

Company / Section Section City Council ID Your response Organisation number title response

Finally, Scenario C, ‘High Economic Growth’, is misleading in that it simply proposes a level of development that would practically meet the identified objectives for the City within the adopted RSS. This is evident in respect of housing as Scenario C identifies that by 2026 new dwellings in the City are proposed to increase by around 23,100, where as the adopted RSS proposes a requirement of 24,000 additional dwellings to be provided within the City by 2026.

As stated above, we therefore support ‘Scenario C’ as the level of growth identified within it sets out an aspirational agenda for the City which is more in line with the identified objectives of the adopted RSS. We support this Option. We are pleased to note (in Paragraph 4.7) See A2.1 – A2.6 English Heritage that the preferred option is based upon having taken full account of

158 Yorkshire and Options 1 the known constraints which might limit the developability of land Humber Region within the city, especially the need to ensure that development will not adversely affect Hull’s historic assets. Natural England considers that Objective 1 (option 2) page 30 is See A2.1 – A2.6 most appropriate as this will help develop the city whilst protecting the natural environment that surrounds it. Consideration should 92 Natural England Options 1 also be given to setting growth within the environmental limits/ environmental capacity of the city due limited land, flooding and designated environment that surrounds the city. In broad terms, a combination of the three options is appropriate, in See A2.1 – A2.6 a stepped manner, but they should be cast in a more positive light. Dransfield 128 Options 1 Properties Ltd It is of course necessary to consider what is required to move away from Scenario A (Option 1.1). It is also necessary to deliver Response to the Hull Core Strategy issues and options report, June 2008 October 2008 61

Company / Section Section City Council ID Your response Organisation number title response Scenario B (Option 1.2), but not as, "the most realistic way forward". This scenario only reflects low economic growth, and should be regarded as cautious, not "most realistic".

Scenario C (Option 1.3) is challenging, but greater emphasis should be placed on it in planning positively for the future, and in particular with encouraging a more rapid pace of change that will help to deliver the level of growth it anticipates. Options 1 set out three scenarios for the most desirable scale and See A2.1 – A2.6 type of future growth to 2026. Scenario A reflects current trends with a total housing requirement of 15,800 dwellings. Scenario B seeks low economic growth with a total housing requirement of 19,600 dwellings, whilst Scenario C sets out high economic growth with a housing requirement of 23,100 dwellings.

Having regard to RSS policy, we support ‘Scenario C’, supporting high economic growth, whilst accepting that this will be a Kingswood Parks challenging and aspirational agenda. RSS policy, HE1, places an

93 Development Options 1 onus on Hull City Council to plan for growth, stating: “Plans, Company strategies, investment decisions and programmes for the Humber Estuary sub area should … Transform the role of Hull as a Regional City, particularly through remodelling the city centre to provide more and better jobs, shops, services, public spaces and homes, and transforming residential areas to create a better mix of housing and quality environments.”

Policy HE1 requires the City Council to work towards a high growth scenario. We object to the alternative scenarios as we consider that Scenario A, to follow current trends, and Scenario B, to plan for low

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 62

Company / Section Section City Council ID Your response Organisation number title response economic growth, would be inconsistent and out of step with policy HE1 of the RSS. We consider that Scenario C, which plans for a population increase of 11,300 and job increases of 8,000 is most in line with the RSS.

Moreover, in respect of the identified scenarios we object to the general approach taken. We consider these to pose leading options, as the alternatives are unrealistic. Scenario A, entitled ‘follow current trends’, identifies that the Council currently act in a reactive manner to the identified issues of environmental deterioration, deprivation and economic decline. There are currently a number of planning initiatives taking place in the City, such as Gateway Pathfinder and a number of City Centre developments which identify that the Council are acknowledging the need for proactive planning. We therefore feel that Scenario A is a leading option which does not reflect current Council strategy or reality and as such no one would wish to select this option. In respect of Scenario B, ‘Low Economic Growth’, the prospective growth figures identified within the scenario (namely housing) are below that identified within the adopted RSS. We therefore consider that Scenario B identifies a negative development strategy which will ensure the City continues to under perform when assessed against adopted planning guidance. Finally, Scenario C, ‘High Economic Growth’, is misleading in that it simply proposes a level of development that would practically meet the identified objectives for the City within the adopted RSS. This is evident in respect of housing as Scenario C identifies that by 2026 new dwellings in the City are proposed to increase by around 23,100, where as the adopted RSS proposes a requirement of 24,000 additional dwellings to be provided within the City by 2026. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 63

Company / Section Section City Council ID Your response Organisation number title response As stated above, we therefore support ‘Scenario C’ as the level of growth identified within it sets out an aspirational agenda for the City which is more in line with the identified objectives of the adopted RSS. We agree with the "stepped approach" of paragraph 3.18 the See A1.1 and development proposed in the city centre Masterplan was conceived A2.1 – A2.6. Garden Village 309 Options 1 before the Dot.Com bubble burst and some of the proposed Society development is now looking unrealistic, especially now that there is a credit crunch. The growth scenarios set an important starting context to the Core See A1.1 and Strategy and it is important in our view that in setting the approach A2.1 – A2.6. to growth the City remain realistic in terms of the City’s potential but equally incorporates some degree of positive aspiration if the economic and social transformations are to be achieved.

178 Pure Urban Options 1 Pure Urban support the approach taken in the Core Strategy which seeks to work towards achieving high levels of growth for the City over the long term thereby endorsing Scenario C, but recognising that as a minimum Scenario B is the more realistic way forward as a first step. It is agreed that a ‘stepped approach’ to delivering development is See A1.1 and the most appropriate way forward. However, East Riding of A2.1 – A2.6. Yorkshire Council considers it prudent to plan on the basis that scenario C may not be deliverable within the timescales of the Core East Riding of 449 Options 1 Strategy (because it is so aspirational). The approach of the Core Yorkshire Council Strategy should therefore provide a step change from Scenario A to B. Scenario C could still be recognised as a ‘longer term’ aspiration and form the content of a future review of the Core Strategy if, through monitoring of the plan, it becomes apparent that Scenario Response to the Hull Core Strategy issues and options report, June 2008 October 2008 64

Company / Section Section City Council ID Your response Organisation number title response B is being achieved.

It is questionable whether the first option (to consider what is needed to move away from Scenario A) is necessary. It is effectively the same as the second option (to deliver Scenario B as the most realistic way forward). In addition, is it the case that the first option is already being addressed through the emerging Area Action Plans and Gateway initiatives?

A major concern with Scenarios B and C is that they fail to address how they relate to the wider sub-region. For example, even with a phased approach to development, demand will continue for residential and business uses (to provide a complementary offer to the city centre) within the Hull Housing Market Area. Development needs will still need to be met within East Riding and RSS places a requirement for approximately 40% of the East Riding’s housing requirement to be within the Hull Housing Market area. This places a significant requirement for East Riding of Yorkshire Council to identify deliverable sites in that area.

In addition, Scenarios B and C would have significant implications on infrastructure capacity in the East Riding (for example to deal with increased commuting levels to the city). This would impact upon the highway network (e.g. capacity issues on the A164) and public transport. It will be very important for the City Council to determine how these constraints will impact upon the Scenarios, how they will be addressed, by whom and how they will be funded? Future Table 4.1. This table needs to reflect a realistic timetable for See A2.1 – A2.6 40 Gateway 4. development Holderness Road Corridor i.e. delivering change much sooner. and A18.1.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 65

Company / Section Section City Council ID Your response Organisation number title response needs Gateway has a fundamental concern about whether we should be proposing possible urban extensions even in the later phases of the plan. There is no consideration of possible alternative options particularly around increasing densities within the existing built form. This would provide increased support for existing services and enable an improved mix of housing, available through a mixture of redevelopment and infill, thus making the City more sustainable. This could be considered over the long term. Discussion needs to take place on the role and timing of any new housing within the Drypool/River Hull Corridor areas relative to the strategic regeneration areas. Table 4.1. Natural England supports the inclusion in Phase 1 of the See A1.1 Future stepped approach, the realisation of “The right amount and quality 96 Natural England 4. development of greenspaces for sport, recreation and amenity value and new needs provision in the NaSA area should be realised. Para 4.4 / Table 4.1. Quay West is expected to be open and trading See A1.1 and before 2015 and should therefore be identified as a priority in A2.1 – A2.6. Phase 1 (2008-2014) alongside the other “priorities” indicated – Future Humber Quays, Fruit Market, East Bank. This timing is well known Henderson 313 4. development to the City Council. Consequent changes to the text under Phase 2 Global Investors needs will also be necessary to reflect the expectation that by 2015 Quay West will be complete and trading. As currently drafted the document appears to include a prioritisation of SDA schemes that defers Quay West which is unacceptable to the promoters. Para 4.6 / Table 4.2. The major non-food shopping floorspace See A1.1 and Future needs to 2014 is given as 13,000 sq m. It should be noted that this A2.1 – A2.6. Henderson 315 4. development figure is excluding commitments such as Quay West and a net Global Investors needs sales area figure. If the figure is intended to include Quay West it would be significantly in error and this representation should then Response to the Hull Core Strategy issues and options report, June 2008 October 2008 66

Company / Section Section City Council ID Your response Organisation number title response be considered as an objection. The formulation in the CCAAP following our representations to that document explained the position. The use of a stepped approach to delivering the plan objectives is See A1.1 and Future Yorkshire supported in principal, however, the plan should also include A2.1 – A2.6. 229 4. development Forward sufficient flexibility to allow development planned for later phases to needs be brought forward, if the market conditions allow. Table 4.2 suggests the development needs over the period to 2026. See A1.1 and In terms of food shopping it is estimated that in the period 2008- A2.1 – A2.6. See 2014 (Phase 1) there is no need and in the period 2015 – 2020 also A36.1. (Phase 2) there is a need of 3,000 sq m between major and local centres. Furthermore, in terms of non-food shopping, it is estimated that in the period 2008 – 2014 major needs of approximately 13,000 sq m and local needs of approximately 17,500 sq m are required. We disagree with these figures, which are based on the Hull Retail and Leisure Study 2006. The figures included within this report significantly underestimate the available retail floorspace and Future Tesco Stores this was illustrated by the retail assessment that accompanied the 308 4. development Limited planning application, which was for the replacement of the Tesco needs store at Beverly Road, Hull.

The Hull Retail and Leisure Study 2006 sets the amount of comparison floorspace within large foodstores to be 15.8%. We would therefore like to point out that modern foodstores generally contain a much higher level of comparison floorspace and therefore the assessment conducted in 2006 would have overestimated the provision of convenience floorspace.

Furthermore, a larger format store may be justified where

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 67

Company / Section Section City Council ID Your response Organisation number title response significant regeneration benefits would be gained by the proposed development and when the increased size is required in order to support the viability of the scheme. Para 4.7. RSPB supports the inclusion of "nature conservation Support Future value of urban green spaces including those along the Humber welcomed. 329 RSPB 4. development estuary, which have to be protected from development by needs international law" as a constraint on development. Future The Highways Agency supports the view expressed in the plan that Support Highways 224 4. development economic proposals being promoted in outlying parts of the city welcomed. Agency needs should be cautioned against. Table 4.2. Suggested development needs to 2026. Evidence base See A1.1 and to underpin this will be critical and will impact on relationship to A2.1 – A2.6. See RSS and conformity with it. For example: also A36.1.

i) It identifies 120ha of employment land. RSS, table 11.3 suggests 90ha 2006-2021. Is the Employment Land Review informing this?

ii) You will need to be clearer about housing supply over the plan Government Future period (see also comments on option 10, below). The document Office for 273 4. development identifies 650 (phase 1), to 1000 (2) to 1300 (3). Is this net or gross Yorkshire and the needs (presumably net)? This appears to suggest 963 pa based on 19 Humber calendar (?) years. You may wish to consider whether to base the figures on financial years (to better fit with the AMR etc) - this would make it 1,016 pa (i.e. over 18 years only). RSS = 880 pa (net) 2008 – 2026, so seems to be quite a bit higher. Is this correct? If so, whilst RSS requirements are not now seen as a ceiling, is it realistic? You will need to consider this in the context of your Housing Implementation Strategy (PPS3 paragraph 62). Is the evidence base robust and up to date, e.g. SHMA? Response to the Hull Core Strategy issues and options report, June 2008 October 2008 68

Company / Section Section City Council ID Your response Organisation number title response

iii) Retail – again, are the numbers quoted informed by an up to date Retail Needs Study? Despite the concerns highlighted above, this chapter (and See A1.1 and particularly table 4.2) is helpful in setting out how the City Council A2.1 – A2.6. Future proposes to realise a stepped approach. Setting out the three East Riding of 450 4. development phases identifies clearly what is expected to happen and by when. Yorkshire Council needs It does raise the question, however, why options are set out in the previous chapter (under Options 1) as chapter 4 identifies that the future pace of change has already been decided. Future Noted. East Riding of Para 4.4. The JSP policy on the sequential approach (principally 451 4. development Yorkshire Council H3) was deleted on the 28 June 2008. needs Future Para 4.5. Given the references in table 4.1 to edge of city urban See A3.1 – A3.2. East Riding of 452 4. development extensions in East Riding it would be helpful for the Key Diagram to Yorkshire Council needs show the extent of the Regional City area. Future See A1.1 and Table 4.2. Gateway supports the stepped approach, but it is 384 Gateway 4. development A2.1 – A2.6. unclear how these new dwelling numbers have been determined. needs Noted, although the concern is one of jobs and Future Para.4.14. Clarity is needed in terms of economic opportunities houses occurring 385 Gateway 4. development moving out of the city, that jobs moving out will in turn consolidate outside the city, needs population drift. potentially fuelling outward migration. See A1.1, A2.1 –

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 69

Company / Section Section City Council ID Your response Organisation number title response A2.6. Table 4.1. Consider the approach – should this cautious timeline be Noted. See A1.1, Future adhered to concerning implementation of City Centre Masterplan? A2.1 – A2.6. 400 Hull Forward 4. development (indicates SDAs ‘almost complete’ in Ph3 2021-26, though CCMP needs targets are only up to 2016. The issue here is maintaining developer confidence. Future Table 4.2. Are the figures for Ph1 also over-cautious? HF has the Noted. See A1.1, 401 Hull Forward 4. development opportunity to increase flow-through of employment land. (Though A2.1 – A2.6. needs recognise the current direction of travel in the economy!). Para. 4.11. References HF will prepare a city-wide action plan to Noted including assemble sites etc to accommodate development needs. To clarify, clarification on Future HF will be working on an action plan for employment land in approach. See 402 Hull Forward 4. development targeted areas – Spatial Strategy should deal with the broader also A1.1, A2.1 – needs picture (development land in general & across the whole city is A2.6. KHCC-led). Noted, although the concern is one of jobs and Para. 4.14. Need info on what the ‘current economic proposals houses occurring Future being promoted in the outlying parts of the city’ are. Agree what the outside the city, 403 Hull Forward 4. development end of this para says, that the focus should not be on the periphery potentially needs of the city until the economy is better able to accommodate this. fuelling outward migration. See A1.1, A2.1 – A2.6. Future We object to the phased approach as set out above on the basis See A2.1 – A2.6. 382 Barratt Homes 4. development that the RSS requires an increase in housing provision in the City to needs 1,200 dwellings per annum from 2008. The phased approach is

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 70

Company / Section Section City Council ID Your response Organisation number title response inconsistent with this requirement. Table 4.2 suggests development needs over the period to 2026. See A2.1 – A2.6. This table states that 650 dwellings will be required in Phase 1 All figures Yorkshire and Future (2008-2014), 1000 dwellings will be required in Phase 2 (2015- outlined are 357 Humber 4. development 2020) and 1300 dwellings will be required in Phase 3 (2021-2026). gross figures. Assembly needs It is unclear if these housing figures are net or gross figures, and the Assembly would wish to seek clarification on this. In order to meet the future growth needs of the City it is our view See A1.1, A2.1 – that the Core Strategy needs to take a flexible approach which A2.6. combines both potential options of maximising vacant and under- used land within the City, particularly previously developed land, but also retain opportunities for the growth of the City through further urban extension.

Objective 180 Pure Urban A phased approach is essential, providing a portfolio of 2 development options and alternative growth points for the city in order to maximise the potential to achieve the high growth levels aspired to.

Growth on the periphery of the city may require co-ordination with East Riding in order to understand the most appropriate locations to accommodate growth. Government See A4.1. Office for Objective 274 Objective 2 is too generic (see further below). Yorkshire and the 2 Humber Objective Balancing the uses in a way that promotes environmental and See A1.1, A2.1 – 412 Hull Forward 2 economic sustainability is critical. A2.6.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 71

Company / Section Section City Council ID Your response Organisation number title response In terms of providing land for housing development we consider See A1.1, A2.1 – that a mixed approach of both of the above options is necessary to A2.6. ensure that the level of development is enabled to meet RSS requirements. In accordance with national planning policy, we consider that the Council should support an approach which makes the best use of vacant, underused, previously developed and previously allocated land to enable future development. However, it should be accepted at the outset that the development of vacant, underused and previously developed land, when coupled with the implementation of existing planning permissions, will not achieve the required annual step change in housing delivery in Hull. There will be a need to consider options for the development of urban extensions as part of a delivery strategy.

In the context of greenfield urban extensions, the expansion of the 36 Barratt Homes Options 2 City’s edges into the East Riding of Yorkshire would indeed alleviate the existing land supply constraints of the City. In order for this approach to be considered viable, and thus be attributed realistic merit, it would require buy in from the East Riding of Yorkshire Council and would need to be incorporated within the current housing reviews being undertaken on a regional level by the Government Office for Yorkshire and The Humber and at the local level by LPA’s through the preparation of Strategic Housing Market Assessments (SHMA).

One further potential means of delivering a proportion of the required additional land for housing development in the City is through the redevelopment of some of the City’s urban greenspace and redundant recreational facilities. We make further representations on this point in relation to Options 18 & 20 of the Response to the Hull Core Strategy issues and options report, June 2008 October 2008 72

Company / Section Section City Council ID Your response Organisation number title response Core Strategy Issues and Options DPD. Strong emphasis should be placed on Option 2.1, at least in the See A1.1, A2.1 – medium term. Very considerable opportunities exist within Hull on A2.6. vacant, underused and previously developed land. The consolidation of development on such sites should be strongly encouraged. It is acknowledged that many of these sites present development challenges, but the Core Strategy must work to ensure that everything is done to bring them forward.

Wildmoor (Hull) 69 Options 2 The alternative is a more dispersed pattern of development in the Ltd. early phases of the plan. This is unsustainable, will not contribute to the regeneration of Hull's deprived areas, and may well also serve to divert investment to such an extent that brown field sites within the existing urban area remain as a wasted resource for the foreseeable future.

Option 2.2 should only be considered in the long term once Option 2.1 has been fully pursued. We object to the phased approach as set out above on the basis See A1.1, A2.1 – that the RSS requires an increase in housing provision in the City to A2.6. 1,200 dwellings per annum from 2008. The phased approach is inconsistent with this requirement.

73 Kayterm Ltd Options 2 In terms of providing land for housing development we consider that a mixed approach of both of the above options is necessary to ensure that the level of development is enabled to meet RSS requirements. In accordance with national planning policy, we consider that the Council should support an approach which makes the best use of vacant, underused, previously developed and

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 73

Company / Section Section City Council ID Your response Organisation number title response previously allocated land to enable future development. However, it should be accepted at the outset that the development of vacant, underused and previously developed land, when coupled with the implementation of existing planning permissions, will not achieve the required annual step change in housing delivery in Hull. There will be a need to consider options for the development of urban extensions as part of a delivery strategy.

In the context of greenfield urban extensions, the expansion of the City’s edges into the East Riding of Yorkshire would indeed alleviate the existing land supply constraints of the City. In order for this approach to be considered viable, and thus be attributed realistic merit, it would require “buy in” from the East Riding of Yorkshire Council. This also needs to be incorporated within the current housing review of the RSS for Yorkshire and the Humber and at the local level by LPA’s through the preparation of Strategic Housing Market Assessments (SHMA). Option 2.1. Natural England supports Objective 2 (option 1) as is See A1.1, A2.1 – the most sustainable means of development for the city. This option A2.6.

94 Natural England Options 2 does need to take into consideration the environmental designations and sites that surround the city to protect and enhance them as part of any future development. Strong emphasis should be placed on Option 2.1, at least in the See A1.1, A2.1 – medium term. Very considerable opportunities exist within Hull on A2.6. vacant, underused and previously developed land. The Dransfield 130 Options 2 consolidation of development on such sites should be strongly Properties Ltd encouraged. It is acknowledged that many of these sites present development challenges, but the Core Strategy must work to ensure that everything is done to bring them forward.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 74

Company / Section Section City Council ID Your response Organisation number title response

The alternative is a more dispersed pattern of development in the early phases of the plan. This is unsustainable, will not contribute to the regeneration of Hull's deprived areas, and may well also serve to divert investment to such an extent that brownfield sites within the existing urban area remain as a wasted resource for the foreseeable future.

Option 2.2 should only be considerable in the long term once Option 2.1 has been fully pursued. We object to the phased approach as set out above on the basis See A1.1, A2.1 – that the RSS requires an increase in housing provision in the City to A2.6. 1,200 dwellings per annum from 2008. The phased approach is inconsistent with this requirement.

In terms of providing land for housing development we consider that a mixed approach of both of the above options is necessary to ensure that the level of development is enabled to meet RSS Kingswood Parks requirements. In accordance with national planning policy, we

97 Development Options 2 consider that the Council should support an approach which makes Company the best use of vacant, underused, previously developed and previously allocated land to enable future development. However, it should be accepted at the outset that the development of vacant, underused and previously developed land, when coupled with the implementation of existing planning permissions, will not achieve the required annual step change in housing delivery in Hull. There will be a need to consider options for the development of urban extensions as part of a delivery strategy.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 75

Company / Section Section City Council ID Your response Organisation number title response If urban greenspace is to be safeguarded, there are four readily available options to increase housing provision at Kingswood including:

• permitting an increase in housing delivery rates through condition (iv) of the Kingswood outline planning permission;

• reallocation of part of the employment land to housing;

• the relocation of overhead lines from Kingswood Parks to increase the developable areas; and

• allocating land to the north of Kingswood as a future urban extension. WLL has no objection to option 2, a balanced approach to meeting See A1.1, A2.1 – the City's future development needs. However, this should be A2.6. implemented cognisant of the overarching requirement to ensure sufficient land is made available, at the appropriate time, to deliver the Core Strategy growth strategy.

Whilst the emerging Core Strategy currently identifies circa 120 Wrenbridge Land 143 Options 2 hectares of land to be identified across the plan period WLL Limited consider there could be a requirement to increase this allocation figure in line with the higher job creation targets in RSS. This will ensure that sufficient land is made available for economic development purposes as required to facilitate an urban transformation of the City (see table 11.3).

Within the employment land strategy it is considered appropriate

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 76

Company / Section Section City Council ID Your response Organisation number title response that development seeks to make the best use of vacant, underused and previously developed land in the City, consolidating uses and activity as appropriate.

Where sites are available and suitable to accommodate development, without constraints, this should be facilitated through a flexible development plan enabling early release providing developer certainty and employment opportunities.

This approach accords with the Government's emerging guidance as provided in the Consultation Paper on a new Planning Policy Statement 4 ("PPS4"): Planning for Sustainable Economic Development. The emerging PPS4 seeks to ensure a positive proactive framework for economic development is achieved where the needs of businesses are recognised and proposals should be considered favourably. Para. 4:18: This assumes that ERYC is in agreement with "urban Noted. Friends of 231 Options 2 extensions," and that it wants to work with HCC. The opposite has Pearson Park often proved true. RSPB supports option 1 but believes that the LDF should also See A27.1 recognise that the biodiversity value of previously developed sites can be high. Paragraph 15 of PPS9 states that "where such sites have significant biodiversity or geological interest of recognised local importance, local planning authorities, together with 330 RSPB Options 2 developers, should aim to retain this interest or incorporate it into any development of the site". We believe that all developments on brownfield land should be evaluated for their biodiversity potential, and where this is of local or greater importance a design scheme incorporating this into the development should be adopted.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 77

Company / Section Section City Council ID Your response Organisation number title response ABP supports Option 1: To make the best use of vacant, Support underused, and previously developed land within the city in welcomed. consolidating uses and activity including completing sites which already have planning permission.

National and regional planning policy states that Local Authorities should make the most efficient and effective use of land through the use of previously developed land. More specifically, Policy YH7 of the Regional Spatial Strategy (May 2008) (RSS) states the following: “…local planning authorities should allocate sites by giving: 1. First priority to the re-use of previously developed land and buildings and the more effective se of existing developed areas within the relevant city or town….” Associated 258 Options 2 British Ports The RSS also states that across the Region, local authorities should aim to achieve a target of 65% of development on previously developed land. ABP considers that priority should therefore be given in the Core Strategy to the use of previously developed land, particularly in central locations, where this has the potential to reduce transport use and create sustainable travel patterns. Policy YH2 of the RSS also states that development on previously developed land should be encouraged, to assist in reducing impacts on climate change and resource use.

Further to the above, as the city’s boundary is tight to the built-up See A30.1 area, the reuse and recycling of previously development land should be maximised. This will help to protect valuable greenfield sites, and other areas of open space within the city.

199 Local resident Options 2 It is obviously preferable to use vacant, underused, or previously See A30.1 and Response to the Hull Core Strategy issues and options report, June 2008 October 2008 78

Company / Section Section City Council ID Your response Organisation number title response developed land. Mention of expanding the City outwards points up A2.1 – A2.6 a basic problem of planning for Hull: it is hemmed in by suburbs jealous of their status. The outward expansion of Option 2 is not realistic. Government Options 2 refers to urban extensions. How realistic an option is See A30.1 and Office for this? Presumably only needed in phase 3, if then. Where are these A2.1 – A2.6 276 Options 2 Yorkshire and the locations potentially envisaged, given would need to be in city Humber boundary – is there a need for site specific allocations in the CS? The two options set out in Options 2 are not mutually exclusive. It is See A2.1 – A2.6 also a concern that they may not be meaningful options for a consultation document as they replicate National and Regional planning guidance which promote both options in a sequential order (i.e. sites within urban areas to be the preference for development before urban extensions).

East Riding of Yorkshire Council has significant concerns over the reference in phase 3 (2021 – 2026) that ‘edge of city urban extensions are under discussion with East Riding of Yorkshire East Riding of 453 Options 2 towards the end of the plan period’. It is inappropriate to suggest Yorkshire Council this as a preferred approach without any discussion with the Council. It is therefore not possible to show how this ‘preferred option’ is deliverable.

Furthermore, the actual meaning of the sentence is unclear. Is the City Council expecting East Riding to allocate sites in the East Riding LDF to help meet Hull’s 1,300 completions per year target in phase 3? Or is the City Council expecting East Riding to delay the release of its allocated sites in the settlements surrounding Hull until 2021? If the former is the case, this is a matter to be

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 79

Company / Section Section City Council ID Your response Organisation number title response considered through the Regional Spatial Strategy and its distribution of housing numbers to individual local authorities. It is not something that can be considered through either Local Development Framework.

In any event, it is incorrect to suggest that these sites will be under discussion in 2021. Clearly any allocations will need to be set out in either the East Riding Core Strategy (if strategic) or Allocations DPD which will provide the planning framework to 2026. If the City Council has identified a potential need for urban extensions within the East Riding these should be under discussion now to fit into the preparation of these documents. East Riding would welcome the opportunity to discuss this further. Preference for (1) but specifically focusing on identified target See A1.1 and development areas. Agree with the principle of a stepped approach, A2.1 – A2.6. but consider a more aspirational pace of change by accelerating

404 Hull Forward Options 2 the timescales, particularly to achieve CCMP targets.

Para 4.18 – essential to have effective joint working in place See A3.1 – A3.2 between the 2 authorities, as above. and A7.1 – A7.2 Para 5.4. Noted.

RSPB is pleased that you have identified the requirement for a Strategic Habitats Regulations Assessment and suggests that this is issues, options 331 RSPB 5. undertaken the Preferred Options of the Core Strategy, as this will and suggested allow any changes needed to prevent adverse effects on the preferred option SPA/SAC/Ramsar site in advance of the submission stage. Designated sites within the Local Authority that need to be included are:

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 80

Company / Section Section City Council ID Your response Organisation number title response

Humber Estuary SSSI

Humber Estuary SPA

Humber Estuary SAC

Humber Estuary Ramsar site

Natural England's Nature on the Map (http://www.natureonthemap.org.uk/) provides an excellent resource to learn where designated sites are in relation to particular locations. We support the objective of stabilising Hull’s population through a Support broad range of regeneration initiatives, which will improve the welcomed. Yorkshire Broad, guiding 236 A. attractiveness of the city to residents and businesses, by improving: Forward principles educational facilities; health facilities; and the quality and mix of housing on offer within the city. It is all very generic, i.e. could relate to anywhere, especially the See A4.1. objectives. The objectives need to be more precise, more specific and more localised – SMART. This should also allow them to be cut down considerably. Government

Office for Broad, guiding 278 A. For example, Objective 3, p.45, not unlike Objective 2, is far too Yorkshire and the principles general, possibly superfluous to the CS. Whilst delivery of Humber Sustainable Development is at the heart of the planning system, a requirement of national policy and therefore the main guiding principle for all DPDs, is it necessary to have specific objectives dedicated to it? In essence if you can demonstrate that

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 81

Company / Section Section City Council ID Your response Organisation number title response sustainability is underpinning the whole CS, specific generic objectives requiring development to be sustainable would appear to add little of value.

Options - often all appear to be desirable or necessary, i.e. it is See A3.1 – A3.2 difficult to disagree with or pick one out as opposed to others. and A5.1 – A5.2. Shown by the fact that the preferred approach is nearly always ‘a combination of these…’. (This seems to apply throughout the document). How much real choice is actually being proposed? Especially as a preferred approach is already being identified.

Performance Indicators proposed - how is it envisaged these will be See A12.1 used? Will these be cross-referred to policy measures and indicators? Or will there be policies to deliver all these broad, guiding principles? They will still need to be area specific.

Following on from that, you will need to think about the structure of See A6.1 the document generally. What is the purpose of this section? Not background/context presumably (that is section 2) – yet a lot of the material in it consists of this. Is it going to be policy-based, i.e. higher level ‘key’ or ‘core’ policies? Or forming part of the spatial strategy? A3 page 44 Fully sustainable buildings and environments can only See A46.1 be achieved by designing to the principles of inclusive design, as Hull Access without it, the development will not be used by those in society who Sustainable 13 Improvement cannot access it because the design excludes them. Inclusive development Group design should look at everyone in society. Equality and human rights legislation requires everyone to consider all in society. High profile recent developments have failed to meet the needs of all

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 82

Company / Section Section City Council ID Your response Organisation number title response and expensive adaptations will be required and even then may not be satisfactory. Function over form is the key. Page 44, para.A.3. This definition of sustainable development, Noted. See also insofar as it relates to the environment, misinterprets PPS1. A16.1 Paragraph 4 of PPS1 uses the phrase “effective protection of the environment” - which clearly includes all environmental assets.

As currently worded, the second bullet-point of Paragraph A.3 only relates to the natural environment. In order to deliver sustainable development, it is essential that the strategy for the City balances English Heritage economic prosperity and social progress with protection of all the Sustainable 159 Yorkshire and city’s considerable environmental assets – this includes its wealth development Humber Region of historic buildings and areas. Indeed, the Government has long recognised that the concept of sustainability has a particular relevance for the historic environment since the historic environment is, by its very nature, irreplaceable.

Page 44, para.A.4. In view of the above comments, reference should also be made to the role the planning system can play in protecting and enhancing the City’s historic assets (along the lines advocated in the third bullet point of PPS1, Paragraph 5). It would be beneficial if the Core Strategy used a more up-to-date Noted. See also definition of sustainable development; we consider that it should A12.1 refer to the UK Sustainable Development Strategy and the Yorkshire Sustainable principles it sets out. Objective 3 (becoming a more sustainable 237 Forward development city) is to be welcomed, however, it would beneficial if the objective included additional explanatory text defining what is meant by a sustainable city.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 83

Company / Section Section City Council ID Your response Organisation number title response We support the concept of promoting new development which has a reduced carbon footprint, as outlined in Objective 6. However, we feel that this objective would be more meaningful if it included a baseline against which to judge new development. Paragraph A.4 sets out the suggested aims of the planning system, Agreed and in order for it to contribute towards sustainable development. We changes will be consider that the second to last bullet point should be amended to made to the next incorporate reference to energy efficiency, so that it would read draft. ‘reduce air pollution and congestion by encouraging renewable energy, energy efficiency and low-carbon building practices’.

Further to this, we consider that the last bullet point should also be See A19.1. Tesco Stores Sustainable 310 amended to read ‘help reduce the use of finite resources through Limited development encouraging renewable energy, energy efficiency and low carbon building practices’.

Overall, energy reduction can be achieved in many different ways and energy efficiency measures included within a development scheme can have significant benefits, which in many cases can outweigh potential carbon reduction gained through the inclusion of renewable energy sources. The performance of the preferred option should also be measured See A12.1 Sustainable 333 RSPB by monitoring biodiversity change, e.g. loss or creation of priority development habitats through the development control process. page 45, para. A.4. The Highways Agency suggests that it may be See A14.1 useful to emphasise reducing the need to travel in the sustainable Highways Sustainable 225 development section, a suggested rewording of A4 bullet point 6: Agency development

"Reduce air pollution and congestion by encouraging developments Response to the Hull Core Strategy issues and options report, June 2008 October 2008 84

Company / Section Section City Council ID Your response Organisation number title response to be well connected to public transport and cycle networks and located within sustainable locations reducing the need to travel." English Heritage If it is made clear that the definition of sustainable development This definition Objective 160 Yorkshire and used within the Plan also encompasses the historic environment, will be clarified. 3 Humber Region we support this objective. See also A16.1. Natural England welcomes the Principles and suggested Preferred This definition Option Objective 3 (Option 3 – (1) page 45, and the key will be clarified. measurements for these. However, sustainability themes should be See also A16.1. Objective more strongly embedded throughout the Core Strategy. For 98 Natural England 3 example, it does not clearly demonstrate how the sustainable use and future protection of a healthy natural environment are incorporated within the various policy areas of the document. This requires further work. We support the bullet points at this item but suggest that Objective Support 3 be made more robust. The objective needs to take account of the welcomed. protection, refurbishment, replacement and maintenance of existing The Theatres Objective 184 community facilities across all scales of activity relative to the list at Trust 3 A.11 as The Theatres Trust wishes to be assured that the Local Development Documents are robust enough to include specific guidance on protecting and encouraging arts and cultural provision. Option 2 ought to be preferred, but pragmatically, one would accept Noted. Local resident Objective 200 Option 1; Option 3 is what caused our present problems, and 3 should be rejected. A9 page 46 The code for sustainable homes should include that all See A25.1 Hull Access (100%) homes are built to the life-time homes standard as set down

14 Improvement Options 3 by the Joseph Rowntree Housing Trust and that a percentage Group should be wheelchair accessible homes. Life-time homes standard should be included in this section to ensure monitoring of the need

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 85

Company / Section Section City Council ID Your response Organisation number title response from the start not in years to come. Options 3 relate to sustainable development, weighing whether See A25.1 environmental and social factors should take precedence over economic development, vice versa, or whether they should be given equal weight.

The positive development of Economic, Social and Environmental factors are all incorporated within Sustainable development principles. Consequently, we support Option 3 (1) as this option gives equal weight to environmental, social and economic development.

In the Hull context, sustainable development is about the delivery of development, particularly in respect of housing. If housing is not delivered it leads to unsustainable consequences in form of long 41 Barratt Homes Options 3 distance commuting, social exclusion (as the more prosperous move out of Hull to obtain their housing needs) and continued low house prices. Thus, priority should be given to ensuring the delivery of development and ensuring that micro-sustainability policies such as ‘renewables’ do not undermine or restrict the wider objectives of achieving sustainable development. In practice, some of the measures referred to in paragraph A.9; as measures which will assess performance against sustainability aspirations (including Code for Sustainable Homes, on-site renewables and development on previously-developed land) can be measures that can undermine the viability of new development schemes. The Council need to ensure that the additional burden that such requirements bring do not make Hull uncompetitive as a location for development.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 86

Company / Section Section City Council ID Your response Organisation number title response We would support Option 1 as being the preferred option as long as Noted. Hull Access it is made clear that 'social' means fully inclusive and takes account 49 Improvement Options 3 in particular of the three target groups identified in One Hull's Group Community Strategy. The preferred option should be a combination of Option 3.1 and Noted. Option 3.3. It is important in the first instance to consider environmental, social and economic factors when assessing Wildmoor (Hull) sustainability. However, when these matters are finely balanced 70 Options 3 Ltd. following such an assessment, primacy should be given to economic factors in Hull, where the economy faces considerable challenges and constraints must be minimised if progress is to be made. Options 3 relate to sustainable development, weighing whether Noted. See also environmental and social factors should take precedence over A25.1. economic development, vice versa, or whether they should be given equal weight.

The positive development of Economic, Social and Environmental factors are all incorporated within Sustainable development principles. Consequently, we support Option 3 (1) as it gives equal

74 Kayterm Ltd Options 3 weight to environmental, social and economic development.

In the Hull context, sustainable development is about the delivery of development, particularly in respect of housing. If housing is not delivered it leads to unsustainable consequences in the form of long distance commuting, social exclusion (as the more prosperous move out of Hull to obtain their housing needs) and continued low house prices. Therefore, priority should be given to the delivery of development and ensuring that micro-sustainability policies such as

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 87

Company / Section Section City Council ID Your response Organisation number title response ‘renewables’ do not undermine or restrict the wider objectives of achieving sustainable development.

In practice, some of the measures referred to in paragraph A.9; as measures which will assess performance against sustainability aspirations (including Code for Sustainable Homes, on-site renewables and development on previously-developed land) can be measures that can undermine the viability of new development schemes. The Council need to ensure that the additional burden that such requirements bring do not make Hull uncompetitive as a location for development. We would broadly endorse the choice of Option 1 as the preferred Noted. option (i.e. where the Plan seeks to balance economic, social and English Heritage environmental factors when assessing development proposals).

161 Yorkshire and Options 3 Humber Region However, it should be made clear that the degree of weight which will be given to each factor will be dependent upon the significance of the particular factor relative to the others. The preferred option should be a combination of Option 3.1 and Noted. Option 3.3. It is important in the first instance to consider environmental, social and economic factors when assessing Dransfield sustainability. However, when these matters are finely balanced 131 Options 3 Properties Ltd following such an assessment, primacy should be given to economic factors in Hull, where the economy faces considerable challenges and constraints must be minimised if progress is to be made. Kingswood Parks Options 3 relate to sustainable development, weighing whether Noted. See also

99 Development Options 3 sustainable development should take precedence over economic A25.1. Company development, vice versa, or whether they should be given equal Response to the Hull Core Strategy issues and options report, June 2008 October 2008 88

Company / Section Section City Council ID Your response Organisation number title response weight.

There should be no need to distinguish between sustainable development and economic development as the latter forms part of the former. In the Hull context, sustainable development is about the delivery of development, particularly in respect of housing. If housing is not delivered it leads to unsustainable consequences in form of long distance commuting, social exclusion (as the more prosperous move out of Hull to obtain their housing needs) and continued low house prices. Thus, priority should be given to ensuring the delivery of development and ensuring that micro- sustainability policies such as ‘renewables’ do not undermine or restrict the wider objectives of achieving sustainable development. In practice, some of the measures referred to in paragraph A.9, as measures which will assess performance against sustainability aspirations (including Code for Sustainable Homes, onsite renewables and development on previously-developed land) can be measures that can undermine the viability of new development schemes. The Council need to ensure that the additional burden such requirements bring do not make Hull uncompetitive as a location for development. WLL fuIly recognise the importance of sustainable forms of Noted. See also development in accordance with national and regional policy, both A25.1. of which establish the principle of sustainable development. Wrenbridge Land 144 Options 3 Limited However, in accordance with the wider development strategy for Hull, it is important economic factors are recognised as the main driver of change (option 3 (3)) cognisant principles of sustainable development. This approach accords with the emerging PPS4

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 89

Company / Section Section City Council ID Your response Organisation number title response which states that regional planning bodies and local planning authorities should plan positively and proactively to encourage economic development in line with the principles of sustainable development (page 6).

Through delivering a successful economy, increasing educational attainment and reducing deprivation, WLL considers there will be a corresponding beneficial impact for society and the environment more widely. The environment should take precedence because if issues like Noted. climate change are not ameliorated then the rest won't matter. Friends of Environment should be followed by economic factors and finally 233 Options 3 Pearson Park social, which in Hull seems to be difficult. However, if the economic situation improves, then social changes may (note "may") take place. RSPB supports the preferred option to balance the environment, Support social and economic factors when assessing development welcomed. See proposals (option 1). However, we note that the Habitats also A16.1 and Regulations provide a very high level of protection for Natura 2000 A15.1. sites. Any plans or projects that could adversely affect the integrity

332 RSPB Options 3 of a Natura 2000 site would need to demonstrate Imperative Reasons of Overriding Public Interest (IROPI) - i.e. overriding the objectives of the EU Habitats Directive - and the ability to fully compensate for any damage caused. Therefore, in the majority of such cases the balance would weigh heavily in favour of environmental factors. Yorkshire Water supports Option 1 to give environmental, social Support Yorkshire Water 253 Options 3 and economic factors equal waiting to ensure new development is welcomed. Plc progressed in a sustainable manner. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 90

Company / Section Section City Council ID Your response Organisation number title response Hull & Humber We agree that environmental, Social and Economic factors should Support

299 Chamber of Options 3 all be given weight when assessing sustainability, but it may be too welcomed. Commerce simplistic to say that they should be given equal weight. An option is provided for environmental or economic factors taking See A5.1 – A5.2. precedence. However, no option is provided for social factors taking precedence. It is doubtful whether these options are realistic as giving any factor overall precedence would go against the aims East Riding of and objectives of sustainable development. 454 Options 3 Yorkshire Council Unless Option 1 was chosen there would be a conflict with objective 2 which proposes to meet the city’s future development needs by balancing uses for economic, housing, social and environmental purposes.

405 Hull Forward Options 3 (1) is the only option, in the spirit of the definition of sustainability. Noted.

A11 page 47 Bullet point 6 “are all accessible” is too vague it Noted. should be more specific, possible rewording to include designed for inclusion and will be accessible to all. Access to some just means car parking or a ramp, the use of the term 'accessible’ requires more explanation.

Hull Access Sustainable A12 page 47 quote 'even after people’s life circumstances change' Noted. 15 Improvement communities Life-time homes when well designed and built take into Group consideration the needs for houses to adapt easily and cheaply to changing circumstances. It is important to consider a person’s aspirations as well as their present needs. The reason some have moved from the city is because they could not realise their aspirations here due to lack of space for the improved life style they would like. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 91

Company / Section Section City Council ID Your response Organisation number title response

A13. Do you know how many people consider themselves to have We do not have a disability in the city? Do you know how many wheelchair users detailed there are in the city? Do you know how many adapted properties information of are in the city? Do you know how many people are living in this nature to properties that do not meet their physical/mobility needs? HAIG do enable more not consider it possible to fully plan for the future of the cities effective inhabitants without this information. planning. Natural England believes that all communities should have access Noted. See also to good quality greenspace, play provision and the natural A16.1. environment close to where people live both at a local level and through green infrastructure corridors to enhance the quality of life. Natural England believes that local authorities should consider the provision of natural areas as part of a balanced policy to ensure that local communities have access to an appropriate mix of greenspaces providing for a range of recreational needs. As a benchmark, Natural England uses the Accessible Natural Greenspace Standards Model (ANGST), which recommends that: Sustainable 100 Natural England communities • No person should live more than 300m from their nearest area of natural greenspace of at least 2ha in size

• There should be 1 accessible site of 20ha within 2km of home

• There should be 1 accessible 100 ha site within 5km of home

• There should be 1 accessible site of 500 ha within 10km of home

Suggest that need to include reference to ANGSt in paragraphs:

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 92

Company / Section Section City Council ID Your response Organisation number title response

A.11. p46 and A19 green space in the city for measuring performance p. 49 Sustainable Communities, A.27. p53, Healthy living B113 p 109, B.115, p110, Health care provision B119 p 111. Paragraph A.11 sets out what is required in order to create Noted. Tesco Stores Sustainable sustainable communities. We consider that the third bullet point 312 Limited communities should be amended to read ‘include quality local shopping and community facilities, located near the populations that they serve’. Para. A.11. Existing local leisure and cultural facilities should have Noted. a policy for their protection and enhancement, with provision for new or improved facilities made to ensure the health and well-being of the population. New developments, such as mixed use areas and urban extensions, should include plans for local multi-purpose community facilities for cultural and leisure activities to ensure the population have the capacity to reap the health and social benefits which accrue from participation in regular cultural and leisure The Theatres Sustainable pursuits. 187 Trust communities In recent years, there has been growing recognition that a vibrant cultural life is a necessary ingredient of sustainable communities. Cultural activities contribute to a distinctive local identity, stimulate pride and a sense of belonging, and support individual well-being and enjoyment. Culture has an intrinsic value to both communities and visitors, bringing people together in shared experience, strengthening community bonds and making a major contribution to the quality of life. Hull Access Sustainable communities are about the freedom for a disabled Noted. Objective 16 Improvement person to be a full part of their community this means being able to 4 Group visit neighbours and family as well as use the local amenities. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 93

Company / Section Section City Council ID Your response Organisation number title response We consider that none of these options is specific enough. In Noted. meeting the objective to stabilise and grow the economy, we consider the preferred options will need to be more specific than those set out under ‘Options 4’. In particular, we consider that focus should be given to building houses in communities within Hull where people want to live. It is also important to build the right type 33 Barratt Homes Options 4 of housing.

We consider that if the Council wish to meet objective 4, there should be a specific focus on channelling development to locations favoured by residents. Accordingly, we consider that future revisions of the Core Strategy should acknowledge this. We consider that none of these options is specific enough. In Noted. meeting the objective to stabilise and grow the economy, we consider the preferred options will need to be more specific than those set out under ‘Options 4’. In particular, we consider that focus should be given to building houses in communities within Hull where people want to live. It is also important to build the right type 75 Kayterm Ltd Options 4 of housing.

We consider that if the Council wish to meet objective 4, there should be a specific focus on channelling development to locations favoured by residents. Accordingly, we consider that future revisions of the Core Strategy should acknowledge this. Generally, objective 4 and a combination of the three options is Support supported. However, additionally, in seeking to create and maintain welcomed. Dransfield 132 Options 4 sustainable communities, much greater emphasis should be placed Properties Ltd on planning positively for the growth and expansion of centres, in line with the policy position established by PPS6, and indeed the

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 94

Company / Section Section City Council ID Your response Organisation number title response direction of travel indicated by draft changes to PPS6. These themes should be incorporated into the preferred option. We consider that none of these options are specific enough. In Noted. See also meeting the objective to stabilise and grow the economy, we A2.1 – A2.6. consider the preferred options will need to be more specific than those set out under ‘Options 4’. In particular, we consider that focus should be given to building houses in communities within Hull where people want to live. It is also important to build the right type Kingswood Parks of housing. The Kingswood development has shown that quality

103 Development Options 4 housing provided in a quality environment can be successful in Company keeping people within the City.

We consider that if the Council wish to meet objective 4, there should be a specific focus on channelling development to locations favoured by residents. Accordingly, we consider that the Preferred Option should acknowledge this, in committing to build more homes at Kingswood, so as to meet Objective 4 in a specific manner. In seeking to create and maintain sustainable communities, and Support attract major investment into Hull, WLL support the Council in their welcomed. recognition that a combination of the following three broad options should guide development:

Wrenbridge Land 1. ensure economic development is planned so that it occurs in the 145 Options 4 Limited right places at the right time;

2. attract major investment to Hull; and

3. encourage employment within commuting distance of the city to broaden job opportunities for residents of the city.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 95

Company / Section Section City Council ID Your response Organisation number title response The second option is attracting major investment, but with no Noted. See also Friends of indication of how this would be accomplished. Investment in Hull A2.1 – A2.6. 235 Options 4 Pearson Park will be difficult to come by if the crime and education figures are not improved, as families will be reluctant to relocate here. ABP supports Option 2: Attract major investment in Hull, including Support to option the cite centre, shopping / other centres, the port, and other key 4.2 is welcomed. growth clusters depending on the nature of the location.

RSS Policy YH7 states that priority should be given to development within towns and cities, particularly in locations that make the best use of existing transport infrastructure and capacity, and maximise the use of rail and water for freight generating movements.

Planning Policy Statement 1 Delivering Sustainable Development (PPS1) states that developments that may attract large numbers of people should be located in existing centres to promote their Associated 261 Options 4 viability and vitality, social inclusion and sustainable patterns of British Ports development. Further to this PPS1 states that: “Planning should actively manage patterns of urban growth to make the fullest use of public transport and focus development in existing centres and near to major public transport interchanges”.

ABP considers that the majority of new development should be located within existing centres, particularly within the City Centre and around the Port of Hull. Locating development in these areas will assist in the creation of sustainable communities, by locating development in areas that are accessible by the majority of the population, on foot, cycle, or public transport, allowing them to access to a range of services and facilities, and reducing reliance

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 96

Company / Section Section City Council ID Your response Organisation number title response on private transport. Option 3 is incompatible with A41 and ruled out by 4.14, because of Noted. 201 Local resident Options 4 the risk of economic displacement draining the City. The Highways Agency has concerns about option 3 to achieve See A17.1 objective 4. Namely the option to: “Encourage employment opportunities within commuting distance of the city to broaden job opportunities for city residents, especially along the A63 corridor, providing these opportunities complement those sought in Hull.”

Policies that locate development (particularly B1 office use) in the vicinity of the SRN, in this case the A63, could be a concern to the Highways Agency as they may result in additional traffic impact on sections of the network that already suffer from high peak period commuter traffic demands and congestion. As part of the section on Highways the transport system and getting about the Highways Agency feels 226 Options 4 Agency there is potential to emphasise here the importance and effectiveness of Travel Plans and their ability to influence people’s travel behaviour. The Highways Agency is currently working on a standard statement for inclusion in other LDDs, which we feel should be included within your documents, I will forward this statement to you in due course.

The Highways Agency would like to see sustainable transport initiatives included in the section on infrastructure and development funding. This will include smarter choices initiatives outside the scope of what is already included in the list including travel plans etc. East Riding of The third option relates to employment development within East Noted. 455 Options 4 Yorkshire Council Riding. East Riding of Yorkshire Council supports the proposal to Response to the Hull Core Strategy issues and options report, June 2008 October 2008 97

Company / Section Section City Council ID Your response Organisation number title response encourage employment opportunities within commuting distance of the city, especially along the A63 corridor. It is unclear however how the City Council intends to encourage employment development beyond its boundary and how the commuting distance will be defined (for example does it mean Hull’s travel to work area?).

If Options 3 is to be included in the preferred approach, East Riding of Yorkshire Council will need to be referenced in terms of both measuring performance and as a key delivery agent. Agree a combination seems appropriate, with priority to targeting Support major employment/ trip-generating development to the city centre welcomed. 406 Hull Forward Options 4 and other key employment areas, and other development to other district/local centres in accordance with the development hierarchy. Para A27. Area action plans are now being prepared long after Noted. See also some of the new builds are completed. HAIG is very concerned that A18.1 and A46.1 the completed properties do not meet 'Life-time homes standard' we are unsure if all of them meet current building regulations, they are in no way sustainable and little consideration seems to have been given to the needs of people with disabilities. These action Hull Access plans need to fully take account of the needs of all residents of the Regeneration 17 Improvement city. priorities Group “improved street design so they are pedestrian friendly”. This statement is meaningless it requires considerable clarification. Recent designs have included 'shared spaces and home zones' while these may work if well designed they are not a catch all, HAIG has grave concerns about the street layouts and how friendly it is for those with visual impairments or deaf.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 98

Company / Section Section City Council ID Your response Organisation number title response

While we approve of “better lighting” this again requires more thought as inappropriately placed lighting can be an issue for visually impaired people. HAIG is well aware of the Disability Equality Duties of 2005. The Local Authority needs to comply with their duties or they run the risk of a claim being made against them. HAIG has heard from members of the public about the dangers they face on a day to day basis. It is only a matter of time before a serious accident will happen, if this was to result in death or serious injury a considerable claim for compensation could be made. City council should also be aware of the increased costs associated with rectifying the poor street design. Para. A.27. It is agreed the Newington St Andrews area ("NASA") Support should be an initial primary focus for regeneration given current welcomed. levels of deprivation within the City and specifically that area.

In delivering regeneration WLL support the Core Strategy's recognition of the private sector's role, whereby developers will be actively engaged in delivering the regeneration priorities, including those of NASA. In this regard we look forward to working closely Wrenbridge Land Regeneration 146 with the Council. Limited priorities

Within the NASA area WLL recognise and consider there is potential for, inter alia:

– new business measures to improve access to jobs;

– environmental improvements;

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 99

Company / Section Section City Council ID Your response Organisation number title response – new community facilities; and

– potential additional shopping facilities.

As paragraph A27 of the emerging Core Strategy recognises the precise form of future investment and development will be guided through the Area Action Plan and this is a specific policy area WLL will seek to engage with. Friends of Regeneration Para. A.27. Improving shopping facilities including adding tree Support 240 Pearson Park priorities planting is supported. welcomed We consider that Paragraph A.27 (Page 53), bullet point 7, requires Noted. See also qualifying as ’large scale food retailing’ is not defined. Furthermore, A36.1 – A36.2. as aforementioned in relation to table 4.2, we believe a case for further retail provision could be established. We consider that in some cases the provision of a supermarket within a Large/Important Local Centre could be justified, based on the identification of a site specific catchment and detailed analysis relevant to this catchment.

Tesco Stores Regeneration 314 Paragraph A.30 (Page 54) considers the requirements of Noted. See also Limited priorities regeneration, including timescales. This paragraph specifies A18.1. regeneration priorities and the first bullet point states ‘First priority: City Centre, Newington and St Andrew’s (West Hull) and Holderness Road Corridor (East Hull)’, we support this. Furthermore, the second bullet point specifies the second priority. Where opportunities arise to bring forward development that secures meaningful regenerative progress this should be viewed favourably and flexibility should be incorporated in the approach taken in order for a second priority to become a higher priority.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 100

Company / Section Section City Council ID Your response Organisation number title response Para. A.23. Not a very comprehensive view of Gateway’s role. It Noted. was about bringing a wider range of housing choice in the context of comprehensive regeneration masterplans (AAPs) for each area.

This view of the need for regeneration almost exclusively driven by It is still relevant deprivation is somewhat outdated. We need to focus on the re- to approach structuring of markets, both economic and housing, as the main regeneration with driver of change (tackling deprivation as the consequence of this) a view to a mix of and highlight the opportunities for creating a compact sustainable market and city with a clear raison d'etre which functions much better in the deprivation market. indicators.

Para.A.25. Not sure we actually say anywhere that we have based Noted, although interventions on tackling the worst housing conditions, this interventions in Regeneration statement needs deleting. Nasa are based 383 Gateway priorities on addressing poor environmental conditions. See also A18.1.

Map A.2 & para.A.27 and Pages 54-55. The Gateway strategy is Map A2 follows about housing markets and changing the nature of the housing and from Gateway residential neighbourhoods in the City, to compete with the leafy publicly available suburbs and the ERYC villages and attract and retain the whole documents, range of households. Map A.2 is completely wrong, the correct map although other is the spatial strategy map showing phase 2 areas in north Hull and areas will need area surrounding city centre. Should show AAP boundaries further (including city centre) to support the text - this drives a significant consideration proportion of the rest of the document so needs fundamental re- over time. See Response to the Hull Core Strategy issues and options report, June 2008 October 2008 101

Company / Section Section City Council ID Your response Organisation number title response visiting using the spatial strategy. A18.1.

Somewhere the document needs to acknowledge that there is a Noted. significant amount of demolition included here.

The measures of success could be more outcome orientated e.g. Noted. population stabilized, vacancy rates and house prices rather than no. of homes completed but also on jobs it should be economic activity and types of employment rather than jobs created.

We broadly support this Objective, especially that part relating to Support English Heritage Objective the improvement of the City’s image as a desirable and sustainable welcomed. 162 Yorkshire and 5 place to live, and would endorse the approach set out in Paragraph Humber Region A.34 for the delivery of this Objective. The economic regeneration policies of the HDF seek to focus Support growth within the existing employment areas of the City. It adopts a welcomed. See prioritised approach, whereby first priority is given to the areas of also A32.1. greatest economic need, with a second priority being areas Objective 188 National Grid representative of lesser need, but nevertheless subject to 5 deprivation. The Clough Road site, being located close to the second priority area of Drypool clearly has the opportunity to assist in meeting the regeneration objectives of the HDF. National Grid support the general regeneration Objective (Objective 5). We support the identified objective of enhancing the quality of life in Support the City, reduce poverty and inequality and to improve the city’s welcomed. See image as a desirable and sustainable place to live, through also A18.1. 42 Barratt Homes Options 5 determining regeneration priorities. However, in respect of the identified options, we believe these options are not specific enough and that further evidence is required in order to substantiate the Response to the Hull Core Strategy issues and options report, June 2008 October 2008 102

Company / Section Section City Council ID Your response Organisation number title response proposed regeneration priority sequence. We support the identified objective of enhancing the quality of life in Support the City, reduce poverty and inequality and to improve the city’s welcomed. See image as a desirable and sustainable place to live, through also A18.1.

77 Kayterm Ltd Options 5 determining regeneration priorities. However, in respect of the identified options, we believe these options are not specific enough and that further evidence is required in order to substantiate the proposed regeneration priority sequence. Generally, objective 5 and a combination of the four options is Support supported. In particular, recognition of the Holderness Road welcomed. See Corridor as one of the initial primary focal points for regeneration is also A34.1 supported.

However, additionally, in seeking to promote regeneration, much greater emphasis should be placed on planning positively for the Dransfield growth and expansion of centres, in line with the policy position 133 Options 5 Properties Ltd established by PPS6, and indeed the direction of travel indicated by draft changes to PPS6. Centres have a key role at the heart of sustainable communities, and investment in them can act as a catalyst to the wider regeneration of the communities they serve.

These themes should be incorporated into the preferred option, which should encourage the growth and expansion of centres within the regeneration priority areas, including Holderness Road. We support the identified objective of enhancing the quality of life in Support Kingswood Parks the City, reduce poverty and inequality and to improve the city’s welcomed. See

112 Development Options 5 image as a desirable and sustainable place to live, through also A18.1. Company determining regeneration priorities. However, in respect of the identified options, we believe these options are not specific enough Response to the Hull Core Strategy issues and options report, June 2008 October 2008 103

Company / Section Section City Council ID Your response Organisation number title response and that further evidence is required in order to substantiate the proposed regeneration priority sequence. Henderson The primary focus for development being the City Centre is Support 316 Options 5 Global Investors supported. welcomed. The priority should be preserving the fine housing and the currently See A16.1. high quality of life of the Avenues area. The large houses are a real asset to the city and could be the focus of tourism, (architectural Friends of tours), yet for many long years no effort was made by the council to 242 Options 5 Pearson Park help this area by, for example, providing low cost loans or grants for house maintenance. Residents are fed up with seeing their tax money go to improve the estates and council & private housing in "deprived" areas, while the Avenues are left to slowly decay. ABP considers that the best option to achieve this objective is Support to Option 5.1: Confirm the initial primary focus as being the City Option 5.1 is Centre, Newington and St Andrews Area and Holderness Road welcomed. Corridor as indicated by the boundaries to the Area Action Plans.

The Newington and St Andrews area is in the 10% most deprived wards in England in the Indices of Multiple Deprivation 2007 (IMD), and as such, are in desperate need of regeneration and change. Associated 269 Options 5 British Ports ABP considers that locating development in central area, such as in the Area Action Plans areas identified in Option 5.1 will locate development in locations that are accessible to the majority of the city’s population, allowing those who may have previously been socially excluded to access a range of facilities, services, and employment.

Regeneration of these areas would also create an attractive Response to the Hull Core Strategy issues and options report, June 2008 October 2008 104

Company / Section Section City Council ID Your response Organisation number title response gateway into the city, encouraging further development and investment.

In addition, as stated above, the Port of Hull is an asset to the long term future of the city and its continued future operation would assist in attracting new development and investment to regeneration of the city. The Port of Hull should therefore be protected by the Hull Development Framework Core Strategy, with flexibility provided to allow for any future expansion, particularly at Alexandra, Queen Elizabeth and King George Docks.

202 Local resident Options 5 The options are not separable. See A5.1 – A5.2.

Over the plan period it is appropriate to combine these options and See A5.1 – A5.2.

407 Hull Forward Options 5 align with the proposed stepped approach (with timescales modified as appropriate). The Core Strategy recognises national targets for CO2 emissions See A19.1 reductions. However, greater emphasis on higher quality design and construction standards is required - for example, emphasising on-site renewable in all scales of development, not just in large- scale development in order to assist in delivering the desired targets.

101 Natural England Climate change We welcome the summarised performance monitoring measures, but would also like to see the consideration of mitigation measures if carbon emissions cannot be offset comprehensively through sustainable development. We suggest making a link using green infrastructure with paragraphs A.41. p58, A.44 Options 6 No. 8 p59,.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 105

Company / Section Section City Council ID Your response Organisation number title response As a general point, we would highlight the importance of seeking See A19.1 the application of renewable energy in a manner that maximises the potential for reduction of greenhouse gas emissions.

Whilst we support in broad terms the approach suggested in relation to promoting sustainable forms of development; we would suggest that the second bullet in A41 should remove reference to managing energy demand through switching off appliances which Yorkshire are on stand-by, as the planning system has little control over how 243 Climate change Forward individual businesses, or households use energy.

It would be useful if the Core Strategy highlighted the role that green infrastructure such as green roofs and tree planting can play in helping to improve microclimates and attenuate heavy rainfall.

We welcome the support offered within A46 for district heating systems; the development of a wider district heating system would help to maximise the benefits derived from industrial waste heat. Paragraph A.38 (Page 57) relates to climate change policy and it Support Tesco Stores states ‘The Government’s target is to bring about a 12% reduction welcomed. 318 Climate change Limited in carbon dioxide emissions by 2012, by 26-32% by 2020 and a 60% reduction by 2050’, we support this. The third bullet in A.41 should be amended to read ‘minimise the Noted. Yorkshire risk of flooding’. In addition, it would be useful if this section referred 378 Climate change Forward to the role that public transport can play in cutting greenhouse gas emissions. ** Waste See A8.1 Environment 393 Climate change Agency Waste is not mentioned at all in the Core Strategy except in Response to the Hull Core Strategy issues and options report, June 2008 October 2008 106

Company / Section Section City Council ID Your response Organisation number title response passing as part of the item on climate change. The Council have said that waste is fully addressed in the Joint Waste DPD.

When we checked the Waste DPD again, we found a statement that an identical joint core policy on waste would be placed in both Hull and East Ridings’ Core policies. A draft of that policy is proposed in the Waste DPD Issues and Options doc, (page 23) with the suggestion that it be moved across in to the two councils’ core policies when they are produced, and deleted from the waste DPD. This has not happened at this stage. The Assembly is encouraged by Objective 6 which seeks “to Support ensure that everyone knows about and addresses climate change welcomed. through taking action and that new development a reduced carbon footprint”. The Assembly is encouraged that Options 6 identifies the option of requiring a percentage of energy requirements to be provided through on-site renewable energy for all new development, and increase the requirements year-on-year on the basis of targets set out in paragraph A.38.” The Assembly is Yorkshire and encouraged that paragraph A.38 makes reference to the renewable

358 Humber Climate change energy targets as set out in the RSS. The RSS sets indicative Assembly targets for installed grid-connected renewable energy for Hull of 6 MW by 2010 and 39 MW by 2021 (Table 10.2, Policy ENV5).

The Assembly is encouraged that Options 6 identifies the possible option of identifying suitable locations for renewable energy schemes, such as wind turbines, and seek contributions from developers to fund these schemes if ‘on-site’ renewable energy is not achievable’. It is worth noting that RSS Policy HE1 C provides for the Humber Sub-Area to develop its renewable energy

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 107

Company / Section Section City Council ID Your response Organisation number title response generation potential, whilst taking account of the potential cumulative impact of large numbers of wind turbines and associated development. Paragraph 5.17 of RSS emphasises that the Humber Estuary sub area has a major role to play in terms of the Region’s renewable energy generation.

Options 6 also rightly identify the need for large-scale developments to incorporate on-site renewable energy technology. Policy ENV5 states the Region will maximise improvements to energy efficiency and increase renewable energy capacity. Plans, strategies, investment decisions and programmes should promote and secure greater use of decentralised and renewable or low- carbon energy in new developments, including through Development Plan Documents setting ambitious but viable proportions of the energy supply for new developments to be required to come from such sources. In order to ensure that regeneration proceeds in a sustainable Support to manner, the HDF requires appropriate measure to be taken in all objective is Objective 189 National Grid new development to reduce carbon footprint (Objective 6). National welcomed. 6 Grid support the objective of sustainable development, but note that the HDF does not fully recognise the Policy Guidance of PPS22. Friends of Objective p. 56, A.37: The evidence on climate change does not "suggest;" it Noted. 244 Pearson Park 6 "proves"... A striking way to combat climate change is by making the port Noted. Friends of Objective 372 completely operable by renewable energy as is the port of Pearson Park 6 Rotterdam. Objective We suggest that you remove the words "seek to" from this Noted. 334 RSPB 6 objective.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 108

Company / Section Section City Council ID Your response Organisation number title response We consider that this Objective 6 is too broad for the Core Strategy, Noted. and does not add anything to national policy guidance.

Possible options to include this objective range from requiring on- Support to site renewable energy in all new development through to the Option 6.3 is identification of suitable locations for renewable schemes. We welcomed. support option 3 which seeks to passively support sustainable Suitable sites for development and renewable energy proposals and follow national renewable guidance where applicable. The provision of renewable energy, the development implementation of the Code for Sustainable Homes and the need studying maximisation of energy efficiency adds costs to the implementation further. See also of development. The City Council need to ensure that in a fragile A2.1 – A2.6. housing market such as Hull it does not impose requirements over and above those set out in national planning policy guidance. It is important to ensure that Hull remains competitive as a location for 45 Barratt Homes Options 6 housing development if the high house building rates required by the RSS are to be met.

In this regard, we accept that policy ENV5 of the RSS states:-

“New developments of more than 10 dwellings or 1000m2 of non- residential floorspace should secure at least 10% of their energy from decentralised and renewable or lowcarbon sources, unless, having regard to the type of development involved and its design, this is not feasible or viable.”

We consider that the optimum and most cost effective way of providing renewable energy is through the provision of larger schemes rather than the provision of on-site technology. We consider that the City Council should seek to identify suitable Response to the Hull Core Strategy issues and options report, June 2008 October 2008 109

Company / Section Section City Council ID Your response Organisation number title response locations for renewable schemes. We consider that this Objective 6 is too broad for the Core Strategy, Noted. and does not add anything to national policy guidance.

Possible options to include this objective range from requiring on- Support to site renewable energy in all new development through to the Option 6.3 is identification of suitable locations for renewable schemes. We welcomed. support option 3 which seeks to passively support sustainable Suitable sites for development and renewable energy proposals and follow national renewable guidance where applicable. The provision of renewable energy, the development implementation of the Code for Sustainable Homes and the need studying maximisation of energy efficiency adds costs to the implementation further. See also of development. The City Council need to ensure that in a fragile A2.1 – A2.6. housing market such as Hull it does not impose requirements over and above those set out in national planning policy guidance. It is 78 Kayterm Ltd Options 6 important to ensure that Hull remains competitive as a location for housing development if the high house building rates required by the RSS are to be met.

In this regard, we accept that policy ENV5 of the RSS states:-

“New developments of more than 10 dwellings or 1000m2 of non- residential floorspace should secure at least 10% of their energy from decentralised and renewable or lowcarbon sources, unless, having regard to the type of development involved and its design, this is not feasible or viable.”

We consider that the optimum and most cost effective way of providing renewable energy is through the provision of larger

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 110

Company / Section Section City Council ID Your response Organisation number title response schemes rather than the provision of on-site technology. We consider that the City Council should seek to identify suitable locations for renewable schemes. In relation to Option 6.9 construction waste, given the embodied Noted. energy within existing buildings (in terms of the materials used for their construction, the energy that was involved in moving those materials to the site etc) coupled with the energy which would be expended in the demolition of those buildings and the removal of the waste materials, the LDF, as a whole, should encourage the reuse of existing buildings in preference to their demolition and the English Heritage redevelopment of a cleared site. 163 Yorkshire and Options 6

Humber Region Under such an approach, the starting point for consideration of a proposal would be whether it would reuse or adapt an existing building. Where this was not practicable or it could be demonstrated that this was a less sustainable solution, then the reuse of existing materials should be considered. Only at the end of this process would a building proposing new materials be permitted. Options 6.1 and 6.2 are inappropriate. It is wrong to expect all new Noted. development to provide on site generation, and equally it is wrong to expect only large scale development to incorporate on site renewable energy technology. Rather, targets should be set in Dransfield terms of on site renewable energy generation for all development, 134 Options 6 Properties Ltd but this should only be required to be delivered on site where that is the most appropriate solution. Where it can be demonstrated that it is not the most appropriate solution, then in certain circumstances contributions to off site schemes may be sought. The preferred option should reflect this and additionally be based around options

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 111

Company / Section Section City Council ID Your response Organisation number title response 3 - 9. We consider that this Objective 6.6 is too broad for the Core Noted. Strategy, and does not add anything to national policy guidance.

Possible options to include this objective range from requiring on- Support to site renewable energy in all new development through to the Option 6.3 is identification of suitable locations for renewable schemes. We welcomed. support option 3 which seeks to passively support sustainable Suitable sites for development and renewable energy proposals and follow national renewable guidance where applicable. The provision of renewable energy, the development implementation of the Code for Sustainable Homes, the need studying maximisation of energy efficiency and the like adds costs to the further. See also implementation of development. The City Council need to ensure A2.1 – A2.6. that in a fragile housing market such as Hull it does not impose Kingswood Parks requirements over and above those set out in national planning 113 Development Options 6 policy guidance. It is important to ensure that Hull remains Company competitive as a location for housing development if the high house building rates required by the RSS are to be met, particularly in view of the continuing struggles in the housing market, nationwide.

In this regard, we accept that policy ENV5 of the RSS states: “New developments of more than 10 dwellings or 1000m2 of non- residential floorspace should secure at least 10% of their energy from decentralised and renewable or low-carbon sources, unless, having regard to the type of development involved and its design, this is not feasible or viable.”

We consider that the optimum and most cost effective way of providing renewable energy is through the provision of larger

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 112

Company / Section Section City Council ID Your response Organisation number title response schemes rather than the provision of on-site technology. We consider that the City Council should seek to identify suitable locations for renewable schemes, such as wind turbines, which, given the built up area of the City may need to be provided in East Riding of Yorkshire. It is disappointing that your objective on climate change focuses See A19.1. exclusively on mitigation (by reducing carbon emissions) and does not mention the important issue of adaptation to the climate change which is inevitably going to occur over coming decades and indeed is already happening.

We endorse what you say about mitigation, although it may be appropriate to refer to not just the national targets for reduction in CO2 emissions but also the (more ambitious) regional targets in the draft Yorkshire and Humber Regional Plan (Regional Spatial Strategy). The Woodland 153 Options 6 Trust On mitigation, it would also be good if Option 6.6 could refer to use of wood as a fuel, as this is an area which Yorkshire Forward, the Forestry Commission and other regional partners are showing great interest in. We support use of wood as a fuel but we prefer the emphasis to be on small scale projects where real carbon reduction benefits can be shown and it is also important that the woods used are certified as being managed sustainably.

On adaptation, a particularly important aspect which we would like to see in your Core Strategy is creation of a multi-functional network of green space including areas of high biodiversity value such as woodland. Such a network is of great benefit to local

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 113

Company / Section Section City Council ID Your response Organisation number title response people (encouraging exercise, contact with nature etc) but also can enable wildlife to move and adapt to the impact of climate change.

This is endorsed in the Stern Report on climate change, where it states:

“Protecting natural systems could prove particularly challenging. The impacts of climate change on species and biodiversity are expected to be harmful for most levels of warming, because of the limited ability of plants and animals to migrate fast enough to new areas with suitable climate (Chapter 3). In addition, the effects of urbanisation, barriers to migration paths, and fragmentation of the landscape also severely limit species' ability to move. For those species that can move rapidly in line with the changing climate, finding new food and suitable living conditions could prove challenging. Climate change will require nature conservation efforts to extend out from the current approach of fixed protected areas. Conservation efforts will increasingly be required to operate at the landscape scale with larger contiguous tracts of land that can better accommodate species movement. Policies for nature protection should be sufficiently flexible to allow for species' movement across the landscape, through a variety of measures to reduce the fragmentation of the landscape and make the intervening countryside more permeable to wildlife, for example use of wildlife corridors or “biodiversity islands”. WLL recognise the importance of new development addressing Noted. See also Wrenbridge Land climate change through a reduction in energy consumption. A19.1. 148 Options 6 Limited Whilst a range of measures can be incorporated within

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 114

Company / Section Section City Council ID Your response Organisation number title response developments to achieve the above it is considered appropriate that policy is specific rather than general and applicable to all developments as opposed to only large scale developments (option 6(2)).

Any development plan policy to address energy consumption must be in general conformity with RSS which states (policy ENV3.B.3) that:

"In advance of local targets being set in Development Plan Documents, new development of more than 10 dwellings or 1000m2 of non residential floorspace should secure at least 10% of their energy from decentralised and renewable or low- carbon sources, unless, having regard to the type of development involved and its design, this is not feasible of viable."

In setting any target for decentralised, renewable or low carbon energy consumption WLL request that Hull City Council pay particular regard to the implications any target can have on the viability of a scheme together with other potential section 106 requirements. It will be important that the target is consistent across the region to ensure that Hull, for example, does not have an unduly onerous requirement when compared against other locations within Yorkshire and Humber, as this would potentially deter development, hence investment and job creation. The role of planning to influence matters of climate change and the Support for desire for new development to reduce its carbon footprint is options 6.3 – 6.9 181 Pure Urban Options 6 acknowledged as appropriate to consider in the Core Strategy. That is welcomed. said it is important that the Core Strategy does not provide policy See also A19.1.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 115

Company / Section Section City Council ID Your response Organisation number title response which is unduly prescriptive, particularly in an area of development where new technologies and their full and broad impact on climate change are yet to be known. It is inappropriate in our view to require all new developments to provide a prescriptive percentage of on site renewable energy generation as on site generation may not be the most efficient or effective way to deliver renewable energy. The Core Strategy can however support the provision of renewable energy and therefore a combination of Options 6.3 through 6.9 are supported. Development viability should at all times be a consideration, particularly on urban, previously developed sites which can carry other significant development costs. The Core Strategy should not duplicate standards and codes set out in other legislation and some matters of building standards are therefore more appropriately covered in other areas such as Building Regulations. In order to meet Objective 6, the HDF promotes various initiatives See A19.1. (in the form of Option 6) including the adoption of sustainable construction methods, energy efficiency, onsite renewables, etc. There is however no recognition within these options that in certain circumstances such initiatives may not be practical or economically viable.

190 National Grid Options 6 PPS22, at paragraph 8, recognises that the delivery of onsite renewable energy and sustainable construction methods will not always be practicable or financially viable to developments. National Grid recommend that the HDF should recognise the economics and practicalities of development in delivering sustainable construction and design.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 116

Company / Section Section City Council ID Your response Organisation number title response ABP supports a number of the options set out in Objective 6 in Support for principle. More specifically, ABP welcome the provisions in the options 6.3, 6.4, Core Strategy that promote opportunities for sustainable and 6.8 is welcomed. renewable energy proposals, and the identification of suitable locations for renewable energy schemes such as wind turbines. As such, ABP supports Options 3 and 4 accordingly.

National and regional planning policy emphasises the need for Local Development Framework documents to promote reductions in carbon dioxide emissions and sustainable low carbon and renewable energy proposals. In light of this and ABP’s aspirations for the future of its land holdings in Hull, the potential for sustainable low carbon and renewable energy development is being actively investigated at present, and it is requested that the Associated Core Strategy encourages this accordingly. 280 Options 6 British Ports ABP supports Option 8. However, ABP considers that the wording of Option 8 in the Issues, Options and Suggested Preferred Options document does not read well, and suggest it is amended to the following: “Locating uses in areas which minimise the need to travel by private car, and maximise the use of the port and the River Hull”.

Policy YH2 in the RSS states that traffic growth should be reduced through the appropriate location of development, and RSS Policy YH7 states that development should be located so that it makes the best use of existing transport infrastructure and capacity.

ABP considers that development should be located close to the city centre and the River Humber. Development in this location would be accessible to the majority of the city’s population by public Response to the Hull Core Strategy issues and options report, June 2008 October 2008 117

Company / Section Section City Council ID Your response Organisation number title response transport, and would also be within walking and cycling distance from the city centre. Development in this location would therefore reduce dependence on the private car; encourage more cycling, walking and use of public transport, therefore reducing vehicle emissions and the impact of climate change.

In addition, ABP requests that the Hull Development Framework protects their operations at the Port of Hull, and gives flexibility to allow for any future expansion. ABP considers that the Port of Hull has a vital role to play in reducing the impacts of climate change by allowing for freight to be transported by more sustainable modes of transport.

Policies T4 and T7 of the Regional Transport Strategy in the RSS states that plans should maximise the use of rail or water for freight movements, and recognise the contribution these modes can make to the transportation of bulk materials. Options 6.1 and 6.2 appear to be mutually exclusive. Option 6.7 Noted. 203 Local resident Options 6 should be rewritten to make the intended meaning clear. East Riding of Yorkshire Council supports the general emphasis See A19.1 towards reducing the impacts of climate change. However, the 9 options are not mutually exclusive and appear more as general statements of intent. There is also significant duplication with East Riding of existing National and Regional policies (e.g. design and layout is 456 Options 6 Yorkshire Council already set out in these higher order documents).

Importantly, the document does not consider options on some of the key issues involved in delivering this objective. For example, it would be helpful if the statement requiring a percentage of energy

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 118

Company / Section Section City Council ID Your response Organisation number title response requirements to be provided through on-site renewable energy for all new developments (already required in the Regional Spatial Strategy) instead provided options on what the percentage requirement and site threshold should be (i.e. to provide a locally distinctive policy for Hull).

It would also be useful to set out how the waste recycling option See A8.1. links to target 45+, Hull and East Riding’s Joint Sustainable Waste Management Strategy and the emerging Joint Waste Development Plan Document. Support for Friends of 371 Options 6 Options 2 & 3 are weak; options 4, 5, 6 are O.K. options 6.4-6.6 is Pearson Park welcomed. There will need to be an element of flexibility and negotiation but See A8.1. where possible all new development should be required to integrate renewable/sustainable energy generation, waste minimisation and

408 Hull Forward Options 6 water recycling/minimisation where possible. All new housing should be required to meet high sustainability standards. Clear and comprehensive guidance should be produced to encourage and support best practice where possible. Specific attention to the needs of disabled people and the flooding Further work is risk needs to be made. Disabled people are probably more needed in vulnerable because of their specific physical requirements. The assessing future Hull Access need to build properties 'out of the ground' could if poorly designed housing

18 Improvement Risk of flooding cause considerable difficulties for disabled people. Some disabled provision. See Group people require ground floor accommodation; this need can be met also A20.1. via building bungalows with the appropriate level access. Family bungalows are required for families with a disabled family member, child or adult. Disabled people are often not able to be evacuated Response to the Hull Core Strategy issues and options report, June 2008 October 2008 119

Company / Section Section City Council ID Your response Organisation number title response easily either. The floods last year saw many disabled people have to leave their homes and in some cases the city, this resulted in the loss of independence for some. p. 61, Map: None of the maps in the framework are "accessible" Noted. Friends of 245 Risk of flooding since the names of areas and salient landmarks and streets are not Pearson Park identified. Friends of See A20.1. 370 Risk of flooding p. 60, A.53: Why is national policy not appropriate to Hull? Pearson Park Para A.50. Should add a reference to the 'draft Hull and Coastal Noted. Environment 389 Risk of flooding Streams CFMP' which has been produced by the Environment Agency Agency. Para A.53-54. Hull is NOT exempt from the requirements of PPS25 See A20.1. and specifically the Sequential Test and Exception Test. However, these paragraphs suggest that this national policy is not appropriate Environment for Hull. It would be more accurate, given the actual content of 390 Risk of flooding Agency Hull's SFRA, to state that the requirements of PPS25 have been accommodated in Hull's SFRA and that development will still need to be subject to the Sequential Test and Exception Test where necessary. Para A.59. The first bullet point needs clarifying - does adaptation These points will include the proportion of development proposals that include SUDs be clarified. provision?

Environment 392 Risk of flooding We question the final bullet point here as we do not see how "how Noted and will be Agency many FRAs are sent to the Environment Agency for comment" amended. adds value and consider that it should be removed. The Hull SFRA contains a standing advice matrix which determines which applications are sent to the Environment Agency for comment on

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 120

Company / Section Section City Council ID Your response Organisation number title response the FRA. If you include an indicator of this nature, it should be asking whether this matrix is being complied with in terms of who (the LPA or EA) is determining which FRAs. ** BIODIVERSITY

The document states that open spaces will be left to hold water in Noted. the event of a flood. These areas should be designed to maximise biodiversity interest.

On 'brown field' sites, surveys should be undertaken for alien Surveys of sites invasive plant species such as Japanese Knotweed. A strategy have recently Environment 394 Risk of flooding should be devised to eliminate any such species that are found. been completed Agency but are not as detailed as this.

As part of the area is adjacent to the Humber Estuary Special Noted. Protection Area (SPA) and Special Area of Conservation (SAC), a Habitats Regulations assessment must be completed to ensure that the proposed development will not adversely impact upon these protected sites. There are very few references to groundwater or water resources, Noted and the within the document. Hull is reliant on groundwater abstractions for issues will be much of its water supply and as such is vulnerable to any considered in Environment deterioration in both the quantity and quality of these groundwater more detail in the 395 Risk of flooding Agency sources. Whilst the main source of supply is from abstractions in next draft East Riding they are of significant importance to the City and we document. consider should be mentioned within the key issues. Consideration needs to be given to the protection of these resources.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 121

Company / Section Section City Council ID Your response Organisation number title response ** WATER QUALITY

Water quality is not specifically addressed in the Core Strategy Noted and the other than in Objective 7 - seek to ensure that new development is issues will be located and designed appropriately and in Option 7 where it states considered in that surface water run off should be restricted and SuDS should be more detail in the included. next draft document.

Within Objective 3, the city will only become sustainable if water quality is addressed alongside the other measures, to ensure the quality is good enough for abstraction and use. This could be measured through a reduction in water pollution incidents or an increase in quality, this would be achieved by working with Environment businesses and communities to ensure correct and suitable 396 Risk of flooding Agency disposal and drainage.

Objective 5, to enhance quality of life in the city. The city's image will improve if the watercourses through it improve. Hull needs spaces that are attractive, feel safe and are open to the public and recreation. The city’s watercourses should be able to provide these spaces. With care and attention, land management, reductions in pollution and surface water run off and river management the waterbodies will move towards meeting the Water Framework Directive.

Objective 6, reducing carbon footprint and climate change must include the reduction of water usage and therefore reduce the amount of raw water and waste water treatment.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 122

Company / Section Section City Council ID Your response Organisation number title response Objective 17, development designs should include methods to reduce water usage and recycle waste water. ** FISHERIES:

The increase in holding ponds to minimise the risk of flooding (as Noted although envisaged in the strategy) may provide some increased angling ponds would opportunities. Future development of Hull should provide need to be opportunities for fisheries and must not compromise the quality of maintained on a the city's fisheries. regular basis if used for angling. Environment 397 Risk of flooding Agency As detailed in our publication 'Fishing for the future', one of the key priorities for fisheries is to increase the contribution angling makes to society, the economy and the environment. To do this, we need more chances for more people to fish and we need our fisheries to perform better. Our publication goes on to highlight the benefits of angling for self-esteem and well being and may be a powerful and cost-effective way of tackling anti-social behaviour, educational under-achievement and youth crime. One further issue we wish to raise in respect of flood risk is the Noted although requirement for further details to demonstrate how the results of the there are Strategic Flood Risk Assessment (SFRA) have informed the overlaps with development distribution strategies of the Core Strategy. In flooding and

373 Barratt Homes Risk of flooding consideration of the recent well publicised flood issues associated impact on with the City, we believe that further evidence is required within the development and Core Strategy to demonstrate how the findings of the SFRA have regeneration. influenced such strategies as the identified development scenarios See also A20.1. and the regeneration priority areas.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 123

Company / Section Section City Council ID Your response Organisation number title response One further issue we wish to raise in respect of flood risk is the Noted although requirement for further details to demonstrate how the results of the there are Strategic Flood Risk Assessment (SFRA) have informed the overlaps with development distribution strategies of the Core Strategy. In flooding and

375 Kayterm Ltd Risk of flooding consideration of the recent well publicised flood issues associated impact on with the City, we believe that further evidence is required within the development and Core Strategy to demonstrate how the findings of the SFRA have regeneration. influenced such strategies as the identified development scenarios See also A20.1. and the regeneration priority areas. Natural England supports Objective 7 ‘To seek to ensure that new Support Objective 102 Natural England development is located in areas of low risk and uses vulnerable to welcomed. 7 flooding are located or designed appropriately.’ A preferred option based around a combination of the options is an Noted. See also appropriate response to the issue of flooding in Hull. A20.1.

However, Objective 7 should be recast to reflect this. At present it does not reflect the tone that would be set by a combination of the options. Objective 7 seeks at the outset to, "seek to ensure that new development is located in areas of low risk". In Hull, very extensive areas are in medium hazard zones, and these areas will Dransfield Objective 135 need to make a contribution to accommodating the city's Properties Ltd 7 development needs. A combination of the options, as recommended in the options document (paragraph A.58) would enable this (particularly options 2 and 3), whilst preventing development in the highest risk areas. However, this would then be at odds with the wording of Objective 7.

Accordingly, Objective 7 should be reworded to read, "To seek to ensure that the location of new development is guided by and

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 124

Company / Section Section City Council ID Your response Organisation number title response responds to flood risk, and uses vulnerable to flooding are located or designed appropriately." Issues of flood risk present particular challenges for Hull however Noted. See also they should not be an overriding influence which in itself stifles and A20.1. constrains the City’s growth aspirations.

Much of the City lies within flood risk areas. Whilst it would be ideal for new development to be located in areas of low risk, this would run contrary to other important planning and economic development strategies which promote the growth of the city in Objective other areas. 182 Pure Urban 7 Pure Urban support an approach which seeks to assess options for growth in low risk areas but not at the expense of other more sustainable and advantageous locations for growth. Therefore it is important that in other areas which may present higher risks of flooding, then adequate and effective flood protection measures are incorporated in development. This has been successfully achieved in the City Centre for example and should continue to be an acceptable option. We welcome the inclusion of Objective 7 which seeks to manage Noted. See also flood risk, it will also be necessary to balance this with the need to A20.1. support urban regeneration within Hull. Whilst we acknowledge that flood risk is an important consideration in informing the allocation of Yorkshire Objective 234 sites for new development, it should not be the sole driver for Forward 7 directing development within the city.

In the situation where suitable alternative lower risk sites are not available, it may be appropriate to develop in higher risk zones, if

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 125

Company / Section Section City Council ID Your response Organisation number title response there is a significant benefit in terms of urban regeneration. However, it will be necessary to ensure that such developments take appropriate account of the proposed use type, building design and other adaptation measures necessary to withstand any increased flood risk. The Objective refers to the siting of new development; most of the Noted. See also objectives are in fact concerned with reducing risk. The two should A20.1. Local resident Objective 205 be brought into line. Presumably, since there are few areas of low 7 risk, opportunities for development are limited, so the City would wish to reduce risks. Given the susceptible nature to flooding of the city, and the need to Noted. See also balance this consideration with the need to ensure the city develops A20.1. Objective to meet the aspirations of the Council, areas of higher flood risk 221 Local resident 7 should not necessarily be discounted as areas for development, providing it can be demonstrated that the proposed design can considerably reduce risk. This would accord with Objective 7. We object to the wording of Objective 7. Given the predominance of Noted. See also flood risk areas within Hull, we consider that this objective would be A20.1. Kingswood Parks Objective better worded: “seek to ensure that new development is located in 377 Development 7 areas of low risk and uses vulnerable to flooding are located or Company designed appropriately or that adequate mitigation measures are in place to ensure the avoidance of flooding.” The RSPB supports Government policy on Development and Flood Noted. See also Risk (PPS 25). The RSPB believes that all new development within A20.1. Objective high flood risk areas is unsustainable due to predicted rising sea 335 RSPB 7 levels and changes in climatic patterns. We believe that it is not possible to be confident about the long-term sustainability of new development within floodplains. The long-term economic

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 126

Company / Section Section City Council ID Your response Organisation number title response implications and environmental sustainability of developing and maintaining infrastructure in areas prone to flooding are not fully understood. However, there is sufficient evidence to indicate that the pressures on natural ecosystem services, public services (such as drainage and water treatment), the public purse and the emotional cost to communities affected by flooding are extremely high. We strongly support the intention for areas of functional floodplain in Hull to remain undeveloped but also believe that new development in the high flood risk areas (option 6) either side of the River Hull should not be permitted.

The RSPB believes that a more sustainable long-term approach to catchment management is required such as the controlled restoration of functioning floodplain and wetland habitats in appropriate areas, in a way that can protect existing infrastructure whilst accommodating flood storage, reducing levels of flash flooding, recharge groundwater levels and bring benefits to biodiversity. We strongly support the option to work with the East Riding to designate areas for flood storage beyond the city boundary (option 7) but that this should be undertaken alongside maximising the use of existing green spaces in Hull as holding ponds to minimise the risk of flooding (option 1). As well as helping to reduce flood risk, this provides excellent opportunities for habitat creation and the enhancement of biodiversity. We are extremely concerned about the proposed urban extension in the Kingswood area to the north of the city. Along with areas to the west of the River Hull we believe that this area should be managed for flood storage to minimise downstream effects of flooding on the existing developed areas.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 127

Company / Section Section City Council ID Your response Organisation number title response We also advocate the incorporation of SUDS in all new developments (option 5). Objective Development should be appropriately located and focused as far as Noted. See also 411 Hull Forward 7 possible in low risk areas… A20.1. Given the predominance of flood risk areas within Hull, we consider Noted. See also that Objective 7 would be better worded: “seek to ensure that new A20.1. Objective development is located in areas of low risk and uses vulnerable to 374 Barratt Homes 7 flooding are located or designed appropriately or that adequate mitigation measures are in place to ensure the avoidance of flooding.” Given the predominance of flood risk areas within Hull, we consider Noted. See also that this objective would be better worded: “seek to ensure that new A20.1. Objective development is located in areas of low risk and uses vulnerable to 376 Kayterm Ltd 7 flooding are located or designed appropriately or that adequate mitigation measures are in place to ensure the avoidance of flooding.” A number of options are proposed to reduce flood risk. We note Noted. See also that the Council are suggesting a Preferred Option which would A20.1. combine all of the suggested options. However, a number of the options set out are contradictory; for example, development could 46 Barratt Homes Options 7 not be permitted within flood risk areas where adequate flood protection can be achieved (3) whilst simultaneously not allowing any development in flood risk areas (6). In our view, all developments within Hull should be designed for flood avoidance. A number of options are proposed to reduce flood risk. We note Noted. See also that the Council are suggesting a Preferred Option which would A20.1. 79 Kayterm Ltd Options 7 combine all of the suggested options. However, a number of the options set out are contradictory; for example, development could

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 128

Company / Section Section City Council ID Your response Organisation number title response not be permitted within flood risk areas where adequate flood protection can be achieved (3) whilst simultaneously not allowing any development in flood risk areas (6). In our view, all developments within Hull should be designed for flood avoidance. Supports (Options 7 No1.) Maximise the use of green spaces as Support to ‘holding ponds’ to minimise the risk of flooding. Any proposals options is proposed as a result of the Core Strategy must be compatible with welcomed. See and complement the two relevant Flood Risk Management also A20.1. Strategies for the rivers Hull and Humber. 104 Natural England Options 7

(Option 7 No 5) Support the promotion of sustainable drainage systems (SUDS) and suggests the requirement for all new development to incorporate the principles of SUDS especially in high risk zones. A number of options are proposed to reduce flood risk. We note Noted. See also that the Council are suggesting a Preferred Option which would A20.1. combine all of the suggested options. However, a number of the options set out are contradictory; for example, development could Kingswood Parks not be permitted within flood risk areas where adequate flood

115 Development Options 7 protection can be achieved (3) whilst simultaneously not allowing Company any development in flood risk areas (6). In our view, all developments within Hull should be designed for flood avoidance. This is the approach taken at Kingswood following the Secretary of State’s grant of outline planning permission in August 2004 which has proved to be successful. The HDF recognises that a significant proportion of the City is Noted. See also located within a high flood risk area, although notes that A20.1. 192 National Grid Options 7 development will continue to be needed within across the city. As a consequence, the generic policies of national and regional policy Response to the Hull Core Strategy issues and options report, June 2008 October 2008 129

Company / Section Section City Council ID Your response Organisation number title response which seek to avoid development in high flood risk areas is not appropriate to Hull, due to its unique characteristics (para A.53). As a consequence, the Council’s Strategic Flood Risk Assessment seeks to place Hull into 6 zones of flood risk, and seeks to direct development to the areas of lowest risk within these 6 zones, specifying only the areas with the highest risk of flooding (functional floodplain) as not being suitable for development.

National Grid support this approach given the economic regeneration agenda of the HDF. Tesco Stores In terms of risk of flooding (Page 62) and objective 7, option 7, point Noted. See 320 Options 7 Limited 6 would not be supported. A20.1. Yorkshire Water supports partnership working to effectively tackle Noted. See also the flooding constraints within Hull. We will continue to work with A20.1. the Council and other partners during the production of this document and beyond.

Yorkshire Water We believe it is essential that this partnership working includes East 254 Options 7 Plc Riding Council. The HDF needs to be co-ordinated with East Riding’s Local Development Framework as development in their area may have direct downstream consequences on Hull’s drainage system that need to be considered. We support the suggested preferred option in paragraph A.58 to combine the 7 options identified to achieve objective 7. East Riding of Yorkshire Council supports the importance of Noted. See also reducing flood risk. However, there is concern that areas outside A20.1. East Riding of 457 Options 7 the city boundary (within the East Riding) are shown on the Key Yorkshire Council Diagram. It is considered that any areas of flood storage within East Riding should be identified by and in the East Riding LDF (through Response to the Hull Core Strategy issues and options report, June 2008 October 2008 130

Company / Section Section City Council ID Your response Organisation number title response the conclusions of the East Riding Strategic Flood Risk Assessment).

It would be helpful if any areas of East Riding that the City Council may propose for flood storage were identified as soon as possible so they can be considered through the preparation of the East Riding Core Strategy and Allocations DPD. This will also allow those developers who may have submitted land bids for the East Riding LDF, landowners and the general public to consider the issue.

The document does not identify any key delivery agencies for this objective. We agree that the preferred option should be a combination of Noted. See also Environment these options. However, the reference to SUDs could be expanded A20.1. 391 Options 7 Agency to include considering using 'green roofs' on new developments, where appropriate. Agree a combination of options is necessary. Clear guidance will be Noted. See also

409 Hull Forward Options 7 needed to support appropriate development and to maintain A20.1. developer confidence. The Assembly welcomes the reflection of flood risk in Option 7, as Noted. See also flood risk is clearly a major issue for Hull. The Assembly welcomes A20.1. the references made to the Strategic Flood Risk Assessment which Yorkshire and considers the most appropriate development locations and provides

359 Humber Options 7 design guidance to protect against the risk of flooding. This will be Assembly an important tool in helping to determine how the Core Strategy will be delivered.

Policy ENV1 states that the region will manage flood risk pro- Response to the Hull Core Strategy issues and options report, June 2008 October 2008 131

Company / Section Section City Council ID Your response Organisation number title response actively by reducing the causes of flooding to existing and future development, especially in tidal areas, and avoid development in high flood risk areas where possible. It also emphasises that flood management will be required to facilitate development in Hull. Many disabled people currently do not have a realistic alternative to Noted, although using their own vehicle. Although some improvement to the these matters are 'accessibility' of public transport has been made, unfortunately it generally outside does not meet the needs of all. The limit of one wheelchair the scope of the accessible space on buses, which is often taken up by prams, the planning system. distance to bus stops for some is just too much. The new Hull Access Transport interchange is a very disconcerting place for those with a visual

19 Improvement system and impairment or developmental condition. Taxis, although some offer Group getting about wheelchair access they are often very expensive, they are still not accessible to other disabled people with physical impairments who do not require to travel in a wheelchair.

The rise in the use of mobility scooters needs to be planned for rather than just reacted to, with rising fuel costs and an ageing population their use can be expected to grow in the future. These are all The Core Strategy should give more emphasis to addressing matters which Transport issues related to: deficiencies in public right of way networks; are adequately

105 Natural England system and maximising opportunities for walking, cycling and riding; integrating covered by getting about access with public transport; and generally promoting alternative national policy so modes of transport. there is no need to repeat this. Transport Para A.60. If a sustainable system is to be put into place I suggest Noted, although Friends of 246 system and following the example of Gothenburg in Sweden where the whole these matters are Pearson Park getting about centre of the city is almost devoid of cars. Instead, buses, trams generally outside Response to the Hull Core Strategy issues and options report, June 2008 October 2008 132

Company / Section Section City Council ID Your response Organisation number title response and even boats abound and are served by one ticket good for 90 the scope of the minutes on any combination of transport. The prices are extremely planning system. reasonable, which Hull ticket prices are not. It has to be made cheaper to use public transport than to use a car, which is not the case today. As Great Union Street is already called the Eastern Orbital Road Noted. presumably this means the dualling of Great Union Street. It would benefit the city far more if Mount Pleasant was dualled between Hedon Road and Holderness Road. There is a grade separated junction where Mount Pleasant joins the A63T and improving traffic Measures flow on the southern part of Mount Pleasant would reduce delays at needed to Garden Village the A63 dumbbell roundabouts while increasing the traffic on Great 306 improve the Society Union Street would increase delays on the A63/ Great Union Street transport roundabout. system

Mount Pleasant is the main route from the East Hull Docks to the York and the North. Improvements to Mount Pleasant would thus stand a good chance of being supported by the Regional Transport Board. Measures Noted. needed to Para A.65. Castle Street traffic will not improve until pedestrian Friends of 248 improve the bridges are built over it. This is not only the cheapest option, but the Pearson Park transport most feasible. system HAig considers that there will always be a need for disabled people Noted. Hull Access to be able to travel into the city centre in their own vehicles, some

20 Improvement Options 8 of which are adapted to give them independence. Parking provision Group and distance to amenities needs to be considered fully in any redevelopment scheme. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 133

Company / Section Section City Council ID Your response Organisation number title response Option 8.2 and 8.5. The transport options should include an option Noted, although to make greater use of existing rail facilities by building rail halts on these are not the Hull-Beverley line which serve the adjacent residential and current viable or service centres in the west of the city. Service hubs should be evidenced located adjacent to these hubs. options.

An example is the current rail opportunity at the intersection with Hotham Road. The development of Kelvin Hall school to incorporate progression from Priory and Wold primary schools is going to massively increase the use of this footbridge by secondary age pupils. It is already used by large numbers of Wyke College students. It is currently in disgraceful condition and yet represents an excellent opportunity for development of a green corridor of pedestrian and cycle movement. This opportunity can be Wyke Sixth Form significantly enhanced by the development, in tandem, of a rail 89 Options 8 College station at this point and a neighbourhood service hub in the Hotham Road corridor. This is one point at which it is necessary to think beyond boundaries. The real community of this area includes many homes in the East Yorkshire local authority area on both sides of the rail line. The travel to learn area, potentially at secondary and already for post-16 students, reaches well out beyond the city boundary.

The plan, needs, therefore, to take more account of cross -LA boundary realities of living and services.

Option 8.2 supports this point.

Option 8.5 should be promoted up the order of priorities in that section. Hull has the opportunity to set a world example in this area Response to the Hull Core Strategy issues and options report, June 2008 October 2008 134

Company / Section Section City Council ID Your response Organisation number title response and this plan lacks the necessary ambition to make it a city in which to cycle and to walk are the first and obvious choices of all citizens. The city is not going to achieve distinction by being a pale regional imitation of other cities with a plan which tries to copy theirs with a pale imitation of resource allocation. To make a compelling bid for the resources it needs it must make its case as a city of the future created out of its unique heritage. Natural England supports Option 8.5 ‘Develop new cycle and Support pedestrian routes along green corridors away from main roads.’ welcomed. Walking and cycling networks can provide important elements of

106 Natural England Options 8 Green Infrastructure, which is integral in securing connectivity for wildlife and accessibility for people and is important not only in terms of environmental quality, but also in providing recreation and improving health. Whilst we welcome point 2 under Option 8 regarding the need to Support work with East Riding, to establish further transport projects which welcomed. See Yorkshire are beneficial to the city, it would also be useful if the bullet also A7.1 – A7.2. 241 Options 8 Forward highlighted the need for better joint working on spatial planning issues to ensure that development is located in accessible locations. ABP supports Option 3 in principle: Maximise the amount of freight Support carried by rail and water to reduce pressure on the A63 Castle welcomed. The Street. suggested option will be taken Associated 292 Options 8 As stated above, the Port of Hull has a vital role to play in the local, forward in the British Ports regional and national economy, offering benefits by providing next draft opportunities for the sustainable transport of goods and materials document. by rail and water which should be encouraged.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 135

Company / Section Section City Council ID Your response Organisation number title response In light of this, ABP are committed to increasing freight movements into and out of the port by rail and water. Also it is important to recognise that the movement of freight by road will continue to play an integral role in terms of the movement of freight out of the Port of Hull.

More specifically, effective transport links to ports are more important than ever for securing business and prosperity in an increasingly globalised economy. Inefficient road access to ports can only damage competitiveness, jobs and economic growth. However, access is becoming an increasingly significant issue for ABP’s port operations at Hull. As such, ABP consider that improvement to the A63 is of critical importance to the future growth and success of their port operations at Hull, as well as the wider regeneration of the city.

The Hull City Centre Area Action Plan identifies the constraints of the A63 Trunk Road on new development and existing uses, and sets out the delivery of a package of short term measure to improve the capacity of the A63. The Yorkshire and Humber Regional Spatial Strategy also states that the A63(T) Trunk Road is ‘the key road access to the Port of Hull’, and its improvement to serve the port is identified as a transport investment priority.

As such, the capacity of the A63 Castle Street, and the continued future improvement of this is vital to avoid restrictions to the future growth of the Port of Hull and the regeneration of the city as a whole. More specifically, it is vital that much needed additional highways capacity is created and bottlenecks to through traffic are reduced. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 136

Company / Section Section City Council ID Your response Organisation number title response

It is therefore requested that a revised option is taken forward for Objective 8 as set out below: “Maximising the amount of freight carried by rail and water, and prioritising future improvements to the A63 Castle Street to address capacity issues restricting the growth of the Port of Hull and the regeneration of the city as a whole.” We support all the Options, but would point out with reference to Support Option 5 that cycling is not only a leisure activity, it is also a rapid welcomed. means of door-to-door transport; cycle routes need to lead to where Local resident 206 Options 8 people want to go, over the shortest distance possible. City planners have had a regrettable tendency to put cycle routes where there is space, rather than where there is need. This must be restrained. Although schemes such as light rail, trams or guided buses may not Noted, although be viable in the immediate future, it would be sensible to reserve there is limited land and plan developments around likely routes accordingly. For scope to reserve example, it might be appropriate to situate the proposed Northern land for strategic Park & Ride site within reach of the existing railway line in case it routes without could one day be used as part of a light rail or tram system. adequate evidence. Hull & Humber Equally, the routes of former railway lines should be protected in 300 Chamber of Options 8 case they could eventually be utilised again. Commerce

Waterfront development is important for making the city a desirable place to live and work, but consideration should also be given to the possibilities of increased freight and passenger transport on inland waterways. It may be appropriate to reserve some land accordingly or consider prior to developments how the waterfront could be adapted in the future.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 137

Company / Section Section City Council ID Your response Organisation number title response

The options do not consider how unnecessary journeys could be reduced. For example, the school run could be tackled in a number of ways including restrictions on parking and stopping around schools; or better provision for storing bicycles at schools. Taking advantage of the opportunities available through BSF, the last option in particular could perhaps be tackled through the planning system by requiring a certain level of provision at new builds and refurbishments.

Further to options 4 and 5, it should be noted that not all employers are able to offer their employees bicycle parking facilities. Being able to securely park a bicycle will have an impact on a person's decision to use it to travel to work, it would be sensible to look at improving provision at strategic locations such as park and ride sites and the city centre. In certain circumstances it may also be appropriate to encourage developers through the planning system to provide secure bicycle storage facilities at new commercial and residential developments. The transport system will require significant improvement, Noted. The especially if the aspirational Scenario C is to become a realistic Highways option. It is surprising that the document does not refer to the Agency will be Highways Agency and the major issue surrounding junction and referred to as a East Riding of highway capacity on the A63 (the Highways Agency is not key delivery 458 Options 8 Yorkshire Council mentioned in the chapter, even as a key delivery agent). agent.

There is no reference to how public transport (other than mention of several park and ride schemes) will be improved to help deliver increased growth.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 138

Company / Section Section City Council ID Your response Organisation number title response

It is unclear whether retaining a route for the Eastern Relief Road is Noted and further still a priority for the City Council. It would be helpful if the City work around Council could confirm whether it expects a route to be retained in urban extensions the East Riding LDF. This can then be considered through the East might require Riding Allocations DPD. this.

The possible park and ride sites appear like allocations on the Key Diagram. As an alternative perhaps these could be shown as ‘corridors to benefit from park and ride facilities’. It is appreciated that potential sites may be identified within both the Hull and East Riding boundaries. Only those certain to be delivered within the plan period should be identified in the HDF. It would be helpful if any park and ride sites within the East Riding of Yorkshire are identified as soon as possible so that they can be considered in the East Riding Allocations DPD.

East Riding of Yorkshire Council supports joint working in relation to major transport schemes and issues. However, the document should also recognise that schemes of major importance to the city will also fall outside of the city boundary (such as the A63, A164 and A1079).

In relation to Options 3 it should also be noted that the East Riding Core Strategy Issues and Options identified an option to safeguard a rail route from the Hull dock branch line to the allocated employment area at Saltend/Hedon Haven. If this option is included within the East Riding Preferred Options Core Strategy it will also need to be referenced within the HDF.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 139

Company / Section Section City Council ID Your response Organisation number title response The Highways Agency are considering long term options for the A63 (Castle Street) but these are too detailed Is it appropriate to include any options referencing long term for inclusion in 410 Hull Forward Options 8 solution for the A63? the Core Strategy. The HA will be carrying out its own consultation including assessing scheme viability. Noted, although there is a need to Infrastructure take a city wide and CIL - should refer to AAPs as mechanism for determining need for 51 Gateway perspective in development and use of CIL in AAP areas. terms of an funding approach to CIL. See also A11.1. Noted and Infrastructure Green infrastructure can contribute towards the natural potential for this and environments adaptation to climate change. Suggest that need to will be 107 Natural England development include reference to green infrastructure as part of para A.76 list of considered as funding items to be considered for CIL. part of a local study. See also

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 140

Company / Section Section City Council ID Your response Organisation number title response A11.1. Para. A.76. WLL have no objection to the provision of planning gain Noted. See also through a section 106 legal agreement where the obligations A11.1. contained therein are:

– relevant to planning;

– necessary to make the proposed development acceptable in planning terms;

– directly related to the proposed development;

– fairly and reasonably related in scale and kind to the development Infrastructure proposed Wrenbridge Land and 149 Limited development – reasonable in all other respects. funding

As the emerging Core Strategy recognises (para. A76) there needs to be further consideration regarding the use of both planning obligations and any Community Infrastructure Levy throughout the lifetime of the Core Strategy, cognisant of the wider national debate.

A key concern, however, is that any levy would meet the above tests and, when paid into a central fund, infrastructure would be provided in a timely manner cognisant of each site's development programme. WLL look forward to working with the Council in the formulation of this most important element of policy.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 141

Company / Section Section City Council ID Your response Organisation number title response In terms of infrastructure and development funding, we support the Support view of the Planning Obligations Circular 05/2005 which states that welcomed. Infrastructure ‘a planning obligation must be: (i) relevant to planning; (ii) Tesco Stores and 325 necessary to make the proposed development acceptable in Limited development planning terms; (iii) directly related to the proposed development; funding (iv) fairly and reasonably related in scale and kind to the proposed development; and (v) reasonable in all other respects.’ Para. A.76. We support a policy in the Core Strategy for a general Noted. See also approach to Planning Obligations with appropriate references to A11.1. Infrastructure strategic sites and clear links to the details set out in an The Theatres and supplementary planning document but is important that the future 191 Trust development development of infrastructure for community and cultural activities funding is also identified within the list at A.76. Investing time and resources in an SPD will set down clearly what is required of the developer and other funding partners. Infrastructure Para A.76. Sport England welcomes the specific reference to sport Noted. See also and made here, recognising the fundamental role that sport and A11.1. 176 Sport England development recreation can play in helping to deliver a good quality of life in the funding City. In relation to objective 9, development contributions to any such Noted. See also Tesco Stores Objective 326 infrastructure need to be properly justified, so as to be reasonable A11.1. Limited 9 and related in scale. Options 9 relate to infrastructure and development. The objective is Noted. See also to secure infrastructure necessary for the sustainable development A11.1. of the City. The option makes reference to the proposed new 47 Barratt Homes Options 9 Community Infrastructure Levy (CIL) which is expected to be introduced by the Government in the near future. At this stage, until the details of the CIL are known, it is impossible to consider this as

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 142

Company / Section Section City Council ID Your response Organisation number title response a realistic option at this time.

Further to the above, Paragraph A.80 of the document identifies that effective measures are already in place in respect of planning obligations, open space/recycling facilities and City Centre infrastructure. We therefore believe that these measures will cater for the needs of the City until further guidance is issued by the government in respect of the CIL. Options 9 relate to infrastructure and development. The objective is Noted. See also to secure infrastructure necessary for the sustainable development A11.1. of the City. The option makes reference to the proposed new Community Infrastructure Levy (CIL) which is expected to be introduced by the Government in the near future. At this stage, until the details of the CIL are known, it is impossible to consider this as a realistic option at this time. 80 Kayterm Ltd Options 9

Further to the above, Paragraph A.80 of the document identifies that effective measures are already in place in respect of planning obligations, open space/recycling facilities and City Centre infrastructure. We therefore believe that these measures will cater for the needs of the City until further guidance is issued by the government in respect of the CIL. Options 9 relate to infrastructure and development. The objective is Noted. See also to secure infrastructure necessary for the sustainable development A11.1. Kingswood Parks of the City. The option makes reference to the proposed new

117 Development Options 9 Community Infrastructure Levy (CIL) which is expected to be Company introduced by the Government in the near future. At this stage, until the details of the CIL are known, it is impossible to consider this as a realistic option at this time.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 143

Company / Section Section City Council ID Your response Organisation number title response PPS12 requires Core Strategies to be supported by evidence of Noted. See also what physical, social and green infrastructure is needed to enable A11.1. Cross the amount of development proposed for the area. Therefore the boundary most appropriate way forward would be to prepare an infrastructure working is being assessment to identify the social, physical and environmental supported. East Riding of infrastructure required to meet the preferred growth scenario. This 459 Options 9 Yorkshire Council would be the basis for setting charges through the Community Infrastructure Levy, taking into account viability.

East Riding of Yorkshire Council will commence an infrastructure assessment shortly. This will need to take into account a number of cross-boundary issues. There may be merit in strengthening existing policies on design, or Noted. developing a separate design principles policy, as this would give additional support to the investments currently being made in Hull Yorkshire 238 B. Quality of life to achieve an improved urban environment, and would help to Forward support Objective 6 B (i) of the RES, which seeks to ‘deliver high quality, integrated renaissance activities in all our major cities and town’s, including Hull ’. The Assembly is encouraged that paragraph B.5 makes reference Noted. Net/gross to the fact that RSS sets an overall housing requirement for Hull provision will be between the years 2004 and 2026 as being around 24,000 gross referred to in the dwellings. However, there is no reference made to the RSS figures next draft, which Yorkshire and for net addition in Hull. RSS policy H1 deals with the provision and takes account of 360 Humber B. Quality of life distribution of housing. Table 12.1 confirms an annual average net housing Assembly addition to the dwelling stock of Hull up to 2026 of 880 dwellings demolitions. per annual. It is also worth noting that Table 12.1 also confirms that an annual average net addition to the dwelling stock of East Riding up to 2026 of 1150 dwelling per annum from 2008 - 2026 (of which

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 144

Company / Section Section City Council ID Your response Organisation number title response 40% of this housing provision should be provided within the Hull housing market area). Page 72. Gateway supports using the HMA range of housing Support numbers (i.e. planning for this level of flexibility) and not accepting welcomed. See RSS or the even higher number that they may come up with next also A2.1 – A2.6. draft.

Page 74. Should refer to demolitions creating sites for building Noted. back.

Table B.3 of new housing no's is very arbitrary. NaSA is based on These figures will AAP but East Hull certainly needs to have the potential to be higher be reviewed as if you consider the opportunity to build back in some of these areas part of the to higher density, which will inherently make them more sustainable housing Future housing and provide mix. 'Other' should be phrased as other regeneration availability study provision – 52 Gateway areas not just Gateway. We support phased release outlined in and AAP overall scale B.18. progress. and distribution

Table B3. Change phrases 'other Gateway priority areas'. Possibly These figures will show a range for east Hull - 2,000 is very rounded and the AAP be reviewed as isn't done yet. Low densities here mean we might build back part of the considerably more than we demolish. housing availability study and AAP progress.

Page 78. Could also include for regeneration of outer estates as Noted. 'urban villages' as mentioned above.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 145

Company / Section Section City Council ID Your response Organisation number title response Para.B.21. Change phrase 'other Gateway priority areas'. Suggest Noted. need to consider intensification/consolidation of core specifically before urban extensions.

Para.B.25/26. Doesn't refer to stepped approach set out earlier. Noted and phasing will be referred to in this section of the next draft. The Hull City Local Development Framework (LDF) must have Noted. RSS also regard to the provisions of the Regional Spatial Strategy for allows for more Yorkshire and the Humber (RSS) which has recently been up to date local approved by the Secretary of State. interpretation provided this is in The RSS identifies Hull as a Regional City (Policy YH4 and HE1) general which should be a prime focus for housing, employment, shopping, conformity. See leisure, education, health and cultural activities in the region. also A2.1 – A2.6. Future housing provision – Policy H1 of the RSS requires an increase in the average annual 58 Barratt Homes overall scale dwelling stock in the City to 1,200 dwellings/annum from 2008. This and distribution requires a significant increase in past rates of completion, the achievement of which the City Council acknowledge will be challenging. However, in order to ensure Hull’s role as a Regional City it is important that this challenge is met. Policy H2 of the RSS is clear that in responding to and managing the need for the significant ‘step change’ in housing delivery, LPA’s should not treat the housing figures as ceilings.

The importance of meeting the requirements of the RSS is set out

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 146

Company / Section Section City Council ID Your response Organisation number title response in national planning policy. Planning Policy Statement 12 states that Core Strategies should include:

“(1) an overall vision which sets out how the area and the places within it should develop;

(2) strategic objectives for the area focussing on the key issues to be addressed;

(3) develop a strategy for achieving these objectives. This should set out how much development is intended to happen where, when, and by what means it will be delivered. Locations for strategic development should be indicated on a key diagram; and,

(4) clear arrangements for managing and monitoring the delivery of the strategy” (para. 4.1)

With regard to Regional Spatial Strategies, PPS12 states: “The vision should be in general conformity with the RSS” (para. 4.2).

The RSS is clear that it is an expectation that LPAs will work to deliver the housing numbers allocated to them. Within this context, we provide representations to the Issues and Options Paper of the Hull Local Development Framework Core Strategy in the proceeding sections, examining the most relevant options raised by the City Council.

Of key importance is our view that the LPA must adopt the same housing figures as are set out in RSS to ensure the plan passes the soundness test. Whilst Housing Market Assessments can inform Response to the Hull Core Strategy issues and options report, June 2008 October 2008 147

Company / Section Section City Council ID Your response Organisation number title response specific issues of housing need (in respect of affordability or particular locations within an authority with a greater need), it is not the role of HMAs to inform strategic need and overall housing numbers at the local level. PPS3, PPS12 and RSS all require the Core Strategy to be in conformity with RSS. As such, the LPA should plan to deliver the full 1200 dwellings per annum in Hull. The Hull City Local Development Framework (LDF) must have Noted. RSS also regard to the provisions of the Regional Spatial Strategy for allows for more Yorkshire and the Humber (RSS), which has recently been up to date local approved by the Secretary of State. interpretation provided this is in The RSS identifies Hull as a Regional City (Policy YH4 and HE1) general which should be a prime focus for housing, employment, shopping, conformity. See leisure, education, health and cultural activities in the region. also A2.1 – A2.6.

Policy H1 of the RSS requires an increase in the average annual Future housing dwelling stock in the City to 1,200 gross dwellings per annum from provision – 90 Kayterm Ltd 2008. This requires a significant increase in past rates of overall scale completion, the achievement of which the City Council and distribution acknowledge will be challenging. However, in order to ensure Hull’s role as a Regional City it is important that this challenge is met. Policy H2 of the RSS is clear that in responding to and managing the need for the significant ‘step change’ in housing delivery, LPA’s should not treat the housing figures as ceilings.

The importance of meeting the requirements of the RSS is set out in national planning policy. Planning Policy Statement 12 states that Core Strategies should include:

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 148

Company / Section Section City Council ID Your response Organisation number title response “(1) an overall vision which sets out how the area and the places within it should develop;

(2) strategic objectives for the area focussing on the key issues to be addressed;

(3) develop a strategy for achieving these objectives. This should set out how much development is intended to happen where, when, and by what means it will be delivered. Locations for strategic development should be indicated on a key diagram; and,

(4) clear arrangements for managing and monitoring the delivery of the strategy” (para. 4.1).

With regard to Regional Spatial Strategies, PPS12 states:

“The vision should be in general conformity with the RSS” (para. 4.2).

The RSS is clear that it is an expectation that LPAs will work to deliver the housing numbers allocated to them. Within this context, we provide representations to the Issues and Options Paper of the Hull Local Development Framework Core Strategy in the proceeding sections, examining the most relevant options raised by the City Council.

Of key importance is our view that the LPA must adopt the same housing figures as are set out in RSS to ensure the plan passes the soundness test. Whilst Housing Market Assessments can inform specific issues of housing need (in respect of affordability or Response to the Hull Core Strategy issues and options report, June 2008 October 2008 149

Company / Section Section City Council ID Your response Organisation number title response particular locations within an authority with a greater need), it is not the role of HMAs to inform strategic need and overall housing numbers at the local level. PPS3, PPS12 and RSS all require the Core Strategy to be in conformity with RSS. As such, the LPA should plan to deliver the full 1200 gross dwellings per annum in Hull. The Hull City Local Development Framework (LDF) must have Noted. RSS also regard to the provisions of the Regional Spatial Strategy for allows for more Yorkshire and the Humber (RSS12) which has recently been up to date local approved by the Secretary of State. interpretation provided this is in The RSS identifies Hull as a Regional City (Policy YH4 and HE1) general which should be a prime focus for housing, employment, shopping, conformity. See leisure, education, health and cultural activities in the region. also A2.1 – A2.6.

Policy H1 of the RSS requires an increase in the average annual Future housing Kingswood Parks dwelling stock in the City to 1,200 dwellings/annum from 2008. This provision – 127 Development requires a significant increase in past rates of completion, the overall scale Company achievement of which the City Council acknowledge will be and distribution challenging. However, in order to ensure Hull’s role as a Regional City it is important that this challenge is met. Policy H2 of the RSS is clear that in responding to and managing the need for the significant ‘step change’ in housing delivery, LPA’s should not treat the housing figures as ceilings.

The importance of meeting the requirements of the RSS is set out in national planning policy. Planning Policy Statement 12 states that Core Strategies should include:

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 150

Company / Section Section City Council ID Your response Organisation number title response “(1) an overall vision which sets out how the area and the places within it should develop;

(2) strategic objectives for the area focussing on the key issues to be addressed;

(3) develop a strategy for achieving these objectives. This should set out how much development is intended to happen where, when, and by what means it will be delivered. Locations for strategic development should be indicated on a key diagram; and,

(4) clear arrangements for managing and monitoring the delivery of the strategy” (para. 4.1).

With regard to Regional Spatial Strategies, PPS12 states: “The vision should be in general conformity with the RSS” (para. 4.2).

The RSS is clear that it is an expectation that LPAs will work to deliver the housing numbers allocated to them. Within this context, we provide representations to the Issues and Options Paper of the Hull Local Development Framework Core Strategy in the proceeding sections, examining the most relevant options raised by the City Council. Noted. RSS also Future housing Para B.5: RSS figures are completely unrealistic. People are allows for more Friends of provision – deserting Hull, not coming to it, and this fact will not change no up to date local 249 Pearson Park overall scale matter how many new dwellings are built. There are huge over interpretation and distribution estimates here. provided this is in general

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 151

Company / Section Section City Council ID Your response Organisation number title response conformity. See also A2.1 – A2.6. Government Future housing SHLAA is being Office for provision – Paras B.9-B.13. What is the position with the SHLAA? It is a key commissioned 279 Yorkshire and the overall scale part of the evidence base yet there is no reference to it in the text. and will inform Humber and distribution the next draft. Government Future housing See A10.1. Office for provision – Para B.14. Needs updating. CS’s can show broad locations on a 282 Yorkshire and the overall scale key diagram but can also show allocations on a proposals map. Humber and distribution Para B.28. East Riding of Yorkshire Council is not viewed as a key Noted and Future housing delivery agent. This is surprising given the suggestion that East changes will be East Riding of provision – 461 Riding should restrain housing land supply in its part of the Hull made to reflect Yorkshire Council overall scale housing market area and possibly help meet the city’s requirements this. and distribution by allocating land at the edge of the city. One of the key housing sites for Hull is Kingswood, which currently Noted. benefits from outline planning permission. Whilst we appreciate that Kingswood the principle for development here has already been agreed, we developers are in feel it is necessary to reiterate the significant risks this area is discussions with facing from flooding. The area is low lying and is in the highest the EA Future housing flood risk zone (Flood Zone 3a iii) shown in the Hull SFRA. concerning Environment provision – 388 engineering Agency overall scale This high level of risk is due to its proximity to the River Hull solutions to and distribution defences, and therefore the risk of rapid and deep inundation in the minimise flood event of failure of the River Hulls banks. Work by Halcrow as part of risks. Suggested the SFRA shows this area of Kingswood could be flooded up to policy approach 1.5m depth in the event of failure/breach of the earthen is to require a embankments of the River Hull. The Kingswood area also suffered detailed flood risk

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 152

Company / Section Section City Council ID Your response Organisation number title response from flooding as a result of drainage problems in the Summer 2007 assessment for event. any further development We suggest that a drainage strategy be produced to manage within high risk surface water run-off in the area on a strategic scale, as well as any areas. requirements needed to achieve the Code for Sustainable Homes standards. Flood proofing and resilience measures should be incorporated into the design of new buildings. From discussions held with other social housing providers - Noted. Housing including the Kingston upon Hull City Council - it would appear that vacancies are housing waiting lists in the city are increasing - not decreasing. taken into Pickering and Ferens Homes now has a housing waiting list of over account in Future housing 700. The Kingston upon Hull City Council has a waiting list of assessing future Pickering and provision – 469 approximately 14,000. This situation is going to worsen - with more needs. Ferens Homes overall scale residents of the city wishing to apply for accommodation as the and distribution 'credit crunch' continues. Consequently, we should not have a phased "low start stepped approach" - but rather attempt to construct additional properties in the city - in order to help alleviate the present housing difficulties in the city. No matter the housing; it is not the main reason why people would Noted. move here; first comes the chance for employment and second the Friends of Objective quality of life depicted in crime & education figures. The apartments 250 Pearson Park 10 already being built and due to be built in the City Centre are doomed to remain empty as there are not enough young single professionals in the city to fill them. In respect of objective 10, we do not consider that the wording set Noted although Kingswood Parks Objective out in the Issues and Options Paper to “provide a suitable scale, the additional 427 Development 10 distribution and phasing of housing to meet the city’s future needs,” wording is not Company is precise enough. We consider that this objective should be considered to Response to the Hull Core Strategy issues and options report, June 2008 October 2008 153

Company / Section Section City Council ID Your response Organisation number title response broadened as follows: “Provide a suitable scale, distribution and add any further phasing of housing to meet the city’s future needs, in line with RSS precision. requirements.” Objective Noted. 413 Hull Forward Add ‘balanced with and complementing employment provision’? 10 In respect of objective 10, we do not consider that the wording set Noted although out in the Issues and Options Paper to “provide a suitable scale, the additional distribution and phasing of housing to meet the city’s future needs,” wording is not Objective 425 Barratt Homes is precise enough. We consider that this objective should be considered to 10 broadened as follows: “Provide a suitable scale, distribution and add any further phasing of housing to meet the city’s future needs, in line with RSS precision. requirements.” In respect of objective 10, we do not consider that the wording set Noted although out in the Issues and Options Paper to “provide a suitable scale, the additional distribution and phasing of housing to meet the city’s future needs,” wording is not Objective 426 Kayterm Ltd is precise enough. We consider that this objective should be considered to 10 broadened as follows: “Provide a suitable scale, distribution and add any further phasing of housing to meet the city’s future needs, in line with RSS precision. requirements.” In terms of the overall scale of housing the Council are considering See A2.1 – A2.6. whether to allocate land for 1,200 new dwellings per annum in It is clear there is accordance with the requirement of the RSS or, alternatively, to a need to allocate 1,000 new dwellings per year in line with the housing adequately Options 48 Barratt Homes market assessment. As set out above, we consider that it is vital assess the extent 10 that provision is made in accordance with the RSS at a rate of of future housing 1,200 dwellings per annum. needs across the city and wider We note that Table B.2 of the Options and Issues Paper shows that market area. The

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 154

Company / Section Section City Council ID Your response Organisation number title response allocations totalling 9,320 dwellings are required. This allocation is, City Council’s however, based on the Housing Market Assessment (HMA) rather HMA was than the RSS requirement for Hull. We consider that the RSS completed after should provide the basis for the annual housing requirement in the RSS was finally City. agreed. The Council takes a The Core Strategy justifies this lower level on the basis that: “Over more pragmatic the period to 2026, RSS sets out housing requirements to be view on the use achieved in Hull, although it recognises that more up to date of more up to information can be used to determine a particular direction.” date and local information on However, there is no such allowance in the CLG Guidance for future housing Housing Market Assessments to allow HMA’s to override RSS requirements. requirements. The most up to date guidance from CLG (Strategic The City Council Housing Market Assessments – Practice Guidance Version 2, is following August 2007) is clear in stating:- “The Value of Strategic housing Government market assessments is in assisting policy development, decision- policy in moving making and resource-allocation processes by: away from a ‘predict and • Enabling regional bodies to develop long-term strategic views of provide’ to a housing need and demand to inform regional spatial strategies and ‘plan, monitor regional housing strategies; and manage’ approach in • Enabling local authorities to think spatially about the nature and meeting housing influence of the housing markets in respect to their local area;” (p7) requirements while being in The guidance from CLG is clear in that the assessment of overall general need and demand from HMAs is only intended to inform the conformity with regional planning bodies with respect to reviews of the RSS. It is for RSS. RSS is also the RSS to set housing levels, and it is for the review of the RSS to being reviewed Response to the Hull Core Strategy issues and options report, June 2008 October 2008 155

Company / Section Section City Council ID Your response Organisation number title response amend the requirements rather than the HMA. The HMAs are only following intended to inform the ‘spatial interpretation’ of the housing need as concerns about set out by RSS. Whilst HMAs can discuss ‘need’ at the local level, the current this is only in respect of the need for affordable housing, need market downturn. within sub areas and the need for housing for specific groups. Rates of actual There is no allowance for LPA’s to consider the overall strategic demolitions are housing requirement independently of the RSS. also far less than originally The RSS assumes that LDFs will automatically adopt the housing estimated by numbers it sets out, without further assessment of the overall need Gateway when and demand. Policy H1 of RSS states clearly that: “Plans, the RSS was strategies, programmes and investment decisions should ensure drafted which the delivery of the average annual net additions to the dwelling has a major stock set out in Table 12.1 in locations that accord with the Core influence on Approach and Sub Area policies, taking account of indicative timing overall housing set out in Table 12.2.” requirements. The housing land Although HMAs need to be carried out and taken account of (RSS assessment also para. 12.2) no allowance is provided in the RSS for HMAs to needs effectively set a lower housing delivery target. The RSS supporting completing which text is clear that the figures in RSS Table 12.1 provide a ‘framework helps determine for LDFs’. In particular, RSS states that the figures ‘reflect higher the supply side levels of growth that now need to be planned for’, rather than being and a housing a mere reflection of the market and net build rates up to 2008 (para. development 12.4). Indeed, the RSS clearly states that housing figures are not trajectory. based on what has gone before: “This means that the annual average housing growth figures set out in Table 12.1 represent a significant shift away from what has happened in the past in some parts of the region” (Para. 12.6).

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 156

Company / Section Section City Council ID Your response Organisation number title response Only Table 12.2 of the RSS, which sets the timing for growth, is noted as being ‘indicative’. Meanwhile, with regard to Table 12.1 and Policy H1, which set the housing level for Hull at a rate of 1,200 dwellings per year, post 2008, Policy H2 states: “To support the step-up in the delivery of new homes required by policy H1 and to ensure that new homes are in locations that accord with the Plan’s Core Approach and Sub-Area Policies:………….

(B) LPAs should identify and manage the release of land to maintain the momentum of urban transformation … by:……….

5. Adopting a flexible approach to delivery by not treating housing figures as ceilings …” (our emphasis).

Policy H2 is consistent in setting out that the housing figures set out by the RSS are the minimum that should be ‘required’ and should not be treated as ‘ceilings’. Therefore, whilst there is support for LPAs to exceed these figures, there is no policy allowance for LPAs to effectively plan to meet a lower target, disregarding the Development Plan requirement, as set out in RSS. It is not the role of HMAs to set housing targets, since it is clear that the RSS targets have not been set in response to market demand, but as a driver for planned economic growth in the region, and therefore, by definition, this cannot be a response to market conditions and assessments.

Whilst the RSS does require LPAs to work collaboratively to provide HMAs in line with PPS3 (para. 12.2), PPS3 is clear that it is for the RSS to set the level of housing provision and to allocate housing requirements to Local Authority areas: “RSS should set out Response to the Hull Core Strategy issues and options report, June 2008 October 2008 157

Company / Section Section City Council ID Your response Organisation number title response the level of overall housing provision for the region, broadly illustrated in a housing delivery trajectory, for a sufficient period to enable LPAs to plan for housing over a period of at least 15 years. This should be distributed amongst constituent housing market and Local Planning Authority areas.” (PPS3 para. 34).

Accordingly PPS3 requires LPAs to provide LDF development plan documents which ‘set out a strategy for the planned location of new housing which contributes to the achievement of sustainable development’ taking into account ‘objectives set out in the relevant RSS’ (PPS3 para. 38). Since the RSS for Yorkshire and Humber has been approved by the Secretary of State and has been published in its final form, we consider that not adopting the housing numbers set out in RSS would fundamentally undermine the soundness of the Core Strategy and, therefore, the entire LDF.

We note that the LPA claim that following the findings of the ‘more up to date Housing Market Assessment’, which claims that there is no demand for the level of housing required by RSS. However, both RSS (para. 12.2) and PPS 3 are clear that any changes to market conditions should inform a review of RSS, rather than at the LDF level: “In circumstances where market conditions have changed, it may also be necessary to reassess need and demand, considering a review of approach across the housing market area and/or initiating a partial review of the RSS to update the local level of housing provision.” (PPS3 Para. 66)

There is no allowance in PPS3 for HMAs to amend the level of housing requirement. Annex C of PPS 3 states, rather, that the role of HMAs should be to (1) estimate the need and demand in terms Response to the Hull Core Strategy issues and options report, June 2008 October 2008 158

Company / Section Section City Council ID Your response Organisation number title response of the proportion of affordable and the proportion of market housing (rather than the overall need, per se), (2) determine how the distribution of need and demand varies across the plan area and (3) consider future demographic trends to identify the accommodation requirements of specific groups (e.g. key workers, the elderly, the disabled) rather than the total population. PPS3 envisages that Housing Market Assessments should consider how the needs of the local population should impact on the delivery of the housing numbers required at the strategic level, as set out in the RSS. In this way, LPAs are required to take account of HMAs in the formation of LDFs and determining how and where the RSS housing numbers will be delivered. Adopting a lower housing target altogether, in response to an HMA, would be an attempt by the LPA to move beyond the remit of how an HMA can inform an LDF, as set out in PPS3. As such, we consider that option 10 (A) (2) to be entirely unsound.

In view of the above, we support option 10 (A) (1) as the only sound option in terms of the overall scale of housing delivery. Consequently, as the indicative figures for further housing allocations identified within Table B.2 (9,320 dwellings) are based on the housing requirements identified within the HMA, in order for the City to meet the housing requirements of the RSS the Council will need to provide for a total of 14,920 dwellings through the LDF, 5,600 more dwellings than that identified within Table B.2. This level of provision will most definitely require that the Council release greenfield land, urban extensions and urban greenspace (where appropriate) for future housing development.

In respect of the future distribution of housing, we support all of the Response to the Hull Core Strategy issues and options report, June 2008 October 2008 159

Company / Section Section City Council ID Your response Organisation number title response options set out in 10B. However, in addition to identifying specific areas in which future housing in the City is to be distributed, it is considered that text should be included to enable the allocation of future housing sites in all areas of the City where sufficient evidence is presented that a site is either:-

• Deliverable – a site is available now, offers a suitable location for housing development now and there is a reasonable prospect that housing will be delivered on the site within five years from the date of adoption of the plan; and

• Developable – a site should be in a suitable location for housing development, and there should be a reasonable prospect that it will be available for and could be developed at a specific point in time.

Such an approach will allow for the allocation of suitable housing sites to meet the needs of the whole the City rather than simply within identified areas.

In the context of option 10 (B) (3), the expansion of the City’s edges through the allocation of housing land within the East Riding of Yorkshire would help to alleviate the existing land supply constraints of the City. As discussed above, though this approach can be supported in principal, for this approach to be considered viable it would require approval from the East Riding of Yorkshire Council and would need to be incorporated within the current housing review being undertaken by the Government Office for Yorkshire and The Humber. In order to substantiate the City Council’s assertion that there is not enough available land within the City’s boundaries to meet the RSS housing requirements, Response to the Hull Core Strategy issues and options report, June 2008 October 2008 160

Company / Section Section City Council ID Your response Organisation number title response robust and justifiable evidence should be presented within future revisions of the Core Strategy to demonstrate this.

In terms of phasing, options suggested involve continuing with current allocations to 2014, focusing on the previously developed sites to 2026 and only considering further urban extensions beyond 2021, once all other opportunities are exhausted.

As there is no justifiable evidence set out within the Core Strategy to demonstrate that the estimated figures within the table are deliverable, there is no assurance that the identified phasing approach within Option 10 (C) will provide and maintain the delivery of housing within the City to meet the RSS housing figures.

Consequently, further evidence should be presented within future revisions of the Core Strategy to demonstrate that the housing figures identified within Table B.3 are capable of being delivered. As discussed above, the delivery of the proposed housing numbers identified within Tables B.2 and B.3 of the Core Strategy would result in a short fall of 5,600 dwellings in the City when measured against the requirements of the adopted RSS. Therefore, should the Council fail to deliver the housing potential identified within these tables this would increase the housing shortfall and compound the current housing issues of the City. In terms of the overall scale of housing the Council are considering See A2.1 – A2.6. whether to allocate land for 1,200 new dwellings per annum in It is clear there is Options 81 Kayterm Ltd accordance with the requirement of the RSS or, alternatively, to a need to 10 allocate 1,000 new dwellings per year in line with the housing adequately market assessment. As set out above, we consider that it is vital assess the extent

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 161

Company / Section Section City Council ID Your response Organisation number title response that provision is made in accordance with the RSS at a rate of of future housing 1,200 dwellings per annum. needs across the city and wider We note that Table B.2 of the Options and Issues Paper shows that market area. The allocations totalling 9,320 dwellings are required. This allocation is, City Council’s however, based on the Housing Market Assessment (HMA) rather HMA was than the RSS requirement for Hull. We consider that the RSS completed after should provide the basis for the annual housing requirement in the RSS was finally City. agreed. The Council takes a The Core Strategy justifies this lower level on the basis that: “Over more pragmatic the period to 2026, RSS sets out housing requirements to be view on the use achieved in Hull, although it recognises that more up to date of more up to information can be used to determine a particular direction.” date and local information on However, there is no such allowance in the CLG Guidance for future housing Housing Market Assessments to allow HMA’s to override RSS requirements. requirements. The most up to date guidance from CLG (Strategic The City Council Housing Market Assessments – Practice Guidance Version 2, is following August 2007) is clear in stating:- Government policy in moving “The Value of Strategic housing market assessments is in assisting away from a policy development, decision-making and resource-allocation ‘predict and processes by: provide’ to a ‘plan, monitor • Enabling regional bodies to develop long-term strategic views of and manage’ housing need and demand to inform regional spatial strategies and approach in regional housing strategies; meeting housing requirements • Enabling local authorities to think spatially about the nature and while being in Response to the Hull Core Strategy issues and options report, June 2008 October 2008 162

Company / Section Section City Council ID Your response Organisation number title response influence of the housing markets in respect to their local area;” (p7) general conformity with The guidance from CLG is clear in that the assessment of overall RSS. RSS is also need and demand from HMAs is only intended to inform the being reviewed regional planning bodies with respect to reviews of the RSS. It is for following the RSS to set housing levels, and it is for the review of the RSS to concerns about amend the requirements rather than the HMA. The HMAs are only the current intended to inform the ‘spatial interpretation’ of the housing need as market downturn. set out by RSS. Whilst HMAs can discuss ‘need’ at the local level, Rates of actual this is only in respect of the need for affordable housing, need demolitions are within sub areas and the need for housing for specific groups. also far less than There is no allowance for LPA’s to consider the overall strategic originally housing requirement independently of the RSS. estimated by Gateway when The RSS assumes that LDFs will automatically adopt the housing the RSS was numbers it sets out, without further assessment of the overall need being drafted and demand. Policy H1 of RSS states clearly that: “Plans, which has a strategies, programmes and investment decisions should ensure major influence the delivery of the average annual net additions to the dwelling on overall stock set out in Table 12.1 in locations that accord with the Core housing Approach and Sub Area policies, taking account of indicative timing requirements. set out in Table 12.2.” The housing land assessment also Although HMAs need to be carried out and taken account of (RSS needs para. 12.2) no allowance is provided in the RSS for HMAs to completing which effectively set a lower housing delivery target. The RSS supporting helps determine text is clear that the figures in RSS Table 12.1 provide a ‘framework the supply side for LDFs’. In particular, RSS states that the figures ‘reflect higher and a housing levels of growth that now need to be planned for’, rather than being development a mere reflection of the market and net build rates up to 2008 (para. trajectory. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 163

Company / Section Section City Council ID Your response Organisation number title response 12.4). Indeed, the RSS clearly states that housing figures are not based on what has gone before: “This means that the annual average housing growth figures set out in Table 12.1 represent a significant shift away from what has happened in the past in some parts of the region” (Para. 12.6).

Only Table 12.2 of the RSS, which sets the timing for growth, is noted as being ‘indicative’. Meanwhile, with regard to Table 12.1 and Policy H1, which set the housing level for Hull at a rate of 1,200 dwellings per year, post 2008, Policy H2 states: “To support the step-up in the delivery of new homes required by policy H1 and to ensure that new homes are in locations that accord with the Plan’s Core Approach and Sub-Area Policies:

(B) LPAs should identify and manage the release of land to maintain the momentum of urban transformation … by:

5. Adopting a flexible approach to delivery by not treating housing figures as ceilings …” (our emphasis).

Policy H2 is consistent in setting out that the housing figures set out by the RSS are the minimum that should be ‘required’ and should not be treated as ‘ceilings’. Therefore, whilst there is support for LPAs to exceed these figures, there is no policy allowance for LPAs to effectively plan to meet a lower target, disregarding the Development Plan requirement, as set out in RSS. It is not the role of HMAs to set housing targets, since it is clear that the RSS targets have not been set in response to market demand, but as a driver for planned economic growth in the region, and therefore, by definition, this cannot be a response to market conditions and Response to the Hull Core Strategy issues and options report, June 2008 October 2008 164

Company / Section Section City Council ID Your response Organisation number title response assessments.

Whilst the RSS does require LPAs to work collaboratively to provide HMAs in line with PPS3 (para. 12.2), PPS3 is clear that it is for the RSS to set the level of housing provision and to allocate housing requirements to Local Authority areas: “RSS should set out the level of overall housing provision for the region, broadly illustrated in a housing delivery trajectory, for a sufficient period to enable LPAs to plan for housing over a period of at least 15 years. This should be distributed amongst constituent housing market and Local Planning Authority areas.” (PPS3 para. 34).

Accordingly PPS3 requires LPAs to provide LDF development plan documents which ‘set out a strategy for the planned location of new housing which contributes to the achievement of sustainable development’ taking into account ‘objectives set out in the relevant RSS’ (PPS3 para. 38). Since the RSS for Yorkshire and Humber has been approved by the Secretary of State and has been published in its final form, we consider that not adopting the housing numbers set out in RSS would fundamentally undermine the soundness of the Core Strategy and, therefore, the entire LDF.

We note that the LPA claim that following the findings of the ‘more up to date Housing Market Assessment’, which claims that there is no demand for the level of housing required by RSS. However, both RSS (para. 12.2) and PPS 3 are clear that any changes to market conditions should inform a review of RSS, rather than at the LDF level: “In circumstances where market conditions have changed, it may also be necessary to reassess need and demand, considering a review of approach across the housing market area and/or Response to the Hull Core Strategy issues and options report, June 2008 October 2008 165

Company / Section Section City Council ID Your response Organisation number title response initiating a partial review of the RSS to update the local level of housing provision.” (PPS3 Para. 66)

There is no allowance in PPS3 for HMAs to amend the level of housing requirement. Annex C of PPS 3 states that the role of HMAs should be to:-

• Estimate the need and demand in terms of the proportion of affordable and the proportion of market housing (rather than the overall need, per se);

• Determine how the distribution of need and demand varies across the plan area ;and,

• Consider future demographic trends to identify the accommodation requirements of specific groups (e.g. key workers, the elderly, the disabled) rather than the total population.

PPS3 envisages that Housing Market Assessments should consider how the needs of the local population should impact on the delivery of the housing numbers required at the strategic level, as set out in the RSS. In this way, LPAs are required to take account of HMAs in the formation of LDFs and determining how and where the RSS housing numbers will be delivered. Adopting a lower housing target altogether, in response to an HMA, would be an attempt by the LPA to move beyond the remit of how an HMA can inform an LDF, as set out in PPS3. As such, we consider that option 10 (A) (2) to be entirely unsound.

In view of the above, we support option 10 (A) (1) as the only sound Response to the Hull Core Strategy issues and options report, June 2008 October 2008 166

Company / Section Section City Council ID Your response Organisation number title response option in terms of the overall scale of housing delivery. We note that the indicative figures for further housing allocations identified within Table B.2 (9,320 dwellings) are based on the housing requirements identified within the HMA. Therefore, in order for the City to meet the housing requirements of the RSS, the Council will need to provide for a total of 14,920 dwellings through the LDF, 5,600 more dwellings than that identified within Table B.2. This level of provision will most definitely require that the Council release greenfield land, urban extensions and urban greenspace (where appropriate) for future housing development.

In respect of the future distribution of housing, we support all of the options set out in 10B. However, in addition to identifying specific areas in which future housing in the City is to be distributed, it is considered that text should be included to enable the allocation of future housing sites in all areas of the City where sufficient evidence is presented that a site is either:-

• Deliverable – a site is available now, offers a suitable location for housing development now and there is a reasonable prospect that housing will be delivered on the site within five years from the date of adoption of the plan; and

• Developable – a site should be in a suitable location for housing development, and there should be a reasonable prospect that it will be available for and could be developed at a specific point in time.

Such an approach will allow for the allocation of suitable housing sites to meet the needs of the whole the City rather than simply within identified areas. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 167

Company / Section Section City Council ID Your response Organisation number title response

In the context of option 10 (B) (3), the expansion of the City’s edges through the allocation of housing land within the East Riding of Yorkshire would help to alleviate the existing land supply constraints of the City. As discussed above, this approach is supported in principal. However, for this approach to be considered viable it would require approval from the East Riding of Yorkshire Council and would need to be incorporated within the current housing review of the RSS for Yorkshire and the Humber. In order to substantiate the City Council’s assertion that there is not enough available land within the City’s boundaries to meet the RSS housing requirements, robust and justifiable evidence should be presented within future revisions of the Core Strategy to demonstrate this.

In terms of phasing, options suggested involve continuing with current allocations to 2014, focusing on the previously developed sites to 2026 and only considering further urban extensions beyond 2021, once all other opportunities are exhausted.

As there is no justifiable evidence set out within the Core Strategy to demonstrate that the estimated figures within the table are deliverable, there is no assurance that the identified phasing approach within Option 10 (C) will provide and maintain the delivery of housing within the City to meet the RSS housing figures.

Consequently, further evidence should be presented within future revisions of the Core Strategy to demonstrate that the housing figures identified within Table B.3 are capable of being delivered. As discussed above, the delivery of the proposed housing numbers identified within Tables B.2 and B.3 of the Core Strategy would Response to the Hull Core Strategy issues and options report, June 2008 October 2008 168

Company / Section Section City Council ID Your response Organisation number title response result in a short fall of 5,600 dwellings in the City when measured against the requirements of the adopted RSS. Therefore, should the Council fail to deliver the housing potential identified within these tables this would increase the housing short fall and compound the current housing issues of the City. In terms of the overall scale of housing, the Council are considering See A2.1 – A2.6. whether to allocate land for 1,200 new dwellings per annum in It is clear there is accordance with the requirement of the RSS or, alternatively, to a need to allocated 1,000 new dwellings per year in line with the housing adequately market assessment. As set out above, we consider that it is vital assess the extent that provision is made in accordance with the RSS at a rate of of future housing 1,200 dwellings per annum. needs across the city and wider We note that Table B.2 of the Options and Issues Paper shows that market area. The allocations totalling 9,320 dwellings are required. However, this City Council’s allocation is based on the Housing Market Assessment (HMA) HMA was Kingswood Parks Options rather than the RSS requirement for Hull. We consider that the RSS completed after 118 Development 10 should provide the basis for the annual housing requirement in the RSS was finally Company City. agreed. The Council takes a The Core Strategy justifies this lower level on the basis that: “Over more pragmatic the period to 2026, RSS sets out housing requirements to be view on the use achieved in Hull, although it recognises that more up to date of more up to information can be used to determine a particular direction.” date and local information on However, there is no such allowance in the CLG Guidance for future housing Housing Market Assessments to allow HMA’s to override RSS requirements. requirements. The most up to date guidance from CLG (Strategic The City Council Housing Market Assessments – Practice Guidance Version 2, is following

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 169

Company / Section Section City Council ID Your response Organisation number title response August 2007) is clear in stating: “The Value of Strategic housing Government market assessments is in assisting policy development, decision- policy in moving making and resource-allocation processes by: away from a ‘predict and • Enabling regional bodies to develop longterm strategic views of provide’ to a housing need and demand to inform regional spatial strategies and ‘plan, monitor regional housing strategies; and manage’ approach in • Enabling local authorities to think spatially about the nature and meeting housing influence of the housing markets in respect to their local area;” (p7) requirements while being in The guidance from CLG is clear in that assessment of overall need general and demand from HMAs is only intended to inform the regional conformity with planning bodies with respect to reviews of the RSS. It is for the RSS. RSS is also RSS to set housing levels, and it is for the review of the RSS to being reviewed amend the requirements rather than the HMA. The HMAs are only following intended to inform the ‘spatial interpretation’ of the housing need as concerns about set out by RSS. Whilst HMAs can discuss ‘need’ at the local level, the current this is only in respect of the need for affordable housing, need market downturn. within sub areas and the need for housing for specific groups. Rates of actual There is no allowance for LPA’s to consider the overall strategic demolitions are housing requirement independently of the RSS. also far less than originally The RSS assumes that LDFs will automatically adopt the housing estimated by numbers it sets out, without further assessment of the overall need Gateway when and demand. Policy H1 of RSS states clearly that: “Plans, the RSS was strategies, programmes and investment decisions should ensure being drafted the delivery of the average annual net additions to the dwelling which has a stock set out in Table 12.1 in locations that accord with the Core major influence Approach and Sub Area policies, taking account of indicative timing on overall Response to the Hull Core Strategy issues and options report, June 2008 October 2008 170

Company / Section Section City Council ID Your response Organisation number title response set out in Table 12.2.” housing requirements. Although HMAs need to be carried out and taken account of (RSS The housing land para. 12.2) no allowance is provided in the RSS for HMAs to assessment also effectively set a lower housing delivery target. The RSS supporting needs text is clear that the figures in RSS Table 12.1 provide a ‘framework completing which for LDFs’. In particular, RSS states that the figures ‘reflect higher helps determine levels of growth that now need to be planned for’, rather than being the supply side a mere reflection of the market and net build rates up to 2008 (para. and a housing 12.4). Indeed, the RSS clearly states that housing figures are not development based on what has gone before: “This means that the annual trajectory. average housing growth figures set out in Table 12.1 represent a significant shift away from what has happened in the past in some parts of the region” (Para. 12.6).

Only Table 12.2 of the RSS, which sets the timing for growth, is noted as being ‘indicative’. Meanwhile, with regard to Table 12.1 and Policy H1, which set the housing level for Hull at a rate of 1,200 dwellings per year, post 2008, Policy H2 states: “To support the step-up in the delivery of new homes required by policy H1 and to ensure that new homes are in locations that accord with the Plan’s Core Approach and Sub-Area Policies:

(B) LPAs should identify and manage the release of land to maintain the momentum of urban transformation … by:

5. Adopting a flexible approach to delivery by not treating housing figures as ceilings …” (our emphasis).

Policy H2 is consistent in setting out that the housing figures set out Response to the Hull Core Strategy issues and options report, June 2008 October 2008 171

Company / Section Section City Council ID Your response Organisation number title response by the RSS are the minimum that should be ‘required’ and should not be treated as ‘ceilings’. Therefore, whilst there is support for LPAs to exceed these figures, there is no policy allowance for LPAs to effectively plan to meet a lower target, disregarding the Development Plan requirement, as set out in RSS. It is not the role of HMAs to set housing targets, since it is clear that the RSS targets have not been set in response to market demand, but as a driver for planned economic growth in the region, and therefore, by definition, this cannot be a response to market conditions and assessments.

Whilst the RSS does require LPAs to work collaboratively to provide HMAs in line with PPS3 (para. 12.2), PPS3 is clear that it is for the RSS to set the level of housing provision and to allocate housing requirements to Local Authority areas: “RSS should set out the level of overall housing provision for the region, broadly illustrated in a housing delivery trajectory, for a sufficient period to enable LPAs to plan for housing over a period of at least 15 years. This should be distributed amongst constituent housing market and Local Planning Authority areas.” (PPS3 para. 34).

Accordingly PPS3 requires LPAs to provide LDF development plan documents which ‘set out a strategy for the planned location of new housing which contributes to the achievement of sustainable development’ taking into account ‘objectives set out in the relevant RSS’ (PPS3 para. 38). Since the RSS for Yorkshire and Humber has been approved by the Secretary of State and has been published in its final form, we consider that not adopting the housing numbers set out in RSS would fundamentally undermine the soundness of the Core Strategy and, therefore, the entire LDF. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 172

Company / Section Section City Council ID Your response Organisation number title response

We note that the LPA claim that following the findings of the ‘more up to date Housing Market Assessment’, which claims that there is no demand for the level of housing required by RSS. However, both RSS (para. 12.2) and PPS 3 are clear that any changes to market conditions should inform a review of RSS, rather than at the LDF level: “In circumstances where market conditions have changed, it may also be necessary to reassess need and demand, considering a review of approach across the housing market area and/or initiating a partial review of the RSS to update the local level of housing provision.” (PPS3 Para. 66)

There is no allowance in PPS3 for HMAs to amend the level of housing requirement. Annex C of PPS 3 states, rather, that the role of HMAs should be to (1) estimate the need and demand in terms of the proportion of affordable and the proportion of market housing (rather than the overall need, per se), (2) determine how the distribution of need and demand varies across the plan area and (3) consider future demographic trends to identify the accommodation requirements of specific groups (e.g. key workers, the elderly, the disabled) rather than the total population. PPS3 envisages that Housing Market Assessments should consider how the needs of the local population should impact on the delivery of the housing numbers required at the strategic level, as set out in the RSS. In this way, LPAs are required to take account of HMAs in the formation of LDFs and determining how and where the RSS housing numbers will be delivered. Adopting a lower housing target altogether, in response to an HMA, would be an attempt by the LPA to move beyond the remit of how an HMA can inform an LDF, as set out in PPS3. As such, we consider that option 10 (A) (2) to be Response to the Hull Core Strategy issues and options report, June 2008 October 2008 173

Company / Section Section City Council ID Your response Organisation number title response entirely unsound.

In view of the above, we support option 10 (A) (1) as the only sound option in terms of the overall scale of housing delivery. Consequently, as the indicative figures for further housing allocations identified within Table B.2 (9,320 dwellings) are based on the housing requirements identified within the HMA, in order for the City to meet the housing requirements of the RSS the Council will need to provide for a total of 14,920 dwellings through the LDF, 5,600 more dwellings than that identified within Table B.2. This level of provision will most definitely require that the Council release greenfield land, urban extensions and possibly urban greenspace (where appropriate) for future housing development.

In respect of the future distribution of housing, we support all of the options set out in 10B. However, in addition to identifying specific areas in which future housing in the City is to be distributed, it is considered that text should be included to require that sufficient evidence is presented that a site is either:-

• Deliverable – a site is available now, offers a suitable location for housing development now and there is a reasonable prospect that housing will be delivered on the site within five years from the date of adoption of the plan; and

• Developable – a site should be in a suitable location for housing development, and there should be a reasonable prospect that it will be available for and could be developed at a specific point in time.

In respect of Kingswood, we support the possible reallocation of Response to the Hull Core Strategy issues and options report, June 2008 October 2008 174

Company / Section Section City Council ID Your response Organisation number title response existing employment land for housing, as set out in para B.20 and Table B.3m, and the possibility of extensions outside of the City boundary to the north of Kingswood. Both of these options are considered deliverable and developable.

Indeed, we consider that there may be scope to include more dwellings at Kingswood than the additional 1,000 set out in Table B.3 on the basis that, in line with the RSS, the LPA need to plan for a further 5,600 dwellings, in addition to those already set out in the Core Strategy Issues and Options Paper. In this context, the relocation of the overhead lines at Kingswood Parks, the reallocation of part of the employment land and an urban extension to the north of Kingswood should be progressed.

In respect of phasing, options suggested involve continuing with current allocations to 2014, focusing on the previously developed sites to 2026 and only considering further urban extensions beyond 2021, once all other opportunities are exhausted. Reference is made to the planning permission at Kingswood and as such the Core Strategy states that: “Assumptions used in determining these broad requirements include… likelihood that Kingswood will build out towards the back end of the plan period.”

The build out of Kingwood will continue throughout the Plan period in accordance with the approved build rates set by condition (iv). This build rate can be increased in accordance with the agreed formula to meet any shortfall in house building rates in the rest of Hull. Having regard to the need to increase house building to meet RSS requirements, we consider that it would be appropriate to allow for a more rapid build-out rate at Kingswood. The recent Response to the Hull Core Strategy issues and options report, June 2008 October 2008 175

Company / Section Section City Council ID Your response Organisation number title response approval of condition (iv) for future housing provision allows for increased house building rates. In the short term, through the relocation of the overhead lines and the reallocation of the employment area to housing, it is also possible to increase the number of housing units and the rate of housing delivery at Kingswood. In the longer term, the release of land to the north of Kingswood could also assist in housing delivery. We need to consider all reasonable Friends of Options Option B3: The land at the edge of the city is greenfield and should, alternatives to 251 Pearson Park 10 in no circumstances, be built on. achieving housing needs, particularly over the long term. In terms of overall scale, ABP support Option 1 Use the Regional Support for a mix Spatial Strategy housing figure of around 1,200 dwellings per year. of Options 10.1 and 10.2 are In recent years the number of new households has risen welcomed. dramatically. The RSS identifies that household growth between 2001 and 2004 was around 18,000 per year. Factors that have Associated Options influenced this boom in household growth include increased birth 293 British Ports 10 rates in the region, longer life expectancy, increased migration to the region, and reductions in household size.

In light of the above, ABP considers that an increased level of house building in Hull is required to meet the demand of increasing household numbers.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 176

Company / Section Section City Council ID Your response Organisation number title response In terms of distribution, ABP considers that a mixture of Options 1 and 2 should be adopted. ABP consider that in order to meet increased demand for housing in Hull, further allocations need to be made. In addition, ABP consider that the majority of new housing should be located in central areas, and particularly within and on the edge of the City Centre and Newington and St Andrews Area. ABP request that an option similar to the following should be adopted: “Make further allocations to meet the increasing demand for housing in the city, particularly within and on the edge of the City Centre and the Newington and St. Andrews area”.

ABP consider that new housing should be focused in the above areas because, as stated above, these areas are some of the most deprived areas in the Region, and additional new housing in these locations could kick-start regeneration, and create a vibrant gateway into the city. In addition, new residential development in these areas would assist in the creation of sustainable travel patterns, and would assist in meeting objectives in other areas of the Core Strategy, such as reducing climate change, and encouraging regeneration.

In terms of phasing due to the reasons stated above, ABP supports Option 1 Use the sequence suggested in paragraph B.21, particularly in respect to early delivery of housing in the deprived City Centre and Newington and St Andrews area. Government Gross figures in RSS are indicative only (see para 12.16, RSS) so The housing land Office for Options option A is okay, assuming evidence base is okay. But you still assessment will 283 Yorkshire and the 10 need to ensure delivery of (RSS) net additions of 880 pa (as per help better Humber H1, table 12.1, RSS). Housing trajectory (-ies) would help here – determine these

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 177

Company / Section Section City Council ID Your response Organisation number title response you should address this. matters. It may be helpful if the chapter provided options for the The housing land amount/proportion of housing development to be located in different assessment will parts of the city (such as in the AAP areas and Kingswood). Other help determine Core Strategies have been found unsound because they have the extent of failed to consider, or have provided little evidence, on how housing future options development will be distributed. including possible urban extensions.

East Riding of Yorkshire Council has significant concerns over the See A2.1 – A2.6 reference ‘to meet the city’s requirements by allocating land in East and A3.1 – A3.2. Riding of Yorkshire at the edge of the city’. It is inappropriate to suggest this as a preferred approach without any discussion with East Riding of Options the Council. It is therefore not possible to show how this ‘preferred 460 Yorkshire Council 10 option’ is deliverable.

Furthermore, the actual meaning of the sentence is unclear. Is the Joint working will City Council expecting East Riding to allocate sites in the East or should enable Riding LDF to help meet Hull’s 1,300 completions per year target in consideration of phase 3? Or is the City Council expecting East Riding to delay the what is release of its allocated sites in the settlements surrounding Hull appropriate for until 2021? If the former is the case, this is a matter to be each area considered through the Regional Spatial Strategy and its without triggering distribution of housing numbers to individual local authorities. It is the need for a not something that can be considered through either Council’s review of RSS. Local Development Framework. Clearly, more local evidence It is also unclear in the document when further land at Kingswood base work can

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 178

Company / Section Section City Council ID Your response Organisation number title response may be released for residential development (through the re- be material to our allocation of current employment land). The timing of any release plan making in should be consistent with any phasing/release of greenfield sites following a ‘plan, within East Riding. The City Council should adopt an approach that monitor and makes the best use of vacant and under-used brownfield sites manage’ within the city first. approach provided this is in general conformity with RSS. Options: Support to these options is A scale – HMA figure seems more relevant welcomed.

B distribution – agree the categorisation with (1) receiving highest priority and (3) the lowest Options 414 Hull Forward 10 C phasing – a combination of (1) and (2) needs to be pursued. A strong protocol needs to be worked up with ERYC. Understand that Gateway are looking at housing mix & provision across the city to provide better choice, including affordable options for larger family housing. To support the developing economy provision of larger, aspirational housing that is accessible needs discussion. To achieve Option 10 – providing a suitable scale, distribution and Noted. See A2.1 phasing of housing to meet the city’s future needs it is suggested – A2.6. Yorkshire and Options that this could be achieved through using the RSS housing figure of 361 Humber 10 around 1,200 dwellings per year or using more up to date local Assembly Housing Market Assessment requirement of around 1,000 dwellings per year. The Assembly would suggest that it would be

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 179

Company / Section Section City Council ID Your response Organisation number title response more beneficial to use the RSS net housing figure instead of gross. Also it is unclear as to whether the local Housing Assessment requirement of around 1,000 is a net or gross figure; therefore this will need to be clarified.

The Assembly is encouraged that in terms of phasing it is suggested that Hull work with East Riding of Yorkshire Council to seek to ensure continued restraint on housing land supply in its part of the Hull Housing Market Area, to help this sequencing. The type of house a person lives in can greatly affect their life Further local chances. A disabled person living in a small 12th floor flat, with a lift evidence in that only works intermittently may find work and social activities terms of current harder than a disabled person living in spacious well designed level and future access bungalow. A family with a disabled child will have differing mobility impaired requirements than the average. Most people with a mobility population is impairment will prefer a bungalow and family bungalows are in being considered short supply. Children with disabilities may also have different prior to needs to adults. The provision of flats for disabled people where the estimating future Hull Access upper storey is occupied by none disabled people can cause housing 21 Improvement Housing mix conflict. requirements. Group

B38 the final sentence reads 'New proposals could take into account the need for 'lifetime homes standard'. This should be non- negotiable, national legislation will require 'lifetime homes standard in the future and promises have been made by Gateway and councillors that the 'lifetime homes standard’ will be adhered to. The city cannot afford to keep paying for expensive adaptations to properties just because the house builders are not prepared to stop discriminating against disabled people.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 180

Company / Section Section City Council ID Your response Organisation number title response Further local evidence in terms of current and future mobility impaired population is being considered Hull Access Table B4 should also include family size bungalows and specifically prior to

22 Improvement Housing mix designed wheelchair accessible properties. An agreed percentage estimating future Group of all new build should be wheelchair accessible, suggest 8 to 10%. housing requirements, along with estimates of a likely increase in older people, over the life of the plan period. Page 80. Need to consider what will work on the ground. We can't See A24.1. build back predominantly large houses, as this will definitely not produce the mixed type and tenure areas that are needed for sustainability. Suggest that a good housing mix of type, size and tenure should be an objective in itself to provide a property ladder at local level and deliver more sustainability. 57 Gateway Housing mix

Page 82 and Table B.4. Seems unlikely that we can or want to See A23.1. provide this level of larger housing in early years. There is a need for mix at a local level and also issue of affordability.

Page 83 and Table B.5 indicative densities look very low for areas See A23.1.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 181

Company / Section Section City Council ID Your response Organisation number title response of change. You would want to see some lower density housing, but to achieve sustainable demand for services etc need a reasonable density, particularly if looking at smaller dwellings in the early years.

Page 87. Should also refer to Building for Life design standards Noted. (planning authorities are going to be charged with measuring against this anyway).

Page 87. Still unclear whether the affordable housing requirement Noted. Affordable is to be set by Core Strategy or AAP's. Need consistent line and requirement is to stick to it. Gateway’s view is that we need a city wide policy with be set out in the possibility of (minor) local variations so as not to disadvantage Core Strategy, developers in the regeneration areas. although this does not prevent suitable standards being introduced in the AAPs. See also A22.1.

Page 87 and para.B.51. Doesn't really signal an intent re affordable The next draft housing. See to need a principle here about achieving mix on any will make this reasonable sized site. 20% minimum seems a sensible overall clear. target. Arguably in regeneration, areas of change will be higher in early years to assist with re-housing, but less in future as there is already significant affordable housing in the area.

Pages 89/90. Option 11A.3 on affordable housing does not The suggested currently make sense, especially in terms of time frame. 20% requirement was a response Response to the Hull Core Strategy issues and options report, June 2008 October 2008 182

Company / Section Section City Council ID Your response Organisation number title response to growing disparity between house prices and wage levels.

Page 88, para.B.56. Welcome idea of revisiting Kingswood re Noted. affordable housing although it is not clear on what grounds as planning permission has already been granted. Paras B.41 and B. 42. We welcome the acknowledgement that the Support plan needs to take account of existing densities around the city and welcomed. English Heritage that new development should respect the current surrounding built

164 Yorkshire and Housing mix form. This is important if the Plan is to safeguard those elements of Humber Region Hull which contribute to the distinct character of the City. This approach also reflects the guidance given in PPS3, particularly Paragraph 46, 48 and 49. Government The housing land Office for Para B.50. You will need to demonstrate that the requirement can assessment will 284 Housing mix Yorkshire and the deliver sufficient provision to meet Hull’s needs. help in Humber determining this. Firstly, it is considered that the population/migration issue should in Noted. See A2.1 spatial terms be considered at the level of the greater Hull area – A2.6 and A7.1 rather than being focussed on the administrative boundary of the – A7.2. City. It is our view that this approach is the one contained in RSS Scruton's & Co policy and needs to be more positively embraced by both the City 352 Housing mix (Builders) Ltd and East Riding.

Secondly that the housing mix within the administrative boundary is Noted. See also a more important issue than appears to be its rating in the paper. A24.1. There is not only a greater need for family homes but a significant Response to the Hull Core Strategy issues and options report, June 2008 October 2008 183

Company / Section Section City Council ID Your response Organisation number title response need to create locations of aspiration for the family units. Whilst these matters are recognised in the analysis it is considered they need greater emphasis.

There needs to be a strongly co-coordinated policy to deliver this See A7.1 – A7.2. housing for the greater Hull area between the two planning authorities and this is clearly flagged up by RSS. Thus the references to joint working should be upgraded to a joint LDD approach on housing.

The City has identified areas for regeneration and that process is Noted. supported. Many of the brownfield sites are not realistically capable of being developed with the appropriate kind of mix until suitable infrastructure is in place to ensure good educational choices in the neighbourhood, safety and crime reduction. Whilst a Brownfield first policy might be the desirable approach this needs a baseline which does not exist within many parts of the City. It would be appropriate to create some areas similar to Kingswood during the period that the regeneration already targeted is delivered and whilst steps are taken to establish the necessary infrastructure to create mix and balanced communities in other parts of the City. As the City does not have the sites to create these Kingswood type regeneration areas within its boundaries on flood risk free sites it will be necessary to achieve this in the short term on land within the East Riding.

However despite the apparent reluctance of both authorities to engage in formal joint working such a process could usefully extend beyond the issues of housing. It is clear that the demand for employment sites is for sites west of the City centre in close Response to the Hull Core Strategy issues and options report, June 2008 October 2008 184

Company / Section Section City Council ID Your response Organisation number title response proximity to the strategic road network. This issue would merit joint working is not necessarily a formal joint policy document.

In conclusion it is the proposition of this response that greater See A24.1 as emphasis needs to be placed on the provision of traditional family well as A7.1 – homes and the creation of modern safe and appropriately serviced A7.2. neighbourhoods in which to locate them. The issue of the comprehensive delivery of housing policy, the provision of affordable housing and the support that the private sector can give to that delivery needs to be considered in a formal collaboration between Hull and the East Riding to cover the greater Hull Area. Para B.32. It is agreed that both Hull City and East Riding of Support Yorkshire Councils need to work to secure greater proportions of welcomed. East Riding of 462 Housing mix affordable housing. East Riding supports the objectives of the Yorkshire Council Gateway Pathfinder. Equally, it must be appreciated that East Riding must address its own housing needs. Para B.40. East Riding of Yorkshire Council finds the suggested Both Councils approach unacceptable, that sites to meet the needs of Gypsy and are working on Travellers ‘may well be met outside the city in East Riding of options in taking Yorkshire’. It is inappropriate to identify this as a preferred option this forward without any formal agreement/arrangements with East Riding of although there Yorkshire Council. The Council is nearing completion of a Gypsy are difficulties in East Riding of 463 Housing mix and Traveller needs study and will have its own requirements to terms of Yorkshire Council meet. It is therefore not possible to show how this ‘preferred option’ addressing flood is deliverable. risks associated with vulnerable Could the City Council meet its requirement by locating sites in uses. See A26.1. those areas of Flood Risk Zone 1 as shown on Map A.3? Alternatively, could needs be met by providing more permanent

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 185

Company / Section Section City Council ID Your response Organisation number title response buildings within Flood Risk Zones 2 and 3?

Noted and this East Riding of Para B.58. It is surprising that East Riding of Yorkshire Council has can be added at 466 Housing mix Yorkshire Council not been identified as a delivery agent. the next draft stage. Affordable housing section – HMA indicates a need for more Noted. See also affordable family housing, which could be highlighted in future A24.1. documents. The line being taken in the city centre in the short to medium terms should also be explained (which takes into account 415 Hull Forward Housing mix the existing mix of housing at different levels, and the more immediate need to develop an aspirational product to attract higher income earners to underpin regeneration and support city centre services, leisure etc). Further local evidence in It is noted that the population of the city is 'ageing' and that the terms of current number of residents of pensionable age is expected to grow and future elderly significantly in the future. It is evident therefore that it is necessary Pickering and population is 470 Housing mix to produce an "older persons housing strategy" in Hull. I am aware Ferens Homes being considered that a number of steps have already been taken to attempt to prior to produce such a strategy - but obviously I consider that the need for estimating future an older persons strategy is becoming more and more acute. housing requirements. We support the need to 'provide for the needs of existing and Support Hull Access Objective potential residents through appropriate housing mix, density and welcomed. 23 Improvement 11 design.' We are not convinced that sufficient research and statistics Further local Group are available to fully understand what these may be. Local statistics evidence in

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 186

Company / Section Section City Council ID Your response Organisation number title response do suggest that Hull has an higher level of people with disabilities, terms of current this may be in part due to the topography of the area and residents and future moving to the city from more rural areas because of the increased mobility impaired accessibility of the landscape, more local amenities etc. population is being considered prior to estimating future housing requirements, along with estimates of a likely increase in older people, over the life of the plan period. Objectives 10 & 11: We broadly agree, and would stress that Hull Support Objective does not currently have much to offer at the upper end of the welcomed. 207 Local resident 11 market, and that this has an effect on the social mix; the consequences of this are felt at various levels. In respect of housing mix, we support the need for a more balanced Support mix of housing in the City. The City has a high proportion of smaller welcomed. properties with a limited choice of larger properties. The HMA suggests that there is a requirement to ensure that 58% of new Options housing to be provided in the City should be larger properties (of 3 50 Barratt Homes 11 or more bedrooms with large gardens).

In determining housing mix, regard should be given to the locational Noted although requirements for new housing. We consider that the City Centre is this is the a location best suited to the provision of smaller dwellings and flats. intention behind

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 187

Company / Section Section City Council ID Your response Organisation number title response Conversely, sites located outside of the City Centre and future the densities urban extension sites would be more appropriate for the provision outlined in Table of family homes. Rather than attempting to apply a certain housing B5. mix to every location within the City, we consider that a higher proportion of small dwellings should be provided within the City Centre and high proportion of larger dwellings to be provided appropriately elsewhere.

It is considered that additional evidence should be provided within Noted, although the Core Strategy to support the options identified in 11 (A) (1 & 2) these are the in terms of housing mix. The Core Strategy identifies that the City main locations Policies DPD and Area Action Plans will set out further details in for realising relation to suitable housing types in the City. We consider that the major physical deferring of this information to other DPD’s is not consistent with change where the guidance set out within PPS12 and PPS3 given that the Core housing mix can Strategy is expected to set out a City wide development framework be improved. that all other DPD’s are required to comply with.

In terms of the provision of affordable housing, we note that the The housing land HMA suggests applying a local requirement of 20%. We object to assessment will the requirement set out within Option 11 (A) (3) on the basis that it consider viability does not reflect the ‘needs’ as set out in the HMA and as there is matters including no demonstrable evidence to suggest that the 20% target is the suggested economically viable. affordable homes requirement. See In respect of ‘need’, we refer to p.229 of the HMA which states:- also A22.1. “The levels of net ‘need’ suggest an annual requirement of almost 200 units. This would therefore represent almost 23% of the RSS net dwelling target of 880 units per annum (16% of the gross RSS figure of 1,200 per annum). Against the Demographic Scenario it Response to the Hull Core Strategy issues and options report, June 2008 October 2008 188

Company / Section Section City Council ID Your response Organisation number title response would represent almost 20% of the net requirement and almost 19% of the gross annual requirement. However, it is important to note that a significant part of the need results from a backlog of need which, once addressed, will reduce the level of need in the longer term highlighting the importance of careful monitoring.”

The HMA, therefore, concludes that the affordable housing provision should be 16% of the gross RSS figure rather than 23%. The HMA also makes the point that Hull has not been an area of the country in need of affordable housing because, unlike other parts of the UK, the City has an overprovision of small “affordable” dwellings. The HMA states that:- “Affordability issues are apparent in Hull although the low average house prices mean that the vast majority of Hull has what is considered relatively affordable properties.”

Although the HMA indicates that as average house prices in Hull touch £100,000 and that issues of affordability are becoming more critical, the recent downturn in the housing market and the collapse of the buy-to-let market has reduced house prices generally. As such, we object to any option which seeks to apply a blanket approach to affordable housing delivery. Rather, in accordance with the HMA (footnote 120), we consider that each site should be individually appraised in acknowledgement of both need and the issue of economic viability.

With regard to economic viability, though we support the findings of the HMA in respect of the identified affordable housing ‘needs’ of the City, we believe that the HMA does not provide a thorough assessment of ‘economic viability’ as requested in Paragraph 29 of Response to the Hull Core Strategy issues and options report, June 2008 October 2008 189

Company / Section Section City Council ID Your response Organisation number title response PPS3 and within the Strategic Housing Market Assessment (SHMA) Practice Guidance, published in August 2007, which at page 63 states that:- “Authorities will need to consider other factors when determining affordable housing targets including the policy definition of affordable housing, an assessment of economic viability within the area and the likely levels of finance available for affordable housing.”

The Council has not provided demonstrable evidence within the Core Strategy Issues and Options paper that they have undertaken or commissioned an informed assessment of the viability and practicability of the proposed affordable housing targets. This lack of viability testing by the Council is therefore contrary to PPS3 requirements.

It is of particular note that this issue has recently been considered by the High Court in respect of Blyth Valley Borough Council’s Core Strategy. In that instance the High Court found the Core Strategy affordable housing policy to be unsound as a result of there being no consideration of viability evidence in respect of the proposed 30% affordable housing target. The judgement is enclosed with these representations for your consideration.

The Blyth Valley judgement is especially pertinent in the context of the City of Hull. Like Hull, the property prices within the Blyth Valley Borough are low and thus the market price which any developer could expect to achieve would be lower than in most other parts of England. Such market conditions need to be considered in order to ensure that the future provision of affordable housing within residential developments does not render developments Response to the Hull Core Strategy issues and options report, June 2008 October 2008 190

Company / Section Section City Council ID Your response Organisation number title response economically unviable.

Having regard to the above, based on the HMA’s assessment of ‘need’ we consider that the Council ought to adopt the lower figure of 15% on sites of 15 dwellings or more, based on the delivery of the full RSS figures of 1200 new dwellings per annum. This figure of 15% is based on the HMA’s assessment which identifies that the rate of affordable housing delivery should only be 16% where the higher RSS target of 1200 dwellings per annum is applied in order to bring forward the suggested 200 affordable homes per annum.

In respect of a proposed affordable housing delivery policy, as the HMA states that once the existing back-log of ‘need’ has been met, there will not be a need to continue to seek affordable housing at the same level. As such, we consider that Option 11 (A) (3) should incorporate more flexibility and be reworded to state: “Ensure that more affordable housing is provided by applying an indicative local standard of 15% between 2008 and 2011, except where:

• market conditions dictate otherwise

• there is no longer a current need for affordable housing

• it is shown to be unviable for the development to deliver affordable housing at this level”.

Prior to the revision of affordable housing targets within the Core Strategy, the Council should undertake a robust economic viability assessment of any revised target in order to provide demonstrable evidence that the target is deliverable. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 191

Company / Section Section City Council ID Your response Organisation number title response

Housing Densities

In respect of the housing densities identified within Table B.5, we The housing land consider that only indicative density standards should be set as the assessment will application of rigid density standards across the City may consider design compromise design quality. Indicative housing densities will ensure and viability that development proposals remain viable whilst enabling variation matters including in the character of housing areas. application of indicative Policies in the Core Strategy should therefore ensure the flexible densities in delivery of appropriate housing densities across the whole of the different City based on identified housing needs and any potential site locations. See specific issues and constraints associated with a development also A23.1. (such as flooding). This approach would ensure that all developments within the City contribute to meeting the City’s identified housing needs whilst remaining viable for developers. We therefore object to the approach identified within Option 11 (B) (1 & 2).

Housing Design

In respect of Option 11 (C) (1, 2 & 3) in relation to Lifetime Homes The housing land and the Code for Sustainable Homes, we consider that these assessment will standards should be introduced in accordance with the consider design Government’s Target dates. We consider that bringing forward and viability schemes in advance of the statutory targets may make some matters including schemes unviable and uncompetitive. application of these standards.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 192

Company / Section Section City Council ID Your response Organisation number title response Whilst accepting the potential impact of the above standards on the See also A25.1. economic viability of development proposals, we feel that this reinforces the need for other policies to also consider the viability of development schemes and thus not impose further demands on them which could potentially prevent their delivery.

We do not consider that the proposed figure of affordable housing The housing land delivery at a rate of 20% is justified. Hull has not had a problem of assessment will affordability, and in the current downturn of the housing market, we consider viability consider that pursing a rate of 20% would be unjustified. A lower matters including rate of 15% may be suitable, if the RSS housing figures are the suggested adopted, however this should be kept under review. affordable homes requirement. See also A22.1. In respect of housing mix, we support the need for a more balanced Support mix of housing in the City. The City has a high proportion of smaller welcomed. properties with a limited choice of larger properties. The HMA suggests that there is a requirement to ensure that 58% of new housing to be provided in the City should be larger properties (of 3 or more bedrooms with large gardens).

Options 83 Kayterm Ltd In determining housing mix, regard should be given to the locational Noted although 11 requirements for new housing. We consider that the City Centre is this is the a location best suited to the provision of smaller dwellings and flats. intention behind Conversely, sites located outside of the City Centre and future the densities urban extension sites would be more appropriate for the provision outlined in Table of family homes. Rather than attempting to apply a certain housing B5. mix to every location within the City, we consider that a higher proportion of small dwellings should be provided within the City

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 193

Company / Section Section City Council ID Your response Organisation number title response Centre and high proportion of larger dwellings to be provided appropriately elsewhere.

It is considered that additional evidence should be provided within Noted, although the Core Strategy to support the options identified in 11 (A) (1 & 2) these are the in terms of housing mix. The Core Strategy identifies that the City main locations Policies DPD and Area Action Plans will set out further details in for realising relation to suitable housing types in the City. We consider that the major physical deferring of this information to other DPD’s is not consistent with change where the guidance set out within PPS12 and PPS3 given that the Core housing mix can Strategy is expected to set out a City wide development framework be improved. that all other DPD’s are required to comply with.

In terms of the provision of affordable housing, we note that the The housing land HMA suggests applying a local requirement of 20%. We object to assessment will the requirement set out within Option 11 (A) (3) on the basis that it consider viability does not reflect the ‘needs’ as set out in the HMA and as there is matters including no demonstrable evidence to suggest that the 20% target is the suggested economically viable. affordable homes requirement. See In respect of ‘need’, we refer to p.229 of the HMA which states:- also A22.1. “The levels of net ‘need’ suggest an annual requirement of almost 200 units. This would therefore represent almost 23% of the RSS net dwelling target of 880 units per annum (16% of the gross RSS figure of 1,200 per annum). Against the Demographic Scenario it would represent almost 20% of the net requirement and almost 19% of the gross annual requirement. However, it is important to note that a significant part of the need results from a backlog of need which, once addressed, will reduce the level of need in the longer term highlighting the importance of careful monitoring.” Response to the Hull Core Strategy issues and options report, June 2008 October 2008 194

Company / Section Section City Council ID Your response Organisation number title response

The HMA, therefore, concludes that the affordable housing provision should be 16% of the gross RSS figure rather than 23%. The HMA also makes the point that Hull has not been an area of the country in need of affordable housing because, unlike other parts of the UK, the City has an overprovision of small “affordable” dwellings. The HMA states that:- “Affordability issues are apparent in Hull although the low average house prices mean that the vast majority of Hull has what is considered relatively affordable properties.”

Although the HMA indicates that as average house prices in Hull touch £100,000 and that issues of affordability are becoming more critical, the recent downturn in the housing market and the collapse of the buy-to-let market has reduced house prices generally. As such, we object to any option which seeks to apply a blanket approach to affordable housing delivery. Rather, in accordance with the HMA (footnote 120), we consider that each site should be individually appraised in acknowledgement of both need and the issue of economic viability.

With regard to economic viability, though we support the findings of the HMA in respect of the identified affordable housing ‘needs’ of the City, we believe that the HMA does not provide a thorough assessment of ‘economic viability’ as requested in Paragraph 29 of PPS3 and within the Strategic Housing Market Assessment (SHMA) Practice Guidance ,published in August 2007, which at page 63 states that:- “Authorities will need to consider other factors when determining affordable housing targets including the policy definition of affordable housing, an assessment of economic Response to the Hull Core Strategy issues and options report, June 2008 October 2008 195

Company / Section Section City Council ID Your response Organisation number title response viability within the area and the likely levels of finance available for affordable housing.”

The Council has not provided demonstrable evidence within the Core Strategy Issues and Options paper that they have undertaken or commissioned an informed assessment of the viability and practicability of the proposed affordable housing targets. This lack of viability testing by the Council is therefore contrary to PPS3 requirements.

It is of particular note that this issue has recently been considered by the High Court in respect of Blyth Valley Borough Council’s Core Strategy. In that instance the High Court found the Core Strategy affordable housing policy to be unsound as a result of there being no consideration of viability evidence in respect of the proposed 30% affordable housing target. The judgement is enclosed with these representations for your consideration.

The Blyth Valley judgement is especially pertinent in the context of the City of Hull. LikeHull, the property prices within the Blyth Valley Borough are low and thus the market price which any developer could expect to achieve would be lower than in most other parts of England. Such market conditions need to be considered in order to ensure that the future provision of affordable housing within residential developments does not render developments economically unviable.

Having regard to the above, based on the HMA’s assessment of ‘need’ we consider that the Council ought to adopt the lower figure of 15% on sites of 15 dwellings or more, based on the delivery of Response to the Hull Core Strategy issues and options report, June 2008 October 2008 196

Company / Section Section City Council ID Your response Organisation number title response the full RSS figures of 1200 new gross dwellings per annum. This figure of 15% is based on the HMA’s assessment which identifies that the rate of affordable housing delivery should only be 16% where the higher RSS target of 1200 gross dwellings per annum is applied in order to bring forward the suggested 200 affordable homes per annum.

In respect of a proposed affordable housing delivery policy, as the HMA states that once the existing back-log of ‘need’ has been met, there will not be a need to continue to seek affordable housing at the same level. As such, we consider that Option 11 (A) (3) should incorporate more flexibility and be reworded to state: “Ensure that more affordable housing is provided by applying an indicative local standard of 15% between 2008 and 2011, except where:

• market conditions dictate otherwise

• there is no longer a current need for affordable housing

• it is shown to be unviable for the development to deliver affordable housing at this level”.

Prior to the revision of affordable housing targets within the Core Strategy, the Council should undertake a robust economic viability assessment of any revised target in order to provide demonstrable evidence that the target is deliverable.

Housing Densities

In respect of the housing densities identified within Table B.5, we The housing land Response to the Hull Core Strategy issues and options report, June 2008 October 2008 197

Company / Section Section City Council ID Your response Organisation number title response consider that only indicative density standards should be set as the assessment will application of rigid density standards across the City may consider design compromise design quality. Indicative housing densities will ensure and viability that development proposals remain viable whilst enabling variation matters including in the character of housing areas. application of indicative Policies in the Core Strategy should therefore ensure the flexible densities in delivery of appropriate housing densities across the whole of the different City based on identified housing needs and any potential site locations. See specific issues and constraints associated with a development also A23.1. (such as flooding). This approach would ensure that all developments within the City contribute to meeting the City’s identified housing needs whilst remaining viable for developers. We therefore object to the approach identified within Option 11 (B) (1 & 2).

Housing Design

In respect of Option 11 (C) (1, 2 & 3) in relation to Lifetime Homes The housing land and the Code for Sustainable Homes, we consider that these assessment will standards should be introduced in accordance with the consider design Government’s Target dates. We consider that bringing forward and viability schemes in advance of the statutory targets may make some matters including schemes unviable and uncompetitive. application of these standards.

Whilst accepting the potential impact of the above standards on the See also A25.1. economic viability of development proposals, we feel that this reinforces the need for other policies to also consider the viability of development schemes and thus not impose further demands on Response to the Hull Core Strategy issues and options report, June 2008 October 2008 198

Company / Section Section City Council ID Your response Organisation number title response them which could potentially prevent their delivery.

We do not consider that the proposed figure of affordable housing The housing land delivery at a rate of 20% is justified. Hull has not had a problem of assessment will affordability, and in the current down turn of the housing market, we consider viability consider that pursing a rate of 20% would be unjustified. A lower matters including rate of 15% may be suitable, if the RSS housing figures are the suggested adopted, however this should be kept under review. affordable homes requirement. See also A22.1. In view of the comments in Paragraph B.42 and B.43 regarding the Noted. English Heritage Options need for housing densities to take account of the surrounding 165 Yorkshire and 11 character of the area, an additional Option should be included Humber Region which makes reference to this approach. In respect of housing mix, we support the need for a more balanced Support mix of housing in the City. The City has a high proportion of smaller welcomed. properties with a limited choice of larger properties. The HMA suggests that there is a requirement to ensure that 58% of new housing to be provided in the City should be larger properties (of 3 or more bedrooms with large gardens). Kingswood Parks Options 121 Development In determining housing mix, regard should be given to the locational Noted although 11 Company requirements for new housing. We consider that the City Centre is this is the a location best suited to the provision of smaller dwellings and flats. intention behind Conversely, Kingswood would be more appropriate for the the densities provision of family homes. Rather than attempting to apply a certain outlined in Table housing mix to every location within the City, we consider that a B5. higher proportion of small dwellings should be provided within the City Centre and high proportion of larger dwellings at Kingswood.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 199

Company / Section Section City Council ID Your response Organisation number title response

Affordable Housing

In terms of the provision of affordable housing, we note that the Noted, although HMA suggests applying a local requirement of 20%. We object to these are the the requirement set out within Option 11 (A) (3) on the basis that it main locations does not reflect the ‘needs’ as set out in the HMA and as there is for realising no demonstrable evidence to suggest that the 20% target is major physical economically viable. change where housing mix can be improved.

In respect of ‘need’, we refer to p.229 of the HMA which states: The housing land “The levels of net need suggest an annual requirement of almost assessment will 200 units. This would therefore represent almost 23% of the RSS consider viability net dwelling target of 880 units per annum (16% of the gross RSS matters including figure of 1,200 per annum). Against the Demographic Scenario it the suggested would represent almost 20% of the net requirement and almost affordable homes 19% of the gross annual requirement. However, it is important to requirement. See note that a significant part of the need results from a backlog of also A22.1. need which, once addressed, will reduce the level of need in the longer term highlighting the importance of careful monitoring.”

The HMA, therefore, concludes that the affordable housing provision should be 16% of the gross RSS figure rather than 23%. The HMA also makes the point that Hull has not been an area of the country in need of affordable housing because, unlike other parts of the UK, the City has an overprovision of small “affordable” dwellings. The HMA states that: “Affordability issues are apparent in Hull although the low average house prices mean that the vast Response to the Hull Core Strategy issues and options report, June 2008 October 2008 200

Company / Section Section City Council ID Your response Organisation number title response majority of Hull has what is considered relatively affordable properties.”

Although the HMA indicates that as average house prices in Hull touch £100,000 and that issues of affordability are becoming more critical, the recent downturn in the housing market and the collapse of the buy-to-let market has reduced house prices generally. As such, we object to any option which seeks to apply a blanket approach to affordable housing delivery. Rather, in accordance with the HMA (footnote 120), we consider that each site should be individually appraised in acknowledgement of both need and the issue of economic viability.

With regard to economic viability, though we support the findings of the HMA in respect of the identified affordable housing ‘needs’ of the City, we believe that the HMA does not provide a thorough assessment of ‘economic viability’ as required in Paragraph 29 of PPS3 and within the Strategic Housing Market Assessment (SHMA) Practice Guidance, published in August 2007, which at page 63 states that:- “Authorities will need to consider other factors when determining affordable housing targets including the policy definition of affordable housing, an assessment of economic viability within the area and the likely levels of finance available for affordable housing.”

The Council has not provided demonstrable evidence within the Core Strategy Issues and Options paper that they have undertaken or commissioned an informed assessment of the viability and practicability of the proposed affordable housing targets. This lack of viability testing by the Council is therefore contrary to PPS3 Response to the Hull Core Strategy issues and options report, June 2008 October 2008 201

Company / Section Section City Council ID Your response Organisation number title response requirements.

It is of particular note that this issue has recently been considered by the High Court in respect of Blyth Valley Borough Council’s Core Strategy. In that instance the High Court found the Core Strategy affordable housing policy to be unsound as a result of there being no consideration of viability evidence in respect of the proposed 30% affordable housing target. The judgement is enclosed with these representations for your consideration.

The Blyth Valley judgement is especially pertinent in the context of the City of Hull. Like Hull, the property prices within the Blyth Valley Borough are low and thus the market price which any developer could expect to achieve would be lower than in most other parts of England. Such market conditions need to be considered in order to ensure that the future provision of affordable housing within residential developments does not render developments economically unviable.

Having regard to the above, we consider that the Council ought to adopt the lower figure of 15% on sites of 15 dwellings or more, based on the delivery of the full RSS figures of 1200 new dwellings per annum, if it can be demonstrated that such a target would be economically viable. This is based on the HMAs assessment that the rate of affordable housing delivery should only be 16% where the higher RSS target of 1200 dwellings per annum is applied to bring forward the suggested 200 affordable homes, per annum.

In seeking affordable housing delivery, however, it should also be noted that the HMA states that there is a need for on-going Response to the Hull Core Strategy issues and options report, June 2008 October 2008 202

Company / Section Section City Council ID Your response Organisation number title response monitoring of “need”. The HMA states that once the back-log has been met, there will not be a need to continue to seek affordable housing at the same level. As such, we consider that Option 11 (A) (3) should be reworded to state: “Ensure that more affordable housing is provided by applying an indicative local standard of 15% between 2008 and 2011, except where:

• market conditions dictate otherwise

• there is no longer a current need for affordable housing

• it is shown to be unviable for the development to deliver affordable housing at this level”.

We consider that this approach would be more consistent with the assessment in both RSS and the HMA.

Housing Densities

In respect of housing densities, we consider that only indicative The housing land density standards should be set as the application of rigid density assessment will standards may compromise design quality. We note from Table B.5 consider design that an indicative range of housing densities has been suggested and viability for Kingswood with more than half of the dwellings being around 35 matters including dwellings per hectare. In order to allow for variations to be made in application of the character of the housing areas, this density should not be indicative applied to individual housing developments but across the whole of densities in Kingswood. different locations. See We therefore object to options 11 (B) (1 & 2), preferring a more also A23.1. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 203

Company / Section Section City Council ID Your response Organisation number title response flexible approach to be adopted.

Housing Design

In respect of Options 11 (c) (design), we object to Option 11 (C) (1) The housing land which seeks to ensure that all new homes are built to Life Time assessment will Home standards. We do not consider that it is necessary for all consider design dwellings to be built to this standard. As previously advised, it is and viability important to ensure that the City Council do not impose local matters including standards that are in excess of national planning policy. The HMA application of certainly does not recommend that all dwellings are built to Life these standards. Time Home standards. Indeed, the document takes a more See also A25.1. pragmatic approach, stating: “Further consideration is required to assess the general deliverability of lifetime homes and the impact they have on ensuring capital receipts are available to contribute to other regeneration priorities and the deliverability of affordable housing options.” (HMA para.9.186)

Indeed, the only recommendation with respect of lifetime homes that the HMA gives is: “Consideration also needs to be given to delivering Lifetime Homes through new developments where it can be shown to not have negative implications in terms of development value and gain.” (HMA para.9.202 point 6)

In view of the lack of any assessment regarding the viability of an option that would seek lifetime home standards on all developments, we consider that any option regarding lifetime homes should simply reflect national policy.

In respect of Option 11 C (2 & 3) in relation to the Code for Response to the Hull Core Strategy issues and options report, June 2008 October 2008 204

Company / Section Section City Council ID Your response Organisation number title response Sustainable Homes, we consider that this should be introduced in accordance with the Government’s Target dates. We consider that bringing forward schemes in advance of the statutory targets may make some schemes unviable and uncompetitive.

5.4 We do not consider that the proposed figure of affordable The housing land housing delivery at a rate of 20% is justified. Hull has not had a assessment will problem of affordability, and in the current down turn of the housing consider viability market, we consider that pursing a rate of 20% would be matters including unjustified. A lower rate of 15% may be suitable, if the RSS housing the suggested figures are adopted. However this should be kept under review and affordable homes must be subject to an economic viability assessment. requirement. See also A22.1. Pure Urban support the approach which seeks to provide for a Support balanced range of housing, including a greater mix and variety of welcomed. housing in areas of change. It is important that the production of the Core Strategy positively engages with the development industry who are uniquely placed to provide guidance on the types and range of housing which are deliverable in the City.

Options Option 11.3 suggests a new indicative local standard of 20% Noted. See also 183 Pure Urban 11 affordable housing. It is our view that the provision of additional A22.1. affordable housing within Hull needs careful consideration particularly if a new inward investment is to be maximised and the full economic, social and environmental change achieved. This is particularly the case in terms of the current challenging housing market which will strongly influence the early years of the plan.

There are some parts of the City where the provision of further

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 205

Company / Section Section City Council ID Your response Organisation number title response affordable housing will be inappropriate. Equally there will be some parts of the City where it will be more appropriate to encourage an alternative social and economic mix and therefore not requiring any affordable housing.

Given the challenging viability of many development opportunities The housing land in Hull, the provision of additional affordable housing could affect assessment will investment and delivery of development. This could fundamentally consider viability affect the economic and social aspirations of the plan. Matters of matters including financial viability are matters which are relevant to justify the the suggested provision of affordable housing as set out in PPS 3 and should be affordable homes reflected in the Core Strategy policy. requirement. See also A22.1. Friends of Options Option 11(C) and B.46: Second option is the only sustainable one. Support 256 Pearson Park 11 Waiting should not be an option, as Hull needs to be proactive. welcomed. It is a concern that Options 11 appears more like a preferred Noted. More options policy. Few options are actually put forward and they are options will be not mutually exclusive. They are statements of fact or intent. explored as part East Riding of Options of the housing 465 Yorkshire Council 11 It would be useful if the document set out options in relation to land assessment different affordable housing thresholds (in terms of percentage study which will requirements and site size), site size threshold for when a mix is include viability required, different density standards, etc. testing. Options A – agree a combined approach is needed, with city centre Support policy focusing initially on developing an aspirational market in the welcomed. Options city centre. 416 Hull Forward 11 Options B – indicative densities seem appropriate; is it appropriate Support to specify a minimum density sought (unless justified – depending welcomed. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 206

Company / Section Section City Council ID Your response Organisation number title response on what the minimum is)?

Options C – housing needs to be of good quality so it is reasonable Support to require that certain design standards are met. Presumably welcomed. Lifetime Homes and Secured by Design are fairly standard. Minimum sustainability standards should be required and higher standards encouraged where possible, with guidance provided to support developers in this. We are pleased to see the issue of affordable housing is covered in Support the Issues and Options document. The Assembly welcomes welcomed. paragraph B.50 which makes reference to the RSS affordable housing target for Hull. The Regional Housing Strategy 2005 identifies affordable housing need in the Hull district as being low. Policy H4 of RSS states that LDFs should set targets for the amount of affordable housing to be provided. Provisional estimates of the proportion of new housing that may need to be affordable in Hull are up to 30%. In Options 11 it is stated that in order to provide Yorkshire and for the needs of existing and potential residents it should be Options 362 Humber ensured that more affordable housing is provided by applying an 11 Assembly indicative local standard of 20% between 2008-2011, depending on the nature of the market. The Assembly would support this indicative target providing that this target is supported by local evidence from the Housing Market Assessment.

The Assembly is encouraged that the issue of housing mix is Support covered in this document. It is suggested that a possible option welcomed. should be to ensure that there is a more balanced housing mix in the city by seeking i) a greater proportion of large family homes; and ii) in the city centre or locations accessible to public transport,

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 207

Company / Section Section City Council ID Your response Organisation number title response high quality apartments. Policy H5 in RSS (2008) emphasises the need for the current mix of housing in the Region to change so that it better supports the creation of more sustainable communities. The Policy recommends that plans, strategies, investment decisions and programmes should ensure the provision of homes for a mix that reflects the needs of the area, including homes for families with children, single persons, and older persons, to create sustainable communities.

The Assembly is encouraged to see that the issue of Gypsy and See A26.1. Travellers is covered in Options 11. The RSS recommends that the Region needs to make additional provision to meet the housing needs of Gypsies and Travellers to address an overall shortfall of at least 255 pitches. Policy H6 states that in the Humber sub region at least 34 pitches will be required by 2010 to address the shortfall in the Region. Policy H6 also requires local authorities to carry out an assessment of the housing needs of Gypsies and Travellers by July 2008. We feel to further develop the policy it would be beneficial to incorporate these provision targets, at least as an interim position until a more detailed local assessment is finalised. Meeting Support

64 Gateway brownfield Para B.66. Gateway supports stepped approach. welcomed. targets It is recognised that national planning guidance encourages See A27.1. consideration of brownfield sites for development before greenfield Meeting sites. However, it is important to recognise that previously 108 Natural England brownfield developed land left derelict for periods of time can develop habitats targets of nature conservation importance. This issue should be considered within the policy approach to brownfield site development.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 208

Company / Section Section City Council ID Your response Organisation number title response

Natural England has no strong preference relating to Objective 12 options. Given the embodied energy within existing buildings (in terms of the See A28.1. materials used for their construction, the energy that was involved in moving those materials to the site etc) coupled with the energy which would be expended in the demolition of those buildings and the removal of the waste materials, this Objective should be more English Heritage Objective explicit in encouraging the reuse of existing buildings in preference 166 Yorkshire and 12 to their demolition and the redevelopment of a cleared site. Humber Region

Therefore, it would be preferable if the Objective was amended to read:- “To promote the most efficient use of land and premises in the city through the reuse of existing buildings, developing previously developed sites etc…” On the service hubs in Table B.8, we note that Spring Bank West Noted. really needs a large food store in the old Kwik Save premises. It is 208 Local resident Table B.8 a pity the Council’s Calvert service centre was not located nearer this possible hub. RSPB recommends that the LDF should also recognise that the See A28.1 biodiversity value of previously developed sites can be high. Paragraph 15 of PPS9 states that "where such sites have significant biodiversity or geological interest of recognised local Objective importance, local planning authorities, together with developers, 336 RSPB 12 should aim to retain this interest or incorporate it into any development of the site". We believe that all developments on brownfield land should be evaluated for their biodiversity potential, and where this is of local or greater importance a design scheme incorporating this into the development should be adopted. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 209

Company / Section Section City Council ID Your response Organisation number title response We in principal support option 12 (2) which promotes a realistic Support approach to brownfield completions, aiming for a rate of 60% over welcomed. See the entire plan period 2008-2026, with a lower rate of 50% at the also A29.1. start of the plan period. We consider that this approach is more appropriate to the Hull context, since Hull is in the unusual position of building out a large Greenfield allocation at Kingswood. However, we believe that the identified brownfield development proportion should not be applied rigidly and the emphasis should be providing the required rate of housing development even if this Options means additional greenfield development. 53 Barratt Homes 12 Though we support the targets set out within the document in principal, we believe that further evidence should be provided within the Core Strategy which identifies that the target of 60% is indeed a realistic and achievable target for the City over the course of the plan period. In consideration of the existing land supply constraints of the City, and the foreseen land availability issues of the future, we believe that the approach to the provision of brownfield development should be tailored accordingly in order to ensure the provision of the required rate of housing development. We in principal support option 12 (2) which promotes a realistic Support approach to brownfield completions, aiming for a rate of 60% over welcomed. See the entire plan period 2008-2026, with a lower rate of 50% at the also A29.1. start of the plan period. We consider that this approach is more Options 85 Kayterm Ltd appropriate to the Hull context, since Hull is in the unusual position 12 of building out a large Greenfield allocation at Kingswood. However, we believe that the identified brownfield development proportion should not be applied rigidly and the emphasis should be providing the required rate of housing development even if this

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 210

Company / Section Section City Council ID Your response Organisation number title response means additional greenfield development.

Though we support the targets set out within the document in principal, we believe that further evidence should be provided within the Core Strategy which identifies that the target of 60% is indeed a realistic and achievable target for the City over the course of the plan period. In consideration of the existing land supply constraints of the City, and the foreseen land availability issues of the future, we believe that the approach to the provision of brownfield development should be tailored accordingly in order to ensure the provision of the required rate of housing development. We support option 12 (2) which promotes a realistic approach to Support brownfield completions, aiming for a rate of 60% over the entire welcomed. See plan period 2008-2026, with a lower rate of 50% at the start of the also A29.1. plan period. We consider that this approach is appropriate to the Hull context, since Hull is in the unusual position of building out a large Greenfield allocation at Kingswood. However, the brownfield development proportion should not be applied rigidly and the emphasis should be providing the required rate of housing Kingswood Parks Options development even if this means additional greenfield development. 123 Development 12 Company Though we support the targets set out within the document in principal, we believe that further evidence should be provided within the Core Strategy which identifies that the target of 60% is indeed a realistic and achievable target for the City over the course of the plan period. In consideration of the existing land supply constraints of the City, and the foreseen land availability issues of the future, we believe that the approach to the provision of Brownfield development should be tailored accordingly in order to ensure the

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 211

Company / Section Section City Council ID Your response Organisation number title response provision of the required rate of housing development. As stated above with reference to Objective 2, ABP considers that Support a high percentage of development should be delivered on welcomed for previously developed sites. Not only will this reduce the Option 1. development pressure on open green spaces within the city, but also would make the best use of existing transport infrastructure, as Associated Options required by Policy YH7 of the RSS. It would also reduce the 294 British Ports 12 number of vacant and derelict sites in the city, making it a more attractive place to live and to invest.

In light of the above, ABP supports Option 1 Continue with the approach in the RSS in terms of seeking to ensure high levels of housing on previously developed sites. Options 12 sets out two options to brownfield development. The Support East Riding of Options completion of the Strategic Housing Land Availability Assessment welcomed. 467 Yorkshire Council 12 will inform this option. East Riding of Yorkshire Council would support those options that maximise the use of brownfield sites. Objective 12 (brownfield development targets) – need to clarify this Noted and relates to housing development only. support is Options welcomed. 417 Hull Forward 12 Options – the stepped approach suggested seem reasonable, and reflects the relatively high proportion of Greenfield development committed at Kingswood. Page 102. Support identification of district centres and clarification Noted. See also Future shopping 59 Gateway of their roles. This will be a key driver of the integrated regeneration A33.1. provision framework. Wildmoor (Hull) Future shopping Table B.7. Generally, it is agreed that a combination of the Support 72 Ltd. provision suggested options is appropriate as the preferred option. welcomed.

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Company / Section Section City Council ID Your response Organisation number title response Maintaining the three district centres as a distinct second tier in the hierarchy, behind the city centre, is supported, as is the designation of service hubs. However, three observations are made in this regard.

First, much greater emphasis should be placed on planning See A34.1, positively for the growth and expansion of centres, in line with the A37.1 and A38.1. policy position established by PPS6, and indeed the direction of travel indicated by draft changes to PPS6. Second, the service hubs should not just be a focus for future investment in local services, but for future investment generally in all centre uses. Third, any reference to Table B.7 should make it clear that this provides only a very broad indication of what might be appropriate, and that individual centres and development proposals will be assessed in line with their individual circumstances. Emphasis is correctly placed throughout the options document on See A34.1 and meeting needs at the local level. For example: A37.1.

Paragraph 2.13 and bullets -recognises issues including the development of Kingswood, re-focusing services around existing centres, re-establishing Orchard Park, and developing sustainable Dransfield Future shopping communities 122 Properties Ltd provision Paragraph A.11 -supports the creation of sustainable communities, with quality shopping facilities

Paragraph B.72 -supports investment in shopping to meet people's needs, in locations accessible to all neighbourhoods

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 213

Company / Section Section City Council ID Your response Organisation number title response Objective 13 -promotes a network of centres across the city, making shops and services accessible to all neighbourhoods

Options 13 -supports development across Hull's centres generally, and promotes the role of enhanced service hubs

In this context, the emphasis of the Core Strategy should be on planning positively for the growth and expansion of Hull's centres, in line with the policy position established by PPS6, and indeed the direction of travel indicated by draft changes to PPS6.

However, there is conflict between this position and the evidence base underpinning the Core Strategy. The Retail and leisure Study Update (Nathaniel Lichfield & Partners, September 2006) is based on the assumption that Hull's local and district centres will lose comparison goods market share, and this will be directed instead to the city centre (a comparison between their tables 3C and 4C shows that market share apportioned to the city centre increases at the expense of other centres in Hull).

Effectively, this advocates a position whereby the centralisation of non-food shopping to the city centre is to be planned for, at the cost of shopping at the local level in centres serving neighbourhoods across the urban area. This is inappropriate for Hull, and inconsistent with the emerging policy direction summarised above, i.e. meeting needs at the local level and supporting sustainable communities.

It is not clear how the results of the Retail and leisure Study (table 8C of that document) are translated into the suggested Response to the Hull Core Strategy issues and options report, June 2008 October 2008 214

Company / Section Section City Council ID Your response Organisation number title response development needs set out in table 4.2 of the options document. This identifies local non food shopping needs of approximately 17,500 sq m between 2008 and 2014. If this figure is indeed derived from the results of the Retail and leisure Study, and relies on the assumption contained therein that market share should be diverted from Hull's smaller centres to the city centre, then it is inconsistent with the policy direction established throughout the options document.

In conclusion, the derivation of the local non food shopping figure (and indeed other retail floorspace figures) set out in table 4.2 of the options document should be clarified and made explicit, in a supplementary retail report if necessary. If it is derived from the Retail and Leisure Study, and hence relies on the assumption that the market share of local and district centres should decline, it should be revised upwards to reflect, at least, a constant market share position. Para.B.75 - B.76 (also Table 4.2). The options document makes it See A36.1 – clear that a comprehensive and sound evidence base is required to A36.2. support the Core Strategy. For retail and centres issues, the evidence is in the form of Nathaniel Lichfield & Partners' September 2006 Retail and leisure Study Update. This is introduced and Dransfield Future shopping summarised at paragraphs B.75 and B.76. It is assumed that the 129 Properties Ltd provision results of the Retail and leisure Study Update inform the data in table 4.2, but it is not clear how they are translated into that table.

For comparison goods retail, the Retail and leisure Study has a number of shortcomings. One of these -the assumption that market share in Hull's city centre should be increased at the expense of its

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 215

Company / Section Section City Council ID Your response Organisation number title response local and district centres -is the subject of a separate representation.

However, a second shortcoming is the very low growth rate in per capita spending on comparison goods assumed in the Retail and leisure Study. Paragraph 3.7 of the Study identifies a growth rate of 3.7% p.a. for the period 2004 -2013, but only actually applies this to the period beyond 2013, using instead a much lower figure (3% p.a.) for the period 2008 -2013. Forecasts produced by others (Oxford Econometrics in Map lnfo Information Brief) are much higher at 5.3% p.a. for the period 2005 -2017, whilst the project growth rate in the same document lies in the range of 4.9% -5.6% p.a.

In conclusion, the derivation of the local non food shopping figure (and indeed other retail floors pace figures) set out in table 4.2 of the options document should be clarified and made explicit, in a supplementary retail report if necessary. If it is derived from the Retail and leisure Study, and hence relies on the assumption that the market share of local and district centres should decline, and on unreasonably low growth rates, it should be revised upwards to reflect, at least, a constant market share position, and a higher growth rate of the order indicated above. Henderson Future shopping Para B.76. The ability of Quay West to meet major non-food Noted. 319 Global Investors provision shopping needs to 2016 is agreed. Para B.78. The identification of the City Centre at the top of the Support Henderson Future shopping shopping hierarchy and the prime focus for shopping in the city and welcomed. See 321 Global Investors provision into the wider catchment, including East Riding of Yorkshire, is A35.1. supported.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 216

Company / Section Section City Council ID Your response Organisation number title response Table B.7. The classification of typical sizes is acknowledged with Noted. Henderson Future shopping 322 the rider that the ‘major shopping centre’ tier would normally Global Investors provision exceed 20,000 sq m (up to 100,000 sq m). Henderson Future shopping Para B.75. This paragraph should make it clear that the future Noted. 317 Global Investors provision floorspace requirement excludes commitments. Para B.76: As there is already vacancy, it should be apparent that Noted. Quay West is surplus to requirement. To fix up a blighted area is Friends of Future shopping fine; to build even more shopping malls is a very bad idea. 257 Pearson Park provision Table B.8: Most local people would not agree that Newland Ave. has improved streetscape. Certainly bus drivers would not agree. The Highways Agency supports the development of service hubs to Support provide a focus for future investment for provision of local services welcomed. Highways Future shopping in the Quality of Life chapter. It is felt that the promotion of the 227 Agency provision amount of local services aligns with the sustainable development principles of reducing the need to travel, particularly by the private car. Map B.1. shows the location of different local centres within the city. Noted. The catchment of local centres within East Riding could also East Riding of Future shopping usefully be shown (sites within the East Riding are helpfully shown 468 Yorkshire Council provision in map B.2). East Riding of Yorkshire Council is nearing completion of a Retail and Town Centre study and can supply relevant information. Table B.8. The concept of "Service Hubs" and in particular the See A34.1. proposed designation of Holderness Road as a hub is supported. Dransfield Future shopping 430 However, the information set out in Table 8.8 underpinning this Properties Ltd provision proposal should be recast better to reflect appropriate proposed action in the centre. In formulating service hub policy, and in any

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 217

Company / Section Section City Council ID Your response Organisation number title response supporting text in the Core Strategy, this should be corrected to read;

"Maintain and enhance its role, expanding but also consolidating facilities, concentrating investment and the proposed service hub within the area between the north side of Holderness Road, and Mount Pleasant." Map B.1. If map B.1 is to be used and referred to in the Core Noted. Strategy it should be corrected to identify the different types of centre it illustrates. At present, it purports to show Hull's local Dransfield Future shopping centres. In fact, it also shows the district centres, but these are 431 Properties Ltd provision illustrated in the same way as local centres. For the avoidance of doubt, a distinction should be made in the shading and key to show that they are not local centres, but in fact occupy a higher position on the hierarchy. Table B.7. Generally, it is agreed that a combination of the Support is suggested options is appropriate as the preferred option. welcomed. Maintaining the three district centres as a distinct second tier in the hierarchy, behind the city centre, is supported, as is the designation of service hubs. However, three observations are made in this regard. Dransfield Future shopping 432 Properties Ltd provision First, much greater emphasis should be placed on planning See A34.1, positively for the growth and expansion of centres, in line with the A37.1 and A38.1. policy position established by PPS6, and indeed the direction of travel indicated by draft changes to PPS6. Second, the service hubs should not just be a focus for future investment in local services, but for future investment generally in all centre uses. Third, any reference to Table B.7 should make it clear that this

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 218

Company / Section Section City Council ID Your response Organisation number title response provides only a very broad indication of what might be appropriate, and that individual centres and development proposals will be assessed in line with their individual circumstances. Para.B.87 - B.92. The change proposed at Paragraphs B.87 - B.92 Noted. (to introduce nine service centres / hubs) is a positive one and should be pursued through the Core Strategy. However, it is important in translating this into policy that a clear vision is provided as to what the role and function of these enhanced centres will be. Some of the themes in this regard are expressed in the Issues, Options and Suggested Preferred Option paper, but they need to be distilled into clear policy.

Dransfield Future shopping 433 The key themes in this regard are that these centres should: Properties Ltd provision

Provide a focus for enhanced and expanded public and private services,

Provide a focus for enhanced and expanded retailing,

Provide a focus for regeneration, funding and investment,

Provide a focus for public transport Paragraphs B.75-B.76. British Land recognise that, by virtue of the Noted. See also recent opening of the St. Stephens Centre and the committed Quay A36.1 – A36.2. West scheme, there is no need to make further provision or identify Future shopping 346 British Land land within Hull City Centre for additional comparison goods provision floorspace until after 2016.

Paragraph 4.36 of PPS12 outlines that a Core Strategy must be

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 219

Company / Section Section City Council ID Your response Organisation number title response justifiable, namely founded on a robust and credible evidence base. Whilst it is acknowledged that the Hull Retail Study 2003 was reviewed and updated by Nathaniel Lichfield & Partners in 2006, that study still relies on the results of a household shopper survey undertaken in 2002; this pre-dates the opening of the St. Stephens Centre, and whilst allowance is made for increased retention rates, the study must be open to criticism that it does not reflect existing shopping patterns. The Hull Retail Study should, therefore, be kept under review and updated as the Core Strategy is progressed toward submission stage. Paragraphs B.77-B.81 Support welcomed. Future shopping 347 British Land British Land entirely support the recognition (at paragraph B.78) provision that Hull City Centre should be the prime focus for shopping in the City. Paragraphs B.82-B.86 See A39.1.

Paragraph B.84 of the Core Strategy explains that there are a number of 'retail parks' in the City that tend to be large in size, often occupied by national retailers attracting people from a wide catchment. It is outlined that these 'retail parks' operate very Future shopping differently to traditional centres, providing limited services, and are 349 British Land provision not recognised in terms of national policy. On this basis, it is suggested that they should not be a focus for further retail development, especially where opportunities exist in the City Centre.

British Land recognise that retail parks are not generally identified as 'centres' (be it a local or district centre) in terms of national policy

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 220

Company / Section Section City Council ID Your response Organisation number title response and that such locations should not be the focus for further retail development unless all of the tests (need, the sequential approach, scale, impact and accessibility) in PPS6 are satisfied. Paragraph B.84, as drafted, is however a misinterpretation of national policy which does not preclude the provision of further out of centre retail floorspace. Explicit reference should be made in paragraph B.84 to PPS6 in the context of the promotion of additional retail floorspace in out of centre locations. It is also worth noting that a retail park can perform a role similar to that of a local or district centre, dependent on the type of units and services provided; paragraph B.84 is an over-generalisation of the role of retail parks. Paragraphs 8.87-8.92 See A39.1.

Paragraph B.90 (and Table B.8) of the Core Strategy identifies the requirement for a 'service hub' to serve the northern housing development at Kingswood. This is anticipated to be developed as an 'important local centre' to provide residents in Kingswood with day-to-day shops and services. Table B.8 outlines that the new centre should be positioned sufficiently far enough away from Future shopping Kingswood Retail Park to ensure the centre is viable and serves a 350 British Land provision different local catchment area.

Whilst the requirement to provide goods and services for the new residential areas of Kingswood is accepted, British Land consider that the Core Strategy fails to evaluate all reasonable alternatives to a new stand alone centre at Kingswood, inconsistent with paragraph 4.38 of PPS12. The Kingswood Retail Park is identified in the adopted Hull City Plan as a Local Centre; it already performs a local shopping role, providing a range of both convenience and

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 221

Company / Section Section City Council ID Your response Organisation number title response comparison goods. The next stages of the Core Strategy should recognise this role, and the opportunity the Kingswood Retail Park offers to provide for an extended range of services, and identify it as an 'important local centre'. We consider that Paragraph B.76 should be amended to read ‘Key Noted. conclusions from the 2006 Hull Retail and Leisure Study’.

The first of these key conclusions states that ‘There is currently an Noted. See also excess of food and grocery shopping floorspace in the city and it is A36.1 – A36.2. estimated this will continue beyond 2016. This follows development of superstores at St Stephens and Mount Pleasant. This means that there is limited scope for further food shopping development until after 2016; we do not agree with this statement. Further to the point raised in relation to Table 4.2, the retail assessment, which accompanied the planning application, which was for the replacement of the Tesco store at Beverley Road, Hull, concludes Tesco Stores Future shopping 345 that there was a clear need identified for the proposal. Limited provision

Table B.7 sets out the typical range and size of uses expected in See A42.1. centres. The identification within the Large/Important Local Centres section of supermarkets as 500 – 1,000 sq m is smaller than the definition of supermarkets within PPS6, which are defined as comprising of less than 2,500 square metres of floorspace. Again we consider that in some cases the provision of a supermarket within a Large/Important Local Centre could be justified, based on the identification of a site specific catchment and detailed analysis relevant to this catchment.

Further to this, we would like to draw attention to the floorspace

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 222

Company / Section Section City Council ID Your response Organisation number title response difference between the stated typical size of facility (gross floorspace) 500 – 1,000 sq m (supermarket) for Large/Important Local Centres and the stated typical size of facility 5,000 – 10,000 sq m (superstore) for District Centres and the City Centre. Without justifications for the stated store sizes, we recommend that the PPS6 definitions of Supermarkets and Superstores (Within Annex A, Table 3) should be abided by.

Paragraph B.83 relates to future changes to the shopping centre Noted. hierarchy and account that needs to be taken to ‘superstores’ that serve the population of the city. We consider that the following should be added to this paragraph: ‘Food store development should be located where it is easily accessible for the catchment it may serve.’

Table B.8 depicts the proposed Actions and Status of Service Noted. Hubs. In relation to the Orchard Park proposed service Hub, we consider that opportunities to bring forward development of Orchard Park more quickly should be encouraged.

Furthermore, in relation to Table B.8, with the identification of the See A39.1. requirement for the creation of an Important Local Centre called Kingswood Village Centre, we consider that this would require the de-allocation of the current designation of the Kingswood Retail Park as an Important Local Centre. In support of this is the proposed policy within paragraph B.84. The Adopted Kingston Upon Hull City Council Local Plan defines Kingswood, Althorp Road, as an Important Local Centre. However, paragraph B.84 of the Hull Core Strategy issues, options and suggested preferred options document classes Kingswood, as a ‘retail park’. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 223

Company / Section Section City Council ID Your response Organisation number title response Furthermore, this paragraph states that retail parks operate very differently to local centres, as they tend to be retail outlets and provide limited services. It also states that ‘they are however not recognised as centres in terms of national policy and should not be a focus for further retail development, especially where opportunities exist in the city centre’. Table B.8. The concept of "Service Hubs" and the proposed Support designation of Northpoint as a hub is supported, the owners of the welcomed. district centre. However, the information set out in Table B.8 underpinning this proposal is incorrect. In formulating service hub policy, and in any supporting text in the Core Strategy, this should be corrected to read;

"This is a popular district centre with an extensive service provision, Wildmoor (Hull) Future shopping 428 but the current quality and quantity of shopping compares Ltd. provision unfavourably with Hull's other district centres. The centre functions as a service hub, although a number of these services require modernisation and / or upgrading. There is a resolution to grant planning permission for the rearrangement and expansion of this centre. Once Northpoint has been enhanced in this manner it will provide a model of what a service hub should be in terms of mix and accessibility, although there may still be scope for further improvements." Para.B.87 - B.92. The change proposed at Paragraphs B.87 -B.92 Noted. (to introduce nine service centres/hubs) is a positive one and Wildmoor (Hull) Future shopping should be pursued through the Core Strategy. However, it is 429 Ltd. provision important in translating this into policy that a clear vision is provided as to what the role and function of these enhanced centres will be. Some of the themes in this regard are expressed in the Issues,

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 224

Company / Section Section City Council ID Your response Organisation number title response Options and Suggested Preferred Option paper, but they need to be distilled into clear policy.

The key themes in this regard are that these centres should:

Provide a focus for enhanced and expanded public and private services .

Provide a focus for enhanced and expanded retailing

Provide a focus for regeneration, funding and investment .

Provide a focus for public transport Objective 13. For clarity, Objective 13 should be revised and See A43.1. expanded. There is an expectation that "centres" should perform a rounded role including, importantly, shopping, but also a range of public and private services -they should not therefore just be referred to as "shopping centres" or "service centres". The enhanced centres should be differentiated from other centres by being referred to as "hubs", and not "service centres" or "service Wildmoor (Hull) Objective 76 hubs". Ltd. 13

Objective 13 should read, "Provide a network of centres across the city to guide development that supports people's future shopping and service needs, and provides essential shops and services within easy access of all neighbourhoods. Within this network, designate a series of hubs with an enhanced role in meeting shopping and service needs."

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 225

Company / Section Section City Council ID Your response Organisation number title response For clarity, Objective 13 should be revised and expanded. There is See A34.1. an expectation that "centres" should perform a rounded role including, importantly, shopping, but also a range of public and private services -they should not therefore just be referred to as "shopping centres" or "service centres". The enhanced centres should be differentiated from other centres by being referred to as Dransfield Objective "hubs", and not "service centres" or "service hubs". 138 Properties Ltd 13 Objective 13 should read, "Provide a network of centres across the city to guide development that supports people's future shopping and service needs, and provides essential shops and services within easy access of all neighbourhoods. Within this network, designate a series of hubs with an enhanced role in meeting shopping and service needs." Objective Reflect that development should be commensurate with the role Noted. 418 Hull Forward 13 and function of the shopping/service centre in question. With regard to the proposals in respect of retail, the Issues and See A40.1. Options Paper identifies three ‘District Centres’, five ‘Large Local Centres, 21 ‘Important Local Centres’ and 44 ‘Small Local Centres’. The retail options draw on a Retail Study (2006), and the main findings of this study are summarised in the Issues and Options Kingswood Parks paper as: Options 124 Development 13 Company • There is currently an excess of food and grocery shopping floorspace in the city and it is estimated this will continue beyond 2016.

• Short-Medium term scope for improvements in non-food retailing to 2016, but much capacity was considered as ‘accounted for’ in

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 226

Company / Section Section City Council ID Your response Organisation number title response existing proposals.

• Excess of non-food retail warehousing.

• Hull has a good selection and growth potential of commercial leisure uses.

• There is a significant vacancy rate within shopping centres.

However, we consider that a main conclusion of the Retail Study which was omitted from the summary in the Core Strategy Issues and Options paper, is the problem of ‘retail leakage’ to other centres outside of Hull. Based on the 2005 shopping patterns, the study noted that: “The estimated comparison goods expenditure currently attracted by shopping facilities within the City as a whole at 2005 is £798.54 million… Comparison expenditure retention within the City (zones 1 to 4) is assumed to be about 89%” (para.3.24). “The assessment of existing shopping patterns in 2005 indicates that there is some comparison expenditure leakage from Hull” (para. 3.35).

The report goes on to state that ‘it may be possible for Hull … to further increase its markets share if new development significantly improves the range, choice and quality of retail provision’ (para. 3.36). We consider that this issue of retail ‘leakage’ or ‘drift’ out of Hull is not one that has been adequately considered in the Issues and Options paper, in terms of measures that could be adopted to reverse this trend. We consider that more thought needs to be given to the proposed retail hierarchy, in particular, as to how it can be improved and strengthened to reverse the trend of retail leakage Response to the Hull Core Strategy issues and options report, June 2008 October 2008 227

Company / Section Section City Council ID Your response Organisation number title response to other centres outside of Hull.

For example, with regard to existing Retail Parks, including that at Kingswood, we note that these important places of retailing are not acknowledged in the ‘retail hierarchy’ at all. Paragraph B.84 states: “A number of ‘retail parks’ also exist in the city at St. Andrews Quay, Clough Road, Kingswood and Kingston Retail Park. These consist of units that tend to be large in size, often occupied by national retailers that attract people from a wide catchment, often city wide and beyond. They therefore operate very differently to local centres. They tend to be retail outlets and provide limited services. They are attractive because of the amount of parking and relative ease of access. They are however not recognised as centres in terms of national policy and should not be a focus of further retail development, especially where opportunities exist in the city centre.”

We do not agree with this assessment which suggests that these retail parks operate differently to identified centres. In particular, we consider that the retail and leisure park at Kingswood does operate as a ‘centre’ and should, therefore, be acknowledged in the Retail Hierarchy. We consider that strengthening the Kingswood leisure and retail offers in this way would assist in reducing, if not reversing, the retail leakage to other locations and would be an option that is supported in planning policy.

PPS6 allows for changes to the role and status of local centres (para. 2.10) and states that ‘local planning authorities should, through the core strategy development plan documents, set out a spatial strategy for the network and hierarchy of centres, including Response to the Hull Core Strategy issues and options report, June 2008 October 2008 228

Company / Section Section City Council ID Your response Organisation number title response local centres, within their area, setting out how the role of different centres will contribute to the overall spatial vision for their area’ (para. 2.15). PPS6 also includes the provision for the identification of new local centres. New centres are encouraged through the plan-making process in areas of significant growth, where there is a need for better access to services, facilities and employment (para. 2.54). Factors influencing the decision-making process regarding new centres include accessibility by various modes of transport. Indeed, Para. 2.54 of PPS 6 specifically notes that there is allowance for existing out-of-centre retail developments, comprising or including main town centre uses (such as shops, shopping centres, leisure parks or retail warehouse parks), to be identified as a new ‘Centre’ through Development Plan Documents.

In this regard, we consider that there is considerable scope to include the retail and leisure park at Kingswood as a ‘Centre’ in its own right, with a place in the retail hierarchy, as a measure to improve Hull’s Retail offer and reverse the trend of retail leakage out of the City.

Indeed, the Kingswood Retail Park was originally designed as a District Centre and when assessing the facilities typically found in a District Centre, it is noted that Kingswood performs well. It has a superstore, national multiples, a chemist, restaurants/take away and a public house. The adjacent leisure park with its range of leisure facilities is also important in contributing to the functions and offer of the ‘centre’. Together the Kingswood Retail and Leisure Parks act as a ‘District Centre’ and should be allocated as such.

The allocation of Kingswood as a District Centre would provide Response to the Hull Core Strategy issues and options report, June 2008 October 2008 229

Company / Section Section City Council ID Your response Organisation number title response scope for the provision of additional shops and non-retail services such as banking/post office to further strengthen the Centre. This is particularly important in north Hull as there is a need to reduce the “leakage” of retail expenditure to the East Riding centres such as Beverley and the expansion of the Kingswood District Centre would be well placed to achieve this.

From Conclusion

In terms of retail development and the retail hierarchy, we have suggested that the LPA should consider an option of identifying the Kingswood Leisure and Retail Park as a District Centre, to be included in the retail hierarchy, in line with allowances in PPS 6 for the delivery of new retail centres.

In essence, we consider that there is significant scope for Hull City Council to continue to promote, and indeed, expand Kingswood as a strategic and essential element of future development in Hull. We will therefore welcome new allocations for housing and retail through the LDF and consider that the Core Strategy should support future development in this location. The Core Strategy document recognises that there is significant See A44.1. investment in new shops and services taking place in the City. The Bank is one such investor and supports the principle of a strong Options City Centre that provides easy access to essential shops and 304 Barclays Bank 13 services (Objective 13). In our representations on the City Centre Area Action Plan (CCAAP) we expressed concern that the support for financial service retailers set out in the adopted 2000 Hull City Plan is not explicit in the CCAAP and we are equally concerned

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 230

Company / Section Section City Council ID Your response Organisation number title response that the Core Strategy is also silent on the matter. The adopted plan recognises that "Jobs in financial communications, business and public services (Use Classes A2 and B1) are very significant in the City Centre" and saved Policy CC4 actively supports such development. That situation has not changed and broadening the base of the City Centre should form a key part of any strategy for strengthening and regenerating the City.

The Core Strategy document acknowledges the risk to the City Centre posed by the loss of trade to other competing centres. In order to be successful, town centres need to provide a full range of services and these usually need to be located in ground floor premises in accessible locations. The alternative to diversity can be long-term vacancy and decline. It is therefore also essential that economic factors should be the main driver of change (option 3 of 'Options 3'). In our response to the CCAAP we emphasised that Banks are important contributors to town centres and significant attractors of visitation and that this key role in underpinning town centres and assisting in regeneration should be recognised in all the policies on the matter of promoting town centre vitality and viability within the LDF.

We therefore urge the City Council to recognise and make specific reference in the Core Strategy, as well as in the CCAAP Policies, to the importance of banks as major attractors of visitation and their role in supporting the vitality and viability of the City Centre. It will be particularly important, as the focus shifts in the City as a consequence of qualitative and quantitative improvements in floorspace provision, to ensure that banks and financial services also have the opportunity to improve their position. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 231

Company / Section Section City Council ID Your response Organisation number title response We agree the Options here. There appears to be no mention of Support Prince’s Avenue, which has a range of shops and restaurants but welcomed. which risks losing character if bars predominate. Prince’s Avenue Local resident Options 209 and Spring Bank between them constitute a shopping area of some 13 importance, relatively near, but distinct from, the City centre. The character of these areas is changing however, and this needs consideration. Whilst British Land do not object to the general approach to Noted. identifying options for future shopping provision within Hull, namely to focus further provision within the City Centre or other identified Options 351 British Land centres in the retail hierarchy, the drafting of Option 13.1 is poor 13 and is inconsistent with guidance contained in PPS6. As it stands, Option 1 could not be considered to pass the soundness test embodied in PPS12 and should be amended accordingly. In relation to potential options, we strongly support Objective 13. Support Furthermore, we generally support option 13, point 1, in order to welcomed. achieve this. However, we consider that the option should be Tesco Stores Options amended to read ‘where floorspace is required, support new 348 Limited 13 shopping provision within, or which is readily accessible to, existing centres, in or on the edge, or closely related to the population that it serves (provided it is suitable in location, and is related in scale and nature to the role of that centre)’. Core strategy policy and supporting text needs to reinforce support Noted. Options 419 Hull Forward for the city centre, particularly to 2016. Is there a need to 13 incorporate anything additional to strengthen this point? Friends of B.101. There are already too many hotels for the number of people Noted. 259 Tourism Pearson Park using them. And the last thing Hull needs is more pubs.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 232

Company / Section Section City Council ID Your response Organisation number title response Para. B.101. A concentration of cultural facilities and activities can See A45.1. act as a magnet for visitors and provide a significant boost to the local economy. Cultural services and tourism are inter-dependent, with tourists being attracted by museums, theatres, heritage sites, arts, sport, entertainment venues, festivals and events.

Future leisure, arts and cultural facilities should be located within the town centres and be part of a successful mixed-use environment with visiting audiences enlivening the surrounding The Theatres 193 Tourism area in the evening, and providing regular custom for local bars and Trust restaurants outside normal working and shopping hours.

The Trust requests that the document provides sufficient protection to ensure continued theatre use within the city, particularly where buildings for performance arts may not be covered by listing or conservation area designations, or may be affected by proposals which come forward for development sites. This should include performing arts facilities that stand-alone, are part of other facilities, or are contained within educational or community buildings. In the section on tourism the Highways Agency supports the Support Highways 228 Tourism location of tourism related activity in the city centre close to the key welcomed. Agency public transport networks. Hull Access Ensure all tourist sites present and new build meet the needs of Noted. Objective 24 Improvement disabled people, nationally many tourist activities do not offer full 14 Group accessibility, Hull could promote itself as a fully accessible city. Objective 14 provides support for major tourism and leisure related Support Yorkshire and Objective businesses within the city centre and in a following a sequential welcomed. 363 Humber 14 approach or is readily accessible to frequent public transport Assembly provision. This approach is in line with Policies YH4 and E2 of RSS. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 233

Company / Section Section City Council ID Your response Organisation number title response The objective of the Core Strategy is to ensure an adequate range See A47.1. of, and access to, tourism and business related leisure uses, with the main focus being on the City Centre.

However, WLL considers that it is appropriate the Core Strategy (option 14(2)) also looks to locations outside the City Centre for major land uses where these uses can bring demonstrable and major regeneration benefits.

An example of a potential location where tourism and business Wrenbridge Land Options 150 related leisure could be accommodated, outwith the core city Limited 14 centre, is the KC Stadium which is located centrally within the NASA regeneration area. This would have the benefit of providing further investment at a key site on a primary route into the core of the City Centre, delivering further job opportunities and assisting in addressing deprivation.

Accordingly, development of leisure facilities in conjunction with the stadium would assist in creating a sporting and leisure/recreational hub within one of the City's main regeneration priorities, the Core Strategy should recognise this. Option 14.1 To the list of facilities B.101 required by tourists should Noted. be added (1) conveniently and agreeably sited seating (much city Options centre seating is awkwardly placed; it should ideally be in a 210 Local resident 14 potentially sunny place and have a pleasant or neutral view), and public conveniences (these should be open at times when visitors might need them). Friends of Options I have always advocated architectural tours to the Avenues area Noted. 434 Pearson Park 14 and parks tour -both ideas would improve tourism offers.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 234

Company / Section Section City Council ID Your response Organisation number title response Options Support 420 Hull Forward Agree (1) to place the primary focus on the city centre. 14 welcomed. Natural England believes that as part of healthy living Green Noted. See also Infrastructure should be part of the solution and therefore we A15.1 – A15.2. recommend that the Core Strategy should include a definition of Green Infrastructure, for example: ‘Green Infrastructure comprises the provision of planned networks of linked multi-functional green spaces that contribute to protecting natural habitats and biodiversity, enable response to climate change and other biosphere changes, enable more sustainable and healthy lifestyles, enhance urban liveability and wellbeing, improve the accessibility of key recreational and green assets, support the urban and rural economy and assist in the better long term planning and management of green spaces and corridors.’

109 Natural England Healthy living Investment in retaining, enhancing and extending green infrastructure - multi-functional networks of green space and natural features - is increasingly an integral component of developing sustainable communities through spatial planning. The recently revised PPS12 requires local planning authorities to facilitate green infrastructure provision through their Local Development Frameworks. The Hull Core Strategy Issues and Options document provides no mention of green infrastructure. In line with PPS12, Natural England expects to see a specific green infrastructure policy to implement the principles and guidance provided by the Regional Spatial Strategy. Such a cross cutting policy would also help bring cohesiveness to the Core Strategy by linking, for example, Health and Quality of Place Objectives and Options (15 and 17).

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 235

Company / Section Section City Council ID Your response Organisation number title response

We also support ‘- having access to open spaces for walking and other activities’ (B113 p 109).

There is growing recognition of the benefit of green infrastructure to the health and physical and mental wellbeing of urban communities, especially access poor communities and vulnerable groups. p. 105, B.110: Remove word "often" from third line. Noted.

p. 106, B. 112: "Deprivation levels" is just an excuse. No one is Friends of 260 Healthy living forcing people to drink or to smoke, and benefit money (far too Pearson Park many people in Hull, quite able-bodied on benefit) is used to support these habits. Nor can you force people to eat the healthy five and obviously suggesting such does not work. I remark in connection with B111 that I thought all public places Noted. were now smoke-free. The Council itself recently attempted to go Local resident Objective 211 against Option 1 by applying for permission to build a school on an 15 open green space. If there are to be plans, they ought to be clear and robust, and the Council should follow them. Research has demonstrated that people's health and quality of life See A15.1 – can be improved through having access to wildspaces and having A15.2. the opportunity to experience nature in their day-to-day lives. The RSPB strongly supports policies that ensure developments accord Objective 337 RSPB with biodiversity by incorporating or creating high-quality green 15 space. Existing areas of greenspace should be enhanced for wildlife to include features such as hedgerows, trees and ponds. Cycle and footpath networks could be enhanced to create green corridors for wildlife and for people. We believe in maximising the Response to the Hull Core Strategy issues and options report, June 2008 October 2008 236

Company / Section Section City Council ID Your response Organisation number title response opportunities to restore and create habitats for wildlife which will help meet Biodiversity Action Plan targets for Priority Species and Habitats. In Objective 15 we support (Options 1, 2 & 5 page 110,) this will Support Options help to improve and support additional open space which should welcomed. 110 Natural England 15 also include green infrastructure and open space to ANGst recommendations. We note the concern expressed in paragraphs B110 to B112 about See A15.1 – aspect of the health of people in Hull and particularly lack of A15.2. exercise and obesity. It is good that in paragraph B113, you recognise the importance of having access to open space for walking and other activities and that in Option 15 you “support the provision of accessible open space and outdoor or indoor sport facilities, following an assessment of what is needed”.

We believe that this green open space, which is often referred to as “green infrastructure” needs to be made up of a variety of different The Woodland Options types of green space which can fulfil a range of functions, from 155 Trust 15 sports facilities through to areas of high biodiversity value and in particular woodland.

A Strategy for England’s Trees, Woods and Forests’ (Defra, 2007, para 30) sets out the Government’s vision for England’s tree and woodland resource over the next 50 years, stating that “Green infrastructure is a network of green spaces in and around towns, and between urban and rural areas. It may include open spaces, parks, water bodies and nature reserves as well as street trees and woodlands….Trees and woodlands – from a country park to an urban street – are a very important element of green infrastructure

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 237

Company / Section Section City Council ID Your response Organisation number title response for several reasons”

We believe that everyone should have a right to have multifunctional green space within easy reach of their homes. For this reason, we would like to see your assessment of what green infrastructure is needed based upon the concept of access standards. Natural England have developed an access standard for natural green space and we have developed a Woodland Access Standard (which is complementary to the Natural England one).

We have set out in the table below how Hull performs against our Woodland Access Standard and how it compares with the neighbouring council of East Yorkshire and Yorkshire and Humber Region as a whole.

Table 1: Accessibility to Woodland in Hull using the Woodland Trust Woodland Access Standard

Hull ERYC Y&H Region

Accessible woods % population with access to 2ha+ wood within 500m 1.72 1.57 13.09

% population with access to 20ha+ wood within 4km 0 4.80 55.60

Inaccessible woods % extra population with access to 2ha+ wood within 500m if existing woods opened 3.52 15.01 24.92

% extra population with access to 20ha+ wood within 4km if existing woods opened 6.68 61.06 28.33 Response to the Hull Core Strategy issues and options report, June 2008 October 2008 238

Company / Section Section City Council ID Your response Organisation number title response

Woodland creation % population requiring new woodland creation for access to a 2ha+ wood within 500m 94.75 83.42 61.99

% population requiring new woodland creation for access to a 20ha+ wood within 4km 93.32 34.15 16.07

Minimum area of new woodland required for 2ha+ woods within 500m (ha) 128 537 5,199

Minimum area of new woodland required for 20ha+ woods within 4km (ha) 23 581 1,900

From the table it can be seen that both Hull and East Yorkshire residents have very poor access to woodland compared to the region as a whole. This is discussed in more detail in our comments on Urban Greenspace below. East Yorkshire Noted. Option 15.5. Recent research shows layout of buildings determines and Derwent Options 301 whether the public walk/cycle, or use their car. Preservation of Area Ramblers 15 snickets betweens developments is therefore important. Association Page 111. No reference to Princess Royal Hospital closing and that Noted. Health care 60 Gateway future use would be determined through Holderness Road Corridor provision AAP. Improve the physical access to the health care centres, the use of Noted. Hull Access Objective reflective materials, glass and steel does not provide an accessible 25 Improvement 16 facility. HAIG agrees that providing the health care facilities near to Group other amenities is a good idea and will assist disabled people.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 239

Company / Section Section City Council ID Your response Organisation number title response Objective Noted. 212 Local resident A laudable ambition, but the Council’s role in this is limited. 16 I disagree with option 16.3, and believe that health care facilities Noted. Friends of Options 264 should be separate. Health is too important an issue to be lumped Pearson Park 16 with other options. B.142 Design and Access Statements Noted.

These have not worked well with regards to improving accessibility, more understanding of ‘access’ issues needs to be gained by all in Hull Access the Council, planning department and in building control.

31 Improvement Quality of place Statements in DAS like the ‘premises have a car park’ show how Group little understanding some applicants have on these matters. We cannot expect every lay person to understand these issues but by not challenging fully these topics poor access is continuing. The DAS is sometimes used to justify reasons for poor access, we do not consider there is ever a reason for this. Page 113. Quality of place section could be strengthened by Noted. We will reference to everything that is needed to create and deliver quality develop a and sustainability, possibly a checklist? If place making is the key checklist function of the LA as seen by government we need to demonstrate approach for the 61 Gateway Quality of place more clearly, how we are delivering it. next draft document. Page 113, para.B.140. This does not capture the quality of place very well. Page 114, para.B.142. We would welcome the production of a Noted and English Heritage design framework covering the whole of the City. This would greatly support 167 Yorkshire and Quality of place assist in helping to ensure that new development compliments and, welcomed. Humber Region where appropriate, reinforces, the distinctive character of the

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 240

Company / Section Section City Council ID Your response Organisation number title response various parts of Hull. The Council’s Conservation Area Appraisals would form a useful starting point for those parts of the City which are designated as Conservation Areas. Page 114, para.B.142. Natural England believes that all towns and Support cities should be locally distinctive and design should enhance and welcomed. improve the living environment of the local residents. We therefore support the para B142 relating to a design framework being based on local character assessment.

Additional item Site Protection.

The Core Strategy needs to reflect the proximity and protection of See A15.1 –

111 Natural England Quality of place the adjacent Humber Estuary SPA and SAC, Ramsar sites, SSSI A15.2. and Natura 2000 network, one of the most important sites in Europe for wildlife. Development within the Hull area can have direct or indirect effects on European protected sites, and these need to be considered within the Local Development Framework. The Core Strategy needs to fully reflect PPS7 and PPS9 guidance in relation to protection of designated landscapes and wildlife sites. Para B140 and B150 needs to recognise these International, National and Regional important sites and include a core policy to ensure there protection and enhancement. p. 114, B. 144: Unfortunately, area committees, such as Wyke, are Noted. Friends of a bad idea in the first place and have done nothing in our area to 267 Quality of place Pearson Park improve environmental quality; it is all being done by community groups. English Heritage We broadly support the thrust of this Objective which will assist in Support Objective 168 Yorkshire and the helping to make the city a more attractive location in which to welcomed. 17 Humber Region live and invest. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 241

Company / Section Section City Council ID Your response Organisation number title response

However, given the intention within the Vision of the Core Strategy to “maintain the distinctive feel” of the City’s neighbourhoods (and mindful of the advice of PPS1 Paragraph 38), it might be better if Objective 17 included specific reference to ensuring that new development is appropriate for its context and reinforces the distinctive character of the various parts of the city.

In addition, the reference to “conserving the historic character of the city” could be deleted since this aspect replicates that contained within Objective 19. Thus, it might be preferable if Objective 17 was amended along the following lines:-

“Promote high-quality design that responds to its local context, reinforces local distinctiveness, and raises environmental quality of the across the City” This is important, and the Council could and should do much in this Support Local resident Objective 213 respect. The Options under the headings Climate Change, welcomed. 17 Flooding, and Housing are also relevant here. Disabled people generally do not get fully consulted on Noted. developments in the city. Including the major ones e.g. Interchange, Boom Bridge over river Hull, Fruit Market redevelopment; The LDF Statement of Community Involvement clearly sets out how Hull Access Options consultation should take place. However when groups such as 30 Improvement 17 HAIG are consulted many issues raised are ignored. Architects, Group designers and planners seem to think they know more about the issues disabled people face than the people themselves, this is not good consultation and has resulted in some very costly mistakes.

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Company / Section Section City Council ID Your response Organisation number title response Option 17. 2, HAIG agree with the review of existing design Noted. guidance, planning needs to be able to take account of the present needs of disabled people and the changing attitudes and aspirations of disabled people.

Option 17, 4, Proposals determined on their own merit is fine but it Noted. needs to be shown that meaningful consultation has taken place and that design issues that affect access and disabled people have been fully dealt with and not ignored.

Option 17, 6, HAIG support the principle that “all development is Support accessible” we assume that this refers to all of the community, We welcomed. would like to see some wording which shows the Council's commitment to higher accessibility standards. English Heritage Support Options We support the approach to deliver Objective 17 as set out in 169 Yorkshire and welcomed. 17 Paragraph B.147. Humber Region Options Page 117, Options 17.1, 17.2 and 17.6. Natural England supports Support 114 Natural England 17 Objective 17, (options 1, 2 & 6 pg 117) welcomed. Agree that a combination of options is appropriate. The text implies Support a lack of or very limited resource to provide a city-wide design welcomed. Options framework. Suggest a targeted approach to develop guidance for 421 Hull Forward 17 key regeneration areas, perhaps as SPDs to AAPs under preparation. City Centre design guidance is advanced and should be completed as a priority. Urban Noted. 65 Gateway Para.B.149. Needs a firm commitment to high quality public realm. Greenspace

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 243

Company / Section Section City Council ID Your response Organisation number title response Para. B.150 refers to “Hull has historically lacked green spaces.” See A15.1 – Suggest that there should be commitment to improving A15.2 and A16.1. greenspaces before they are given up for alternative uses. Suggest Hull aims to raise the quality and provision of locally accessible greenspace by benchmarking against national standards e.g. Green Flag Awards for parks and greenspaces generally managed by the local authority.

Urban 116 Natural England Suggest additional Option of “Work towards achieving Local Nature Greenspace Reserve designation or Green Flag accreditation to provide quality greenspaces.”

Natural England would like to see No net loss of greenspace. - Development proposals should not result in an overall loss of greenspace. Reference should be included in paragraphs: A.4. p 44, B22. p79, B119 p111, B151 p118, B152 p 118, B154 Options 18 No. 1 p119, B165 p121. The National Grid site contains a former private playing field See A32.1. (associated with the Gas Works that existed on the site). This is identified within the existing Hull Local Plan as being an Urban Green Space. The site has, however, not been used or maintained for this purpose for a significant period of time (since 1995). Its Urban value as an Urban Green Space is limited, endorsed by its lack of 194 National Grid Greenspace use, the provision of little visual amenity benefit, poor drainage and distance from any communities who may call upon its use.

Objective 18 of the HDF seeks to protect Urban Green Space where it is of value to the community. Such a valuation of Urban Green Space requires a quantitative and qualitative appraisal of all

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 244

Company / Section Section City Council ID Your response Organisation number title response existing spaces within the City; the City have recently embarked upon an audit of green space.

It is suggested within Option 18 of the HDF that in undertaking this review, sites that are identified as not being required for Urban Green Space should be allocated for alternative uses. National Grid support this Policy approach, and in the case of the site at Clough Road suggest that the area currently identified within the adopted Local Plan should be removed and allocated for mixed employment generating purposes within the appropriate emerging Local Development Document. * Need to protect existing green spaces in the Newland Avenue Noted. area and make what exists more accessible e.g. Sidmouth Street Playing Fields and Newland Avenue Playing Fields.

Urban * Green spaces ought to be recognised for their wide ranging 437 Local resident Greenspace benefits including community cohesion, crime reduction, health and general welfare.

* Children should not be hounded out by police for playing games that others consider as anti-social behaviour. We support this Objective. Hull’s green spaces help contribute to Support English Heritage Objective the character and setting of a number of the City’s historic assets welcomed. 170 Yorkshire and 18 and two of them are, themselves, designated as Historic Parks and Humber Region Gardens. Natural England welcomes Objective 18 and the accompanying Support Objective Options in relation to urban green space. However, we would like to welcomed. 119 Natural England 18 see more emphasis on the role of green space in urban areas as stepping stones for wildlife by providing corridors for species Response to the Hull Core Strategy issues and options report, June 2008 October 2008 245

Company / Section Section City Council ID Your response Organisation number title response migration and dispersal. The RSPB is concerned about the incorrect/missing information in See A15.1 – this part of the document (B.150) relating to the number of locally, A15.2. nationally and internationally designated sites. Most worryingly, there is no mention of the Humber Estuary Special Protection Area (SPA), which is designated for its migratory and wintering waterfowl and breeding Annex 1 species.

The RSPB wishes to point out that the Hull LDF should be in accordance with PPS9, and note paragraph 5 in particular which says that "Local development frameworks should: (i) indicate the Objective 338 RSPB location of designated sites of importance for biodiversity and geo- 18 diversity, making clear distinctions between the hierarchy of international, national, regional and locally designated sites; and (ii) identify any areas or sites for the restoration or creation of new priority habitats which contribute to regional targets, and support this restoration or creation through appropriate policies". The need for improved floodwater management capacity for Hull is likely to offer opportunities to restore or create priority wetland habitats.

We feel that biodiversity issues should be given more prominence in the Core Strategy and could be discussed in their own section. We support the overall approach of Objective 18 which aims to Support protect ‘valued’ urban greenspace from redevelopment once they welcomed. An have been identified. In consideration of Option 18 (3) we fully Open Space Options 54 Barratt Homes support the approach that existing urban greenspace could be Audit is nearing 18 developed for alternative uses such as housing where they are completion that identified as not being ‘valuable’ or ‘not needed’ in terms of both will help quality and quantity. determine value

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 246

Company / Section Section City Council ID Your response Organisation number title response of urban As discussed above, in consideration of the City’s land availability greenspaces. constraints, a potential means of delivering a proportion of the required additional land for housing development in the City is through the redevelopment of some of the City’s urban greenspace.

In accordance with Objective 18 and Option 18 (3), following the undertaking of a robust PPG17 assessment of the ‘value’ and ‘need’ of existing urban greenspace within the City, where existing urban greenspace is found to be either surplus to requirements or fails to meet an appropriate level of quality, we believe that these sites should be released for an appropriate alternative development, including housing. In addition, the results of such an assessment should also be used to identify sites where their potential release, or part release, for redevelopment could provide funding to be used to enhance remaining urban greenspace on the site or the enhancement of other sites located within an identified catchment area. Generally, it is agreed that a combination of the suggested options Noted. is appropriate as the preferred option. However, in combining these options, emphasis must be placed on protecting valued and important green space, not all green space irrespective of its value and importance. New development should increase the quantity Wildmoor (Hull) Options 86 and quality of green space, but only where appropriate, i.e. there Ltd. 18 should be no blanket requirement. Provision must remain to allow the consideration of the loss of green space to development on a case by case basis and on its own merits, e.g. allowing for development where the benefits it creates outweigh any loss of green space.

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Company / Section Section City Council ID Your response Organisation number title response The strategy should also seek to improve the Noted. character/appearance/amenity value of important existing green English Heritage spaces within the city. As currently worded, Option 2 appears to Options 171 Yorkshire and simply refer to the creation of new green spaces as part of new 18 Humber Region developments. In some cases, commuted payments might be used for the improvement of nearby existing spaces within the City rather than providing additional new areas. Options Support 120 Natural England Natural England supports Objective 18 (Options 18 all 5 p117). 18 welcomed. We support the overall approach of Objective 18 which aims to Support protect ‘valued’ urban greenspace from redevelopment once they welcomed. An have been identified. In consideration of Option 18 (3) we fully Open Space support the approach that existing urban greenspace could be Audit is nearing developed for alternative uses such as housing where they are completion that identified as not being ‘valuable’ or ‘not needed’ in terms of both will help quality and quantity. determine value of urban In consideration of the City’s land availability constraints, a potential greenspaces. Kingswood Parks Options means of delivering a proportion of the required additional land for 125 Development 18 housing development in the City is through the redevelopment of Company some of the City’s urban greenspace.

In accordance with Objective 18 and Option 18 (3), following the undertaking of a robust PPG17 assessment of the ‘value’ and ‘need’ of existing urban greenspace within the City, where existing urban greenspace is found to be either surplus to requirements or fails to meet an appropriate level of quality, we believe that these sites should be released for an appropriate alternative development, including housing. In addition, the results of such an

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Company / Section Section City Council ID Your response Organisation number title response assessment should also be used to identify sites where their potential release, or part release, for redevelopment could provide funding to be used to enhance remaining urban greenspace on the site or the enhancement of other sites located within an identified catchment area. All the comments which we made in the section on health above Noted. are valid for this section also.

We endorse your statement in para B150 that Hull has historically lacked green spaces and that urban green space is particularly important for biodiversity in the city and for giving people access to nature.

The figures based on our Woodland Access Standard show that this shortage of green space a problem with regard to woodland. In fact a few years ago, Hull was given the accolade of being the least The Woodland Options wooded city in the UK, with only 28 hectares of woodland in the 154 Trust 18 city.

Recognising this, the Woodland Trust, working with Hull City Council, BTCV and some other local partners set up a 3 year project to plant trees across the city and create another 24 hectares of woodland, with the work being heavily focussed on involvement of children and local people. In a report on the project in 2007, Cllr David Woods, then cabinet member for environment, said:

“The project has raised awareness of the great benefit which trees bring to our environment and of the contribution new woods can make to the regeneration of life in our towns and cities. The

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 249

Company / Section Section City Council ID Your response Organisation number title response planting of trees is an important part of the city’s efforts to combat climate change”.

We would like to see Objective 18 amended to recognise the importance of not just protecting urban green space (including woodland) but also enhancing it be creating new woodland for the benefit of local people and wildlife. We would be very grateful if you could refer to our project in Hull as an example of what can be done to improve access to Woodland across the city.

We would also like to see recognition in bullet point 5 of Option 18 of the importance of green networks and corridors, not just for routes for pedestrians and cyclists, but also for enabling wildlife to move in response to the impact of climate change. It is particularly important in a city such as Hull which has only a small amount of woodland often in small fragments, that opportunities are taken to link it by creation of new woodland and other semi-natural green space so as to create a multifunctional network to benefit both people and wildlife. East Yorkshire Support All 5 options are important for improving the quality of life for and Derwent Options welcomed. 302 residents. To encourage people to walk regularly and therefore Area Ramblers 18 improve their health and reduce obesity, Option 5 is vital. Association Cf. my comment on Objective 15 Option 1. Option 3 should be Noted. Local resident Options 214 deleted: there will inevitably be pressure on existing green space 18 and it is unwise to open a loophole in advance. Hull Access We do not want to see the City’s heritage and historic parts Noted. Objective 26 Improvement destroyed but greater effort should be made in to making it 19 Group accessible, all buildings change over time and still not loose their Response to the Hull Core Strategy issues and options report, June 2008 October 2008 250

Company / Section Section City Council ID Your response Organisation number title response heritage. The historic environment makes an important contribution to the See A16.1. distinct identity of the City, to the quality of life of its communities and to its economic well-being. Therefore, we welcome this Objective.

English Heritage Objective However, the intention of the Plan should not simply be to “protect” 172 Yorkshire and 19 the City’s historic assets, but also to enhance them where this is Humber Region appropriate. Consequently, it might be better if this Objective was worded along the following lines:-

“Manage the historic assets of the City in a way which protects and, where appropriate, enhances their special character and setting”. Objective Yes indeed, but the City’s record on this is not brilliant, and Noted. 215 Local residnebt 19 “heritage related policies” do need to be improved. English Heritage Support Options 173 Yorkshire and We endorse the proposed options to deliver Objective 19. welcomed. 19 Humber Region Unfortunately protecting locally important buildings such as in the Noted. Friends of Options 268 Avenues area, has not been practiced to date and is an urgent Pearson Park 19 necessity. Para B 167: There would be far more people taking part in sports if Noted. some simple measures were carried out such as those I have Sport and active Friends of already recommended: have Adult Only times at the Ice Arena, and 270 recreation Pearson Park Adult Only swimming at the pools with lanes set off for those who provision want to swim and not just paddle around in the water. Also replace chlorine in the pools with a more environmentally friendly option.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 251

Company / Section Section City Council ID Your response Organisation number title response Para B.167 Sport England welcomes the approach adopted to the Noted. Sport and active topic, and note the reference to the Sport and Recreation Strategy 177 Sport England recreation which is in preparation. This should provide an important means of provision helping to deliver objectives of the Core Strategy. Para.B.173. The wording of this paragraph should include the word Noted. play, to read 'Sports and play'

It is important to register concerns that the document does not contain relevant reference to play which should have status within the document, especially as the development of child friendly spaces in the public realm is a key strategic development, especially considering Hull is developing as a family friendly city . this needs to be reflected within the document. Partnership Sport and active Policy and 369 recreation The minutes for the meeting (HDF Forum - 10th July 08) state that Quality Team, provision play and sport are included in the core strategy, it is clear that in Hull City Council terms of play this is not the case at this stage.

Youth Services are engaged in My Space development which in consultation with children and young people will develop new spaces for young people. There is no reference to this within the Core Strategy. There is a need to agree a consultation strategy that effectively engages children and young people's opinion in all developments but this does not appear to be part of the strategic development at this stage. It is considered that there should not be blanket refusal of Noted. Objective redevelopment of playing and sports pitches if significant 220 Local resident 20 improvements to nearby pitches can be provided through development opportunities. In essence, there should not

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Company / Section Section City Council ID Your response Organisation number title response necessarily be a 'quantity over quality' stance taken by the Local Planning Authority where applications may result in the loss of playing pitches. I would like to request that wherever sport and recreation is Noted. Partnership included in the document that it be altered to also include the word Policy and Objective 'play'. 368 Quality Team, 20 Hull City Council Therefore Objective 20 would be 'Secure appropriate provision of sports, play and recreation facilities'. Sport England agree with the sentiment of Objective 20 as it is set Noted. out, but would like to see it modified to ensure the protection and enhancement of facilities as well as their provision. A suggested wording is as follows: Objective 435 Sport England 20 “Secure the protection, provision and enhancement of sport and recreation facilities where appropriate and as opportunities arise.”

This would better reflect the analysis of the topic set out in preceding paragraphs, particularly B.166 and B.167. The use of the word 'accessible' again but does this mean Noted. accessible to all, including disabled people. Disabled people are Hull Access becoming more involved in sporting activities and with the increase Options 27 Improvement in awareness of the need for physical activity to help alleviate 20 Group conditions such as depression it is even more important that the sports facilities are fully accessible to all. This also fits in with the previous section on health. Options In respect of the provision of sports and recreation facilities, we Noted. 55 Barratt Homes 20 support the objective of securing ‘appropriate’ facilities within the

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 253

Company / Section Section City Council ID Your response Organisation number title response City.

In specific relation to the aims of Option 20 (5), we object to the blanket approach of retaining all sports pitches and recreational areas by protecting them from development. We consider that a flexible approach, similar to that identified in Option 18 (3) in respect of urban greenspace, should be adopted within the Core Strategy based on the results of a robust PPG17 assessment of existing sport and active recreation facilities within the City. Where the assessment indicates that certain facilities are found to be either surplus to requirements or fail to meet an appropriate level of quality, these sites should be released or part released for redevelopment.

Of particular relevance to sport and active recreation provision, where certain sites fail to meet an appropriate level of quality, the Core Strategy should support their release or part release for an alternative appropriate use where their redevelopment would result in the provision of funding to be used to finance the enhancement of existing sport and active recreation facilities on the site or the enhancement of other sites located within an identified catchment area. East Yorkshire All 5 options are important for walkers, Option 20.4 is important - it Noted. and Derwent Options should state "by adding safe cycle and pedestrian routes". I look 303 Area Ramblers 20 forward to seeking our Hull and Holderness members' views when Association you publish details of proposed walking and cycling routes. Options Support 216 Local resident We approve all options, especially 4 and 5! 20 welcomed.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 254

Company / Section Section City Council ID Your response Organisation number title response Sport England consider that ‘Options 20’ are not proper options in See A5.1 – A5.2. the spirit of offering a genuine choice between reasonable alternatives. As they stand, they are not mutually exclusive, and all could (and should) in practice be run in tandem to help meet the aspiration of Objective 20.

We note the intention in para B.173 to more fully consider the topic of sport and recreation facilities in the light of the emerging Open Space Audit. Sport England trust that this audit will be PPG17- compliant and consider built sports facilities as well as open space, reflecting the analysis set out in para B.166.

In order to help guide the development of policy, the following framework should be of assistance: Options 436 Sport England 20 THEME - A planned approach

PLANNING POLICY OBJECTIVE 1: To ensure that a planned approach to the provision of facilities and opportunities for sport and recreation is taken by planning authorities in order to meet the needs of the local community. The level of provision should be determined locally, based on local assessments of need and take account of wider than local requirements for strategic or specialist facilities.

POLICY APPROACHES

• encompass a planned approach to the provision of sports facilities based on sound assessments of current and future needs for strategic and local sports facilities, which take account of any Response to the Hull Core Strategy issues and options report, June 2008 October 2008 255

Company / Section Section City Council ID Your response Organisation number title response deficiencies;

• support a mix of facilities which comprise strategic, local and specialist facilities;

• take account of the priorities set out in local sports strategies, and national governing body facility strategies; and

• take account of cross-boundary issues for major or specialist facilities which have extensive catchment areas.

THEME - Protecting existing places for sport

PLANNING POLICY OBJECTIVE 2: To prevent the loss of facilities or access to natural resources which are important in terms of sports development. Should redevelopment be unavoidable, an equivalent (or better) replacement facility should be provided in a suitable location.

POLICY APPROACHES

• seek to protect or enhance existing sites and facilities and access to natural resources which are important for sport;

• identify important sites for sport on the proposals map for protection (including open space and playing fields and facilities which provide access to natural resources such as launching and landing facilities); and

• require at least an equivalent replacement in terms of quality, Response to the Hull Core Strategy issues and options report, June 2008 October 2008 256

Company / Section Section City Council ID Your response Organisation number title response quantity and accessibility if the loss of a facility is unavoidable, unless it can be proved that the facility is genuinely redundant and there is no demand for a replacement based on a thorough local assessment.

THEME - Providing for sport through new development

PLANNING POLICY OBJECTIVE 8: To promote the use of planning obligations as a way of securing the provision of new or enhanced places for sport and a contribution towards their future maintenance, to meet the needs arising from new development

POLICY APPROACHES

• indicate the circumstances in which planning obligations will be sought;

• use the support of local assessments of community requirements likely to be generated by new development and which take account of the adequacy of existing provision and local Sport and Recreation Plans/Strategies;

• ensure that adequate provision of sports facilities is secured as part of major new residential development. Additional requirements could be specified in a development brief;

• seek developer contributions from small scale residential developments towards new or enhanced provision where the development will create additional demand or place additional pressure on existing sports facilities; Response to the Hull Core Strategy issues and options report, June 2008 October 2008 257

Company / Section Section City Council ID Your response Organisation number title response

• where it is not practicable to provide new facilities as an integral part of a new development, seek contributions towards off-site provision or enhancement which is directly related to the development;

• seek financial contributions to the long-term maintenance of any new facilities provided as a result of a new development; and

• encourage the provision of more places for sport in association with major commercial and retail developments.

Derived from the above and looking ahead to the production of the Core Strategy Submission Document, this document should include policy-related consideration of:

• open space provision and protection;

• facility provision;

• access for all/equality of access;

• quality of provision;

• the needs of specific sports and user groups; and

• opportunities for countryside recreation.

In all cases, a sound evidence base is required to underpin any policy which is developed to address these issues, as noted above. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 258

Company / Section Section City Council ID Your response Organisation number title response Summary: A Checklist of Content and Procedure

As a summary of the preceding points, the following checklist should help to ensure that the interests of sport and active recreation (and by association a range of other issues) are properly covered by the Core Strategy.

Theme - Objective-setting

Does the core strategy …

• Set out clear objectives for sport and recreation?

• Reflect community strategy objectives for sport and recreation?

• Safeguard facilities?

• Promote accessible facilities?

• Development of a strategic framework for the provision of sport opportunities?

Theme - Developing and using the evidence base

Does the core strategy …

• Employ a sound evidence base to help inform policy making?

• Identify a hierarchy of sport and recreation provision?

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 259

Company / Section Section City Council ID Your response Organisation number title response • Use policies which anticipate future sport and recreation needs?

Theme - Connecting policies and plans

Does the core strategy …

• Recognise the role of sport in contributing to a wide range of spatial planning issues: regeneration, health promotion, crime reduction, quality of life etc?

• Establish connections between different policy areas?

Theme - Promoting sustainability and quality of life issues

Does the core strategy …

• Promote sustainable design of sports facilities?

• Promote sustainable resource management/stewardship through the relationship between sport and the natural environment?

• Promote mixed use schemes such that there is an appropriate presence of sport and recreation as part of a balanced community?

Theme - Developing spatial planning approaches

Does the core strategy …

• Maximise contributions to spatial planning initiatives such as greenspace networks or better use of the urban fringe and the Response to the Hull Core Strategy issues and options report, June 2008 October 2008 260

Company / Section Section City Council ID Your response Organisation number title response wider countryside?

• Develop policies which respond to the expressed needs and demands of marginal or controversial sports, with due regard to resource protection and wider sustainability issues?

• Explore opportunities for sport and recreation to make a contribution to unprogrammed development proposals? Statistics show that disabled people are disadvantaged in the work Noted. Hull Access environment, a range of job types suited to all should be Jobs and 28 Improvement C. encouraged into the city. Consideration must be given to the needs prosperity Group of part-time workers who tend to be women or people with a disability. We welcome the proposal to work at a sub-regional level to limit the Support supply of new office space in less sustainable locations, in order to welcomed. encourage the development of a more modern office market within the city centre. In addition, policies aimed at strengthening the cultural, leisure offer, and the quality of the urban environment will help to strengthen the attractiveness of the city centre as a location for new office developments. Yorkshire Jobs and 239 C. Forward prosperity Scenario C which outlines a high growth scenario is welcomed; as such an approach would support the objectives of the RES which seeks to encourage sustainable economic growth that will maximise long term benefits to businesses, people and to the environment.

The Humber Ports are of national significance and represent critical assets in increasing UK prosperity through world trade. We,

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 261

Company / Section Section City Council ID Your response Organisation number title response therefore, welcome the recognition given to ensuring that there is a sufficient supply of employment land to meet the needs of Hull port, as it will continue to be an important driver of the local economy. It is therefore important that appropriate recognition be given to the role of rail gauge enhancements, and improvements to Castle Street will play in supporting the port’s growth.

In terms of the overall supply of employment land we would highlight the need to undertake regular reviews of employment land stocks to ensure they are meeting the needs of the modern economy. In particular, it is important that sites which are failing to meet land requirements of local businesses and inward investors are de-allocated and replaced by more suitable sites. The Humber Economic Development Investment Plan has identified that of the regional clusters; the environmental, and digital clusters are forecast to grow during the plan period; it is therefore necessary to ensure that sufficient employment land is allocated to meet the needs of these two sectors. Para C6: The figures are more than improbable. Noted.

Para C7: The IBM report is two years old and nothing has been Friends of Jobs and 271 C. done to "go for growth." I have been present at meetings where Pearson Park prosperity viable first steps were proposed, but again nothing happened. The Council has a reputation of not considering any ideas that do not come from its own officers. Para. C.7. We suggest that the development and management of Noted. The Theatres Jobs and ‘cultural quarters’ can help address the need for affordable 196 C. Trust prosperity workspace for creative industries by providing flexible live/work space and encouraging clusters of activity that provide a trigger for

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Company / Section Section City Council ID Your response Organisation number title response local regeneration. Where they contribute to wider regeneration and mixed-use policies, they should be sustained by the planning system and supported by wider economic and cultural development initiatives.

Creative industries are the UK’s fastest growth sector, generating significant revenue and employing hundreds and thousands of people. Activities at museums, libraries and archives generate substantial income and investment and support the tourism and employment economy. Cultural activity brings economic benefits by providing employment and generating revenue. It attracts people and businesses, inward investment, job creation and supports the visitor economy. The Highways Agency acknowledges the issue highlighted in the See A17.1. jobs and prosperity section that the trunk road network is a constraint on certain development sites.

The Highways Agency supports the “city centre first” policy as it Support reflects the Highways Agency’s desire to see B1 primarily located in welcomed. the central urban areas away from the SRN. Ideally B1 office use Highways Jobs and should be located in town or city centres where there is a choice of 232 C. Agency prosperity sustainable transport modes or, if out of centre, in the vicinity of existing public transport hubs. Thus office parks adjacent to key junctions on the SRN would be considered unacceptable.

The Highways Agency would like to investigate in more detail the Noted. implications of relocating the general industry and warehousing to the Eastern side of the river towards the eastern corridor, particularly as this move could have implications for the A63 Castle

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Company / Section Section City Council ID Your response Organisation number title response Street.

The Highways Agency supports the timetabling of future scenarios Noted. particularly the principle of city centre and Heartlands initiatives taking place after the commencement of the Castle Street scheme. Castle Street is critical in delivering the transformation of the city. The Assembly is encouraged that paragraph C.3 states that the Noted. Council has used the RSS to consider future land needs. However, it has not taken the RSS figure as its guide to future employment land requirements and will be using more up to date figures from the Employment Land Review. RSS Policy E3 makes it clear that Yorkshire and Jobs and land in use or allocated for economic development should be 364 Humber C. prosperity reviewed during the preparations of LDFs. Policy E3 also makes Assembly clear that local employment land reviews to inform LDFs should take account of the potential job growth set out in Tables 11.1 and 11.2. Table 11.1 suggests that the potential annual job growth from 2006 in the Hull district is 910 per annum. Table 11.2 breaks this figure down by different land uses. Government Para C.12. The Employment Land Review requirement of 113- Noted. Projected future Office for 128ha needed to 2026 - this just refers to ‘employment land’, i.e. 285 employment Yorkshire and the not ‘new employment land’. So presumably this is not all additional land demand Humber to existing? How will this relate to existing employment land. The supply of Noted. Page 132. Approach to new jobs seems to be very land to deliver manufacturing/high land usage focused, could stress more how we growth and 62 Gateway will use the planning framework to drive the jobs up the value chain develop i.e. support for knowledge based sectors presumably mainly in city economic centre and its peripheries? clusters

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Company / Section Section City Council ID Your response Organisation number title response Para. C15. As you recognise, there would appear to be plenty of Noted. employment land available (in March 08, 190ha available). The overall strategy will need to identify and deliver realistic provision. The supply of Government land to deliver We note that de-allocations are possible, or alternative uses, when Office for growth and considered in detail in Site Allocations DPD. The CS is where the 286 Yorkshire and the develop big decisions should be taken, including employment land supply. It Humber economic will need to be clear about scale (of new land required), for what clusters purpose and broad locations. The CS could include policies for restricting/allowing the loss of existing employment sites and land previously reserved for employment - with evidence to justify of course. Map C.1. Needs to show all AAP's consistently and consider See A13.1. identifying future AAP's e.g. N Hull, Heartlands etc. Should show city centre AAPs boundary and N Hull area surrounding city centre as second phase for regeneration. Could usefully add Hull College Distribution of 63 Gateway and other facilities (Health is the most notable omission). The land strategy for developing green space connections does not yet come through and this will be fundamental to changing how people use and perceive the City, a major driver of change in both NaSA & HRC AAP's. Para.C.32. We endorse the recognition that the historic buildings of Support English Heritage Distribution of the heartlands area should be considered an asset to the City and welcomed. 174 Yorkshire and land its potential for this area to be the focus for mixed-use Humber Region developments. Within the Jobs and Prosperity section of the HDF, Clough Road is See A32.1. Distribution of specifically identified on Map C1 as a key employment site, 195 National Grid land available for employment development. As outlined above, National Grid support the redevelopment of this site for a range of Response to the Hull Core Strategy issues and options report, June 2008 October 2008 265

Company / Section Section City Council ID Your response Organisation number title response commercial purposes.

The Clough Road area, along with the site itself, already contains a range of commercial uses, including retail, offices, as well as general industrial and warehousing uses. It is suggested at para 35 that the Clough Road area is suitable for meeting industrial and warehousing employment forms of development. Whilst National Grid do not object to such uses, the plan should also support other wider ranging employment uses. The area is appropriate uses as trade counters, car showrooms and other sui generis uses, along with office (B1) development.

Whilst it is accepted that the city centre is the prime location for office development, it is recognised at paragraph C.25 that the policy approach to office development should allow for such uses outside the city centre. The HDF recommends a phased approach to development, based upon the potential availability and deliverability of sites. In terms of Clough Road, Table C.1 suggests that the area “…may provide opportunity in the medium term”. In the case of the National Grid site, given that the majority of it has now been remediated, this is available for development in the immediate future, and the plan should recognise this.

Whilst National Grid do not object to the phasing of development of employment land in principle, the National Grid site at Clough Road should be included in any early phased release of employment land given its immediate availability to deliver regeneration benefits to adjoining deprived communities.

Summary Response to the Hull Core Strategy issues and options report, June 2008 October 2008 266

Company / Section Section City Council ID Your response Organisation number title response These representations seek recognition within the HDF of the importance of the National Grid site at Clough Road to delivery of regeneration benefits to the local community. Redevelopment, including a wide range of uses, and not only B class, would be appropriate on this site and within the general area. Whilst it is appreciated that Core Strategies are not concerned with site specifics, they are concerned with strategic locations, and clearly Clough Road (including the National Grid site) represents such a strategic location worthy of specific reference. Friends of Distribution of Para C.26: There is already unused office space in the city and Noted. 272 Pearson Park land always has been. Para C.24-C.26. It is a concern that the approach to the city centre See A31.1 – fails to recognise that providing sites to complement office A31.3. developments in the city centre is vital to the sustainable economic growth of both East Riding of Yorkshire and Hull as a Regional City. There is a clear distinction between a city centre and edge of city office product and a balanced offer is required. It is evident that other successful City Regions have a comprehensive offering of both products. East Riding of Distribution of 442 Yorkshire Council land There is demand for office development in the East Riding villages to the west of Hull (as set out in the East Riding Employment Land Review and identified through consultation with local and regional agents). Such sites will provide for more choice and ensure that the market requirements are met. Crucially, it will help ensure that companies do not relocate outside the sub-region, ensuring that jobs are retained for residents of the Regional City. It is acknowledged that such development should be complementary to the prime quality office space within the city centre and will help

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 267

Company / Section Section City Council ID Your response Organisation number title response provide a balanced collection of sites across the City Region. Para C.27-C.34. It is questionable whether it is realistic to expect a Noted. See also high proportion of uses from the Heartlands area to relocate to the A31.1 – A31.3. Eastern Corridor. The document does not recognise the constraints to relocating general industry and warehousing to the east of the city – in particular those relating to the highway network and the fact that market forces may drive businesses (other than port East Riding of Distribution of related activity) towards more accessible sites in the western side 443 Yorkshire Council land of the city. Whilst it is appreciated that the Eastern Corridor performs an important function for employment use for the City Region, it must be recognised that companies may consider land to the west of the city (including sites within the East Riding) as a preferable alternative. Perhaps options should have been considered that set out how employment uses from the Heartlands area could be redistributed within the Regional City? Para C.39-C.40. The section on Kingswood makes reference to Noted. there being sufficient capacity to accommodate substantial development and that further development could be encouraged by better marketing and branding of the area. This section makes no East Riding of Distribution of 444 mention of the earlier chapter that suggests the possible need to Yorkshire Council land de-allocate some employment land at Kingswood and replace with housing. It is unclear therefore what the City Council is actually proposing for Kingswood. Perhaps a question could have been included in the document on this issue? Paragraph C.29 See A15.1 – A15.3. Distribution of 340 RSPB The RSPB is keen to see that the impacts of port developments are land given full consideration within the LDF, and is surprised at the limited discussion of this important sector within the Core Strategy. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 268

Company / Section Section City Council ID Your response Organisation number title response The RSPB is aware of a significant port-related project under development on the Hull frontage. The Core Strategy should clarify the particular environmental constraints associated with port developments along the Hull frontage, and identify the potential risks to the integrity of the Humber Estuary's designated sites. In brief, these include but are not exclusive to loss of or changes to designated intertidal habitats, loss of high-tide roosts outside the designated sites; disturbance/displacement of either feeding or roosting SPA birds. The Core Strategy should clarify the need for rigorous assessment of new port proposals under the Habitats Regulations. This will be a key issue for the Habitats Regulations Assessment of the Core Strategy to consider. We would be happy to provide advice at the scoping stage of the Habitats Regulations Assessment. In planning for economic development, as earlier representations See A47.1. have noted, it is important the Council proceeds on the basis of the aspirational growth scenario cognisant of the job projections in RSS. This will ensure the Core Strategy brings forward sufficient land of a suitable quality, and in the right locations, to meet planned requirements for industrial and commercial development. Bringing land Wrenbridge Land 151 forward – future In determining the future employment land supply in Hull it is of Limited phasing note the emerging Core Strategy records that:

– almost three quarters of land supply is on previously developed land and development is very much dependent on the re-cycling of existing land and buildings;

– over a third of the supply is at high risk of flooding and a further

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 269

Company / Section Section City Council ID Your response Organisation number title response 48% is at medium risk of flooding;

– 20% of the total land supply is considered to be significantly constrained ;and

– approximately 10ha is held for expansion

It is, therefore, appropriate for Hull to plan to release sites which are available and deliverable at the current time and not at risk from flooding or significantly constrained. This is particularly the case in respect of regeneration areas and again WLL would request the potential role of the KC Stadium be recognised in the Core Strategy.

WLL agree that the release of employment sites needs to be phased. However, where developers are bringing forward proposals which can make a positive contribution to job creation and delivering the Core Strategy, this should not be frustrated or subject to un-necessary delay. We are acting on behalf of Birds Eye Iglo Limited in respect of their See A32.1. redundant factory site on Hessle Road in Hull. We have been actively marketing the site since July 2007 when production was moved from the Hessle Road site to the new processing plant at Bringing land Birds Eye Iglo Freightliner Road, Hull. 365 forward – future Group Ltd phasing Our evidence base shows that the site is functionally redundant and there is no demand for the existing buildings. On this basis we object to the site specific comments in the Core Strategy DPD restricting the site to employment uses only. This would stifle

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 270

Company / Section Section City Council ID Your response Organisation number title response redevelopment opportunities including the potential to introduce a mix of new employment uses and residential uses in a sustainable manner. In addition the policies are far too prescriptive to be contained within a Core Strategy and we consider the document does not accord with Planning Policy Statement (PPS) 12: Local Spatial Planning (June 2008). PPS12 sets out the purpose and principles of a Core Strategy and we consider that the proposed Core Strategy document does not accord with paragraphs 4.7, 4.36, 4.44 and 4.52 for the following reasons.

Paragraph 4.7 states that whilst Core Strategy DPD's may allocate strategic sites which are central to the achievement of the strategy it should not be held up by the inclusion of non-strategic sites and should not include site specific details. We can demonstrate with evidence that the Birds Eye site is not a strategic employment site because it is not attractive to the market and has been vacant for over 12 months despite being proactively marketed. The site is also within a predominantly residential area and can only be reached from the A63 Clive Sullivan Way through the residential suburbs. In addition to the constraints of its location the site also requires considerable remediation and new infrastructure before it can be re-used. In both qualitative and quantitative terms we consider that the Council has not demonstrated that the Birds Eye site is a strategic employment site which is fundamental to the future supply of employment opportunities across the City as a whole.

Paragraph 4.36 states that Core Strategies must be justifiable, founded on a robust, credible evidence base and be the most appropriate strategy when considered against the reasonable alternatives. First and foremost. not all the documents which should Response to the Hull Core Strategy issues and options report, June 2008 October 2008 271

Company / Section Section City Council ID Your response Organisation number title response be fully taken into account in the Core Strategy have been completed i.e. the Strategic Housing land Availability Assessment. Therefore the document cannot be robust and is not appropriately justified.

Second, the documents which are complete and referenced in the Core Strategy, such as the Housing Market Assessment (HMA), are, in our view, fundamentally flawed. The Core Strategy sets out the future housing requirements for Hull up until 2026 based on the conclusions in the HMA which estimates a shortfall of over 9,000 dwellings. However, the deficit could be much greater than this because:

The HMA and therefore the Core Strategy are underestimating the potential future housing need. The HMA assumes the economy will contract whereas both national and regional estimates set out in the adopted RSS anticipate growth. In particular the HMA takes no account of the 20,000 new jobs and other initiatives proposed in the City Centre Master Plan and Area Action Plan.

The Core Strategy assumes that all the anticipated sites will come forward. However the majority of the sites are green field and therefore less sequentially preferable. Furthermore it is unlikely that all existing allocated sites will come forward and so the Core Strategy has underestimated future housing requirements once again.

Whether or not the assumptions in the Core Strategy are correct, a shortfall in supply is anticipated and as such the proposals to retain the Birds Eye site wholly for employment purposes are short Response to the Hull Core Strategy issues and options report, June 2008 October 2008 272

Company / Section Section City Council ID Your response Organisation number title response sighted because part of the site would be ideal for residential use. The site is more closely related to housing than employment uses with housing to the west, north and east. Therefore its redevelopment in full or as part of a mixed use scheme would be more compatible with surrounding uses than the existing use. Furthermore, the site is previously developed and well located in relation to shops and services meaning it scores highly in sustainability terms. The redevelopment of the site for (some) residential use is therefore a reasonable alternative to the proposed option and in this respect the Core Strategy fails to accord with PPS12.

In accordance with paragraph 4.44 Core Strategy DPD's must be effective which means they must be deliverable, flexible and able to be monitored. In respect of the Birds Eye site, the issue of deliverability for wholly employment use is doubtful as marketing evidence from CB Richard Ellis suggests. Also, the rigid policies recommended in the Core Strategy document do not allow for any flexibility which would mean that if the site cannot attract an employment user it would remain vacant. This approach does not accord with the provisions of PPS3 and PPS1 which seek to develop previously developed sites, such as redundant employment sites, which are in sustainable locations for housing. Nor does this accord with the provisions of paragraph 4.52 of PPS12 which states that to be sound a Core Strategy should be justified, effective and consistent with national policy.

We have clearly demonstrated in the foregoing that the document is unsound because the justification is not solid. The policies are fundamentally flawed by the evidence base and they cannot be Response to the Hull Core Strategy issues and options report, June 2008 October 2008 273

Company / Section Section City Council ID Your response Organisation number title response effective because they disregard the market. In addition, the policies are contrary to national guidance in PPS1 and PPS3 which seek to make efficient use of previously developed sites in sustainable locations.

We fully intend to support the views contained within this letter with our own evidence base. This will make reference to the housing and employment land reviews and will include a sustainability appraisal of the site. Objective We agree that there is a delicate balance to preserve between Support 217 Local resident 21 conflicting demands. welcomed. We believe that the Core Strategy should adopt a more flexible Noted. framework for the safeguarding and allocation of employment land within the City to that identified in Options 21.

As the locational requirements of industry are continually evolving it is becoming increasingly difficult to predict where the suitable locations are for future employment locations and likewise whether existing employment locations will in future be required for the Options same land use. Consequently, we believe that a more responsive 56 Barratt Homes 21 approach to the safeguarding and allocation of employment land should be integrated within future revisions of the Core Strategy.

In order to maintain maximum flexibility, and in acknowledgement of the City’s land availability constraints, we believe that the Core Strategy should include an approach to the safeguarding and allocation of employment land which takes into account the following development factors:-

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 274

Company / Section Section City Council ID Your response Organisation number title response • Responsiveness to Market Signals;

• The most efficient and effective use of the land;

• Ensuring that the overall level of land supply is sufficient so that there is the right potential for both employment and residential use;

• Encourage new uses of vacant and derelict buildings; and,

• The overall aims and objectives of the Core Strategy. We believe that the Core Strategy should adopt a more flexible Noted. framework for the safeguarding and allocation of employment land within the City to that identified in Options 21.

As the locational requirements of industry are continually evolving it is becoming increasingly difficult to predict where the suitable locations are for future employment locations and likewise whether existing employment locations will in future be required for the same land use. Consequently, we believe that a more responsive Options 87 Kayterm Ltd approach to the safeguarding and allocation of employment land 21 should be integrated within future revisions of the Core Strategy.

In order to maintain maximum flexibility, and in acknowledgement of the City’s land availability constraints, we believe that the Core Strategy should include an approach to the safeguarding and allocation of employment land which takes into account the following development factors:-

• Responsiveness to Market Signals;

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 275

Company / Section Section City Council ID Your response Organisation number title response

• The most efficient and effective use of the land;

• Ensuring that the overall level of land supply is sufficient so that there is the right potential for both employment and residential use;

• Encourage new uses of vacant and derelict buildings; and,

• The overall aims and objectives of the Core Strategy. In general terms, a preferred option based on a combination of Support these options is appropriate. However, it should be made explicit welcomed. that the employment land to be safeguarded should only be the best quality and best located land, consistent with specifically Dransfield Options 139 meeting clearly identified need, as assessed on a site by site basis. Properties Ltd 21 Other employment land should not be safeguarded in this manner, and blanket protection should not be applied, as this would stifle development and the ability to meet other needs. This is more in keeping with the wording of Objective 21. The continuing allocation of the employment land at Kingswood is See A32.1. inconsistent with the approach to reallocate the land for housing. Since we support the latter approach, for the reasons set out above, we object to any proposed option that would continue to Kingswood Parks allocate the remaining employment land as a ‘Key Employment Options 126 Development Site’. In view of the availability of employment land elsewhere in the 21 Company City, the lack of take up of the Kingswood Employment Land, and the demand for further housing in the Kingswood area, we consider that it would not be appropriate to continue to allocate the land for employment and we object to the suggested approach for Kingswood set out at Table C1 and the phasing set out at C2.

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Company / Section Section City Council ID Your response Organisation number title response Option 21.A.2. In terms of overall provision, ABP supports Option See A32.1. 21.2 Identify particular sites or areas of the city for particular uses to safeguard areas for specific clusters – or alternatively allocate land for general employment use to maintain maximum flexibility, although with a risk that slower cluster growth may lose out to less strategic uses.

ABP requests that their operations at the Port of Hull should be protected and request that Alexandra, Queen Elizabeth and King George Docks are identified as areas for port-related development.

As stated above, the Port of Hull performs a vital role in the local, Associated Options regional, and national economy, and is an important employer in 295 British Ports 21 the Region. It also offers the opportunity to increase the more sustainable movement of freight by rail and water, and thus reducing the impacts of climate change.

Policies HE1 and T7 in the RSS states that land for port-related activities should be safeguarded and the use of ports and the deep water channel should be maximised.

ABP considers that the Port of Hull, particularly Alexandra, Queen Elizabeth and King George Docks should be safeguarded for port- related development, to assist in the creation of a vibrant local and regional economy, and safeguard the long-term economic future of the city. Our general view is that the document underplays the current and See A48.1. Options 343 University of Hull potential impact that the University has on the City of Hull. 21 Specifically the text of Options 21 and 22 are surprisingly silent in

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 277

Company / Section Section City Council ID Your response Organisation number title response this regard.

The Chief Executives of Hull City Council and Hull Forward have both expressed the view that the University of Hull is central to the city's plans and ambitions. We are grateful for that recognition and have developed very positive working relationships on a number of strategic and operational levels (including projects such as the History Centre, World Trade Centre, Wilberforce Institute, and The Deep). We are extensively referenced in the Hull Geographic Plan currently being prepared by the Council and are in active discussions about taking this further in the weeks ahead. We are a little surprised, therefore, that this does not appear to be reflected in this version of the Core Strategy. We would hope that you will consider adding the following key points:

* The University is a £140m a year business, with a major direct economic impact on the City, discussed in greater detail below. The University is currently undergoing a significant expansion. It is firmly located within the City and makes a huge contribution to its economic and cultural life.

* The University supports around 20,000 students, helping to retain some of the brightest of the local population, and bringing to Hull talented students from around the UK and indeed the globe.

* The University has a national reputation for its capacity to recruit and sustain students from low participating neighbourhoods and backgrounds. It provides a range of training for those in work, and is seeking to further increase its capacity to deliver the higher level skills needed to build and sustain a strong local economy. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 278

Company / Section Section City Council ID Your response Organisation number title response

* The University's large annual intake of overseas students is responsible for much of the ethnic diversity within the City, and much of its reputation overseas.

* The University hosts a Medical School which is of significant benefit to the) i local trusts. It has a highly regarded Business School which makes a major local and national commercial contribution, particularly in the area of logistics.

* The University has a wide research expertise which, particularly in the areas of science and technology, has been extensively used by local companies.

* The University's activities supporting schools and raising aspirations have a major impact on the achievement of local children.

* The excellent reputation the University enjoys as a provider of a high quality student experience in turn significantly enhances the reputation of the City.

* The University operates in an extremely competitive environment. Sustaining its business is a challenge given declining demographics, but one we are confident we can meet, provided we can provide the facilities and experience modern students demand. Option A overall provision – the aspirational target should be Noted. Options 422 Hull Forward followed and areas of the city identified where particular clusters 21 will be encouraged, but recognising their supply needs (more

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 279

Company / Section Section City Council ID Your response Organisation number title response generic supporting uses may be appropriate to support growth in key clusters)

Option B phasing – the location of development should accord to a plan; agree that the target areas and timescales outlined in C1 form an appropriate basis for this. Whilst ad hoc development should be resisted it is important however that the planned approach provides a flexible framework to respond to changing market conditions. There therefore needs to be a reference/relation to the city’s economic strategy which will be reviewed more frequently than the Core Strategy. Table C2: The impounding of the River Hull will have terrible Noted. environmental consequences. Who is responsible for such unscientific schemes? Friends of Delivering 275 Pearson Park transformation Para C51: This should recognize that there is no way to force landowners to open up their land as they, too are interested in profit, and "land bank" is the way to achieve this. Table C.2. The RSPB is concerned to see "River Hull Noted. See also Impoundment" as part of the long-term strategy for development of A15.1 – A15.2. the Heartlands area. We are concerned that the environmental impacts of the impoundment of the River Hull have not been fully considered. The scheme has the potential to have damaging Delivering 339 RSPB impacts on the Humber Estuary SPA through altering hydrology transformation and sediment transport. Furthermore, such a scheme may also affect designated sites upstream of Hull and affect its function as a wildlife corridor. Any impoundment or similar scheme would need to be subject to the rigorous stepwise tests set out in the Habitats Regulations to ensure no adverse effect on integrity of designated

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 280

Company / Section Section City Council ID Your response Organisation number title response sites. The LDF should reflect these considerations and analyse the potential for such impacts. Inclusive education is improving the long term prospects for many Noted. disabled people. The 'Building Schools for the Future Programme' Hull Access Education, needs to address the needs for access to schools, colleges and 29 Improvement D. learning and university to further improve the educational chances for all. Group skills Consideration needs to be given children who are in the school and college system now and adults returning for re training and education later in life, who may have disabilities. Para D. 3: The goal should not be to equal the national average, Noted. but to ensure that all young people are in education, employment or training.

Para D.6: BSF is a flawed program. All the research done (including mine for central government) shows that pupils perform better in small schools. Education, Friends of 277 D. learning and Pearson Park Para D 7: As the writer of 4 research papers for central government skills on improving inner city schools, I can show that you cannot attract high quality teaching staff (as was tried at Endeavour) when pupils' behaviour is so bad that teachers cannot teach.

Para D 16: Quite true that facilities do not make good schools (look at Endeavour). The city will not be attractive to young families until educational facilities improve. Government Noted. Education, Note references to existing/current educational strategies and Office for 287 D. learning and investment programmes so the basis is there. Need to ensure this Yorkshire and the skills develops into appropriate policy coverage. Humber Response to the Hull Core Strategy issues and options report, June 2008 October 2008 281

Company / Section Section City Council ID Your response Organisation number title response Option 22.3, 22.4 and 22.5. The current analysis of educational Noted. See also need and provision in the city takes far too little account of the need A48.1. to develop higher level skills, knowledge and understanding for employment and participation in the city and region in the future. Option 22.3 rightly refers to support for HE in the city but the options ignore the crucial importance of 16-19 education and the role of the sixth form colleges in that. Anyone reading the document would not realise that more than 2,500 FULL TIME sixth form students per year are studying in Wyke and Wilberforce sixth form Wyke Sixth Form Options 88 colleges and the document shows no recognition of the importance College 22 of supporting this as part of the Core Strategy. Labour Market and economic development projections show the need for a massive increase in degree level education and training to support the knowledge economy of the future, particularly in health, energy and renewables and port & logistics. This means supporting young people in progressing in FULL TIME education through sixth form provision to Level 3 and on to Higher Education. The development of the sixth form colleges needs to be explicitly recognised and supported in this plan and its options. Option 5 is to be supported, and there is a certain logic to its Support inclusion, but it does sit rather strangely here. welcomed. Options 218 Local resident 22 Option 1 seems to assume that schools may be placed at will, though again, one agrees that school premises do have a wider role to play in animating a community. We note that labelling the University as a strategic higher education See A48.1 Options site on the proposals map - Spatial Options Map - is appropriate for although more 344 University of Hull 22 a broad brush type document. However we do not consider in will be added Option 22 that a short statement to the effect that it will aid the about the

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 282

Company / Section Section City Council ID Your response Organisation number title response continued expansion of higher education facilities is detailed importance of enough. We seek then a greater recognition of the University's role Hull University to in the City, and for its case for development, and our request is the city in the based upon the following further points building on those listed next draft. above:

1. Many references to the University appear to underplay the importance of higher education, research and out-reach activity in relation to the City. Under D.11 nothing is really made of this: it simply states that the City has a University. There are a number of areas in the document where the University can contribute. There are many comments about the City's disadvantages when compared to the East Riding, yet one clear advantage is that Hull City has a University with its headquarters firmly within its boundaries, whilst the East Riding does not. We would strongly encourage Hull City to trade on this advantage. (Scarborough Borough Council certainly recognises the significance of our campus based within the town.) The City should, for example, be able to take great pride in being able to say that there is a leading University in the city that for the past three years has been named in the 10 most popular in the country (as measured by the national government student survey) and is the No1 university in the North! This attracts very significant investment to the City. It is surprising, on the other hand, that reference continues to be made to the minor residual elements of the University of Lincoln in its plans when their focus, quite rightly, is on Lincoln.

2. As a recent and relevant example of the University's impact we would cite the work on flood risk and flooding, recently completed, that shows the way in which the University can contribute Response to the Hull Core Strategy issues and options report, June 2008 October 2008 283

Company / Section Section City Council ID Your response Organisation number title response significantly to research on and for the City.

3. The comment about 'tackling proliferation of student accommodation' (p19) does cause some concern to the University given the strong preference for students to live near the University rather than in the City centre. There is clearly potential for more on- site residences at the campus, which will significantly improve the attraction of the University and as a consequence its sustainability, with all of the financial benefits this brings to the City.

4. There is limited follow up of the comment (p18) about the University being a draw for investment. There are important links here (as well as a whole range of current industrial collaborations) that are not mentioned and which we would like to draw to your attention. There are many strong examples of how firms have been helped to expand through University input, and vital links between the identified growth sectors in A.29 & C.7 and the University in the area of logistics, health care, biosciences, and renewable energy. This is only mentioned briefly in C.40 in a very abstract fashion in relation to the University helping with R&D as an inward investment factor. We also note a desire within the City to see more graduates staying locally, contributing to job creation and enterprise, but who require appropriate support and incubation facilities. The University is, of course the principal source of such talent, and plays a leading role in providing enterprise training and incubation opportunities.

5. A.11 defines sustainable communities as those who are 'earning, learning, healthy and safe' but the section contains nothing about education. A.14 for example speaks of 'jobs, leisure and health services', when comparing with regional centres of Leeds, Sheffield Response to the Hull Core Strategy issues and options report, June 2008 October 2008 284

Company / Section Section City Council ID Your response Organisation number title response and York. It is hoped that you will also recognise the important role of Universities in regeneration and in resolving other core problems, such as the dearth of managerial and professional groups in the City (Para A. 13). We would welcome a revised text that reflects these points. It would also be helpful to add to option 4 as a second item "attracting investment to higher education" (its current focus on retail and the port give a rather limited view of a City with significant potential).

6. The regeneration section in A.23 acknowledges the role of Education but only insofar as it lists Primary and Secondary school initiatives. Other regions certainly regard universities as a key part of the regeneration mix. Mention should be made of Academies as a relevant initiative, with the University being a sponsor. However the very serious role that the University plays in local schools in raising aspiration and providing professional development for teachers is vital. A very brief mention is given later in D.9.

7. The section on Education (D) has a focus which is almost entirely on schools and pre-19 achievement. Yet it is widely accepted that the prosperity of any city in the future will be measured by its access to high-level skills and its ability to participate in the knowledge-based economy. It is said that in the 21st Century universities will be to economic development what the mills were in the 19th Century. The importance of attracting a well qualified workforce and high skills jobs to wealth generation is well established. We fear that this document underplays higher level skills and surprisingly, also the Leitch agenda of work based learning. So while the Para (D.10) on Hull College ends with 'there are opportunities for Hull College to grow within the City Centre', Response to the Hull Core Strategy issues and options report, June 2008 October 2008 285

Company / Section Section City Council ID Your response Organisation number title response there is no corresponding statement concerning the University. We would strongly urge something in D.11 about the University of a similar nature, recognising a need for an 'Area of Change'.

8. Some of the figures in Para D.10 need revising. The student population can be quoted as 21,000. The £200m cited as the contribution to the economy is now regarded as extremely conservative and is in need of revision. After considerable research Universities UK now use an output multiplier of 2.52 (see: The economic impact of UK higher education institutions) which suggests something more like a £350m value to Hull's economy. Indeed the economic impact of universities across Yorkshire & Humber is now set at £2.8billion a year -which is more than Banking and Insurance (£2.7bn) and the Food & Drink sector (£2.7bn). The value of the University of Hull's interaction with business alone is around £20million annually which, pro-rata, places us second only behind Sheffield in Yorkshire, ahead of Leeds and with double the impact of York.

9. In D.14 we hope that you can amend 'Schools and colleges are a vital part...' to also include the University.

10. Although happy with Option 22 Item 3 'Aid the continued expansion of higher education facilities' we fear, given the other references, that it refers only to Hull College HE expansion in the City centre, but hope that it does not. We should however object to D20, which suggests merging the five options, on grounds that it would lead to a loss of focus.

11. Throughout the document the title 'Hull University' is applied. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 286

Company / Section Section City Council ID Your response Organisation number title response Although it may seem a minor point it would be very helpful to us if the official name, "the University of Hull", was used throughout. We would also note that we are, by an order of magnitude, the principal supplier of higher education to the city and region.

12. D.22 Penultimate bullet in Section D. We suggest deletion of the University of Lincoln as it is not a 'Key...organisation responsible for delivery' and only has some residual elements left in the City.

In planning terms we would make the following observations.

13. We would welcome the benefits of granting an 'Area of Change' designation to the University of Hull campus to accommodate our emerging Master Plan. Planned changes include those necessary to accommodate significant increases in student numbers, growth for on-site residential provision;

amending the site's planning boundary to include a possible community use facility of a GP's practice (already sited here); and to also encourage development of the emerging Enterprise and Business quarter on-campus. Any requests we propose for relevant development can be accommodated within our main campus as an 'Area of Change'. Further details on our plans will, of course, come forward with the production of the Master Plan.

14. Universities UK has recently produced a document entitled Universities Planning Guidance in April 2008 which provides management guidance which encourages pro-active engagement with new local plan-making processes and to include Universities Response to the Hull Core Strategy issues and options report, June 2008 October 2008 287

Company / Section Section City Council ID Your response Organisation number title response estates as a formal part of the wider planning process. Creating an 'Area of Change,' subject to our proposed Master Plan that reflects the University's development needs would recognise the importance of this locality as an economic growth point for strategic provision of higher education.

15. Whilst Hull City Council has progressed with a BSF initiative for the Newland School site, we would note that this is sited within a pocket of land inside the University's main campus, and that this location provides a significant option for potential future expansion of the University, at least in the long term. Options In respect of higher education facilities, this should also encompass Noted. 423 Hull Forward 22 further education and appropriate locations should be identified. Suggested Support Wrenbridge Land Para. 6.8. WLL support the Council's spatial vision for the City at 152 6. spatial vision for welcomed. Limited 2026. the city Page 154. We support the proposed Vision for the City. We Support English Heritage Suggested particularly welcome the inclusion of reference to maintaining the welcomed. 175 Yorkshire and 6. spatial vision for distinctive feel of the City’s neighbourhoods and respecting their Humber Region the city historic past. Para 6.3. A city cannot be living, learning, etc. Revise to "a city Noted. whose people are learning, working, etc." Obviously they are Suggested Friends of "living," so that word can go. 281 6. spatial vision for Pearson Park the city Para 6.8: No need for confusing visions. The one stated on this page will suffice and is certainly better than the previous. Suggested Sport England consider that the proposed vision is reasonable and Support 179 Sport England 6. spatial vision for is sufficiently broadly drawn to meet the interests of sport and welcomed.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 288

Company / Section Section City Council ID Your response Organisation number title response the city active recreation wherever these arise in the spatial planning of the City. Walking or riding a bus up Beverley Road is interesting, instructive, Noted. but at times saddening. It obviously had, and still shows signs of, a Suggested “distinctive feel”, but respect for its “historic past” is disappearing. Local resident 219 6. spatial vision for the city The same could be said for Anlaby Road, and other places in the City. We need to realise that there is still much to capitalise on, preserve, and bring into focus. Para 6.8. Whilst it is recognised that there is a need for ‘a place- Noted. We will related vision’ in the text, we feel that the actual vision fails to consider a more deliver one, being too short and too generic – it could be anywhere. locally distinctive Government A useful example is given in the PAS Core Strategy Guidance. vision for the Suggested Office for Could Hull’s not set out, for instance, in which wards key spatial next draft. 288 6. spatial vision for Yorkshire and the change will occur? You may consider it more appropriate to the city Humber physically locate the Vision after the Issues/Challenges so as it is clear to users what the Strategy is striving for at the outset. Strategic objectives should flow from the vision and be spatial, specific and propose deliverable options. East Riding of Yorkshire Council supports the general thrust of the Support Suggested vision. It is considered however that this would be better placed at welcomed. East Riding of 445 6. spatial vision for the start of the document to help show the context for the Yorkshire Council the city subsequent objectives. It will then be possible to show how the 22 objectives will help deliver this vision. The RSPB does not support the suggested vision for Hull. The Noted. Suggested vision fails to mention the need for safeguarding the environment 341 RSPB 6. spatial vision for including the designated sites, nor the need to restore and enhance the city Hull's environment.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 289

Company / Section Section City Council ID Your response Organisation number title response The suggested vision statement appropriately reflects the role Support Suggested assigned to Hull through RSS as a ‘Regional City’. (Bearing in mind welcomed. 424 Hull Forward 6. spatial vision for this is a planning document that needs to reflect higher level the city planning policy). We don’t necessarily agree that everything listed should be left to Noted and other DPDs, though this is a matter of degree to some extent. Core matters will be Strategies must be spatial, they play a fundamental role in place dealt with prior to shaping and in the delivery of land, uses and associated activities next draft stage. and must cover all relevant matters. This means that the CS will need to take important decisions.

You may wish to consider a number of issues arising, for example:

1) Does the CS adequately present a spatial/settlement strategy ?

Government More detailed 2) Waste and minerals matters are omitted from the CS. As Office for 289 7. planning previously mentioned, we think they ought to be covered, even if to Yorkshire and the matters a limited degree. Humber

3) Transport and accessibility – this ought to be a key area. Has it been covered adequately?

4) A housing trajectory would add value to the CS.

5) Are climate change issues, especially renewable energy addressed adequately?

6) Design, access and crime prevention. Crime is a significant issue for Hull (LAA priority indicator) can issues be captured/addressed

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 290

Company / Section Section City Council ID Your response Organisation number title response better in the CS?

7) Environmental protection, especially given the Humber Estuary European etc designations. Do you consider they are covered adequately?

8) Saved policies – will need to be clear about what the CS will replace. The CS should be robust enough to be able to deal with reasonably Noted, and Government foreseeable change. Risks to delivery should be assessed and matters will be Plan delivery Office for contingency options – a Plan B – to achieve plans objectives dealt with as part 290 8. and Yorkshire and the should be identified in the event the policies cannot be delivered. of the next draft performance Humber Also needs to be credible in terms of the resources available to stage. deliver the plans objectives/options. Hull It has been noted that Yorkshire Water is not included on the list of Noted. Yorkshire Water Appendix Development members. We cannot find any invite to this group and are surprised 255 Plc i: Framework that we were not invited to this forum. We would very much like to forum members be involved in future meetings involving the forum members. In general, the presentation and content of the Spatial Options Map Support is supported. In particular, the more focused areas of employment welcomed. land to be retained (compared with the employment areas established in the City Plan) are welcome, subject to the separate representation made on Options 21. Dransfield Spatial options 140 Properties Ltd map However, in a strategic map of this nature it should not be See A13.1. attempted to show the detailed boundaries of individual centres. Rather, these should be shown with a more generalised block of shading. It may well be that in pursuing other Core Strategy objectives, for example in relation to sustainable communities and Response to the Hull Core Strategy issues and options report, June 2008 October 2008 291

Company / Section Section City Council ID Your response Organisation number title response service hubs, the boundaries shown (which reflect those in the City Plan) need to be amended. It is therefore unhelpful to reinforce the historic boundaries in this strategic diagram.

An example of this is at Holderness Road, where the area between the north of Holderness Road and Mount Pleasant has been identified as the most appropriate location to help accommodate the service hub function, but which on the Spatial Options Map largely lies outside the defined centre. It may be helpful, separate to this diagram, to consult on detailed revisions to these historic boundaries.

As a minor point, it is not clear why the "General Options" are listed in the key, and what distinguishes them from the other options. The KC Stadium is excluded from the West Hull regeneration area - Noted. See also focus of physical change -on the Spatial Options Map. Accordingly, A13.1. an amendment to the spatial options map is sought, to incorporate the stadium site, recognising the potential for change on the Wrenbridge Land Spatial options 147 associated car park areas and also more widely through Limited map regeneration and restoration of the park, as already outlined through the emerging NASA MP. This will also achieve conformity with Map A2 which incorporates that Stadium within the Priority Neighbourhood Group. Henderson Spatial options Should the defined city centre not be notated as a regional/sub Noted. See also 323 Global Investors map regional centre and primary focus for new retail development. A13.1. ABP support the allocation of Alexandra, Queen Elizabeth and King Noted. See also Associated Spatial options George Docks as an employment area. However, for the reasons A13.1. 296 British Ports map identified above, request that the Core Strategy, and any subsequent Area Action Plans for the port area identify these Response to the Hull Core Strategy issues and options report, June 2008 October 2008 292

Company / Section Section City Council ID Your response Organisation number title response Docks as an area for port-related development. This will protect ABP’s existing operations at the port, which are vital to the long term economy of the city.

ABP also support the allocation of Albert and William Wright Docks as an area of potential change for mixed-use development. As stated above, it is possible that parts, or even all, of Albert and William Wright Docks will become vacant in the next 5 to 10 years.

In addition, Albert and William Wright Docks are considered to be suitable for residential led mixed use development in light of their:

■ Previously developed nature;

■ Very attractive waterfront location, which offers the potential to attract significant inward investment;

■ Close proximity to the city centre, and the job opportunities, shopping and leisure opportunities located there;

■ Location on public transport routes, ensuring accessibility to the majority of the city’s population via public transport; and

■ Location at the heart of the current redevelopment area of the city.

In light of the above, ABP consider that Albert and William Wright Docks offers an excellent opportunity for a future exemplar residential led mixed-use development on the waterfront, which has the potential to attract significant inward investment into the city. As Response to the Hull Core Strategy issues and options report, June 2008 October 2008 293

Company / Section Section City Council ID Your response Organisation number title response such, it is requested that Albert and William Wright Docks are also identified as a potential residential led mixed use development site on the Spatial Options Map accordingly. The Key Diagram is very detailed and could be confused for a See A13.1. proposals map.

There is concern that site-specific proposals for land within East East Riding of Spatial options 446 Riding of Yorkshire are shown on the Key Diagram. It is considered Yorkshire Council map more appropriate for sites or designations within East Riding of Yorkshire to be considered through the preparation of the East Riding Core Strategy (Key Diagram) or the East Riding Allocations DPD. All designated sites relevant to the Hull LDF should be indicated on See A13.1. the spatial options map as per paragraph 5 (i) of PPS9 which says that "Local development frameworks should indicate the location of Spatial options 342 RSPB designated sites of importance for biodiversity and geo-diversity, map making clear distinctions between the hierarchy of international, national, regional and locally designated sites". This will ensure conformity with national planning policy. Hull's proposals to adopt a phased or 'stepped' approach (4.2) to achieve the Noted. Discussions city's growth ie. in particular its residential development target set by the between Authorities government, is noted and appears to be quite acceptable until concerning potential the implementation of Phase 3, timed for 2021 to 2026 which states that "Edge of urban extensions are Future City urban extensions will be under discussion with the ERYC towards the end of progressing. Hedon Town Section 4. Development the plan period ". Hedon Town Council wishes to express its concern that any

Council Needs such plans may result in the narrowing, or indeed complete loss of the green belt between the eastern edge of the city as it presently exists, and the town of Hedon. Our fears are that the important open pasture land known as the airport field will become a target in the City's need to expand and the loss of that important amenity is unacceptable to our residents and indeed those of the neighbouring villages. The encroachment of the city up to the boundary of our Response to the Hull Core Strategy issues and options report, June 2008 October 2008 294

Company / Section Section City Council ID Your response Organisation number title response town will inevitably result in the loss of Hedon's unique identity and character such as happened many years ago in the case of Sutton. We understand that the East Riding is also uncomfortable with the idea that Edge of City extensions seem to be already on Hull's agenda without any discussion having taken place with them. Hedon Town Council would also wish to be involved in early discussions regarding any such proposals in our vicinity. Your reference to the completion of the Eastern Park and Ride site is noted and Noted. this Council is generally in favour of such a facility, however its location and its potential impact upon the local road system should be noted. Even now, some 10 years before it's projected completion, the traffic congestion in the vicinity of the Page 33 'Realising a Hedon Town Saltend and Queen Elizabeth Dock roundabouts (which will be even worse if the Table 4.1 Stepped proposed incinerator is constructed) particularly at the evening rush hour requires Council Approach' very careful consideration to avoid making matters worse. Hedon Town Council would wish to take part in discussions relating to the proposal at an early stage as members feel their local knowledge will be useful and enable your Council to make appropriate decisions. The issue of housing This section talks about Housing Land supply and the house-building targets P.77 requirement split will which the city has to achieve. Apparently Hull has to aim for 18,400 dwellings Section need further Hedon Town before the year 2026, and the East Riding has to build 26,000. The question to B.21 discussion between which we would like an answer is 'If the city creates 'urban extensions' will the Council Authorities as number of properties that get built upon them come off Hull's target, or the East evidence base work Riding's? develops. The need to meet the needs of Gypsies and Travellers is discussed, and the Noted. P.82 proposal to improve existing sites in the city and creating a further 72 pitches Section Hedon Town between now and 2021. It appears you propose to locate some of these sites in B39 - 40 the East Riding, however surely the county already has its own target to meet Council before allowing the city to move its gypsy responsibilities outside its own area. If any Gypsy sites are proposed for this vicinity, Hedon Town Council would wish to be involved in discussions at an early stage.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 295

Appendix 2 – Local feedback from locally based ‘Road shows’ and Customer Service Centres

Road Show Events East Park – 26 July 2008 • Concerns with the BSF consultation process, it was explained the consultation process was the concern of BSF and every stage will have been evidenced, including councillor involvement. • Concerns regard the Tesco site on Hall Road and the proposed Park and Ride Site (Beverley Road) but did not elaborate on these issues. • Concerns raised by Telford & Brindley Street residents that the regeneration process would miss out their streets, in effect their properties would take a backward step within the local environment. • East Hull needs regeneration. • Affordable housing is still expensive. • New regeneration areas should not make existing areas worse. • Grants should be available for internal home improvements. • More Family Friendly housing, decent size homes including a front and rear garden. • High quality, energy efficient housing, with regards to the current and future price of gas and electricity. • Grant towards insulation of existing housing. • Housing stock requires improvement • Shared use of facilities a good idea, but, must not be detrimental to the school, example of under-provision of parking and changing facilities at a local school leading to local annoyance at key times of use, and for example cleaning of football boots in school entrance detrimental to school. • Transport should be co-ordinated (not arrive all at once), weekend provision not adequate for weekend workers. • Transport should be more accessible access, i.e. access-buggy friendly. • Reduce congestion on Holderness Road (not traffic numbers), by improving flow, no parking on yellow lines additional of street parking areas for shoppers to keep the road clear.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 296

• Interchange – Excellent. • Adequate greenspace, but not enough playspace (lots more needed). • Provision of greenspace seating not adequate. • Happy with greenspace. • Paving should be more accessible. • Provision of WC facilities for visitors/day trippers (Day pass system as in Nth Yorks). • Hull City Centre, excellent for tourists & locals. • High level of local pride in the City, must be promoted more for good points. • Move Arctic Corsair to the Junction/St Andrews lockpit. • Speedway should relocate to former go-kart track location at the Junction. • Loss of Kwiksave at end of Holderness Road detrimental to area. • Loss of Kwiksave at Calvert Lane/Spring Bank West has been detrimental to area (leading to loss of other shops) & has lead to a reduction in security of area for local residents. • Happy with Holderness Road shops. • St Stephens needs to be full to be a popular destination Yorkshire wide. • Will St. Stephens lead to decline of City Centre shopping. • Must be accessible locally and by public transport (not multiple bus trips). • New sites at Preston Road and Longhill are very good. • Retain local facilities. • Retain historic buildings • A safer environment (remove unsavoury people from key locations) • Important to have safer parks to take children to.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 297

• More family friendly pubs • More facilities for ‘Parkour’ • Toddlers playground in East Park should be age limited • Should be more ‘shared ownership’ housing • There should be more activities available to suit older children • Pavements in the City Centre need repairing as since it is difficult for the mobility impaired to get over some of the uneven surfaces. • City Centre Screen was a bad idea. • The open space available in the City is good. • The one way system within the City Centre needs sorting out to make it less dangerous. • Smoother surfaces are required on footpaths - there is a particular problem at the junction of Maybury Road and Holderness Road where slopes have not been installed to assist those in Wheelchairs to get across the junction. • It is difficult to get around on buses for the mobility impaired- not low enough for wheelchairs to roll on. • Conservation areas are important • Preston Road is a mess- the police station and library are not well linked together as they have been redeveloped in isolation • We have a beautiful City- we need to conserve the cherry tree lined approaches to the City, the beautiful parks, hanging baskets are really nice- the gardeners need to continue doing a great job. • City centre is attractive and clean- there is great architectural diversity • Parking seems to be the only great problem within the City including here at East Park. • More litter bins are required • There aren’t enough buses to get from Hull to the Villages to the East in the East Riding such as New Ellerby • Happy with East Park and Open Space within the City • More cultural/tourism facilities are required in the City Response to the Hull Core Strategy issues and options report, June 2008 October 2008 298

• We need to make more of a big deal over historical areas • We need to make sure that nice areas do not lose out to new developments. • Litter is a problem • Public transport to the east of the City to the villages needs improving • There is a need for more leisure facilities including climbing facilities, motorbiking facilities too, less swimming baths • Buses are good along Holderness Rd • Crime a big issue- police need to do more- crime taking place all the time to the top of Westcott Street at Westcott House- police don’t do anything about it • There are litter problems- need cleaner City - even the dustmen discard litter in the street. • Don’t like speedbumps on roads • St Stephens is a waste of money • East Park is excellent • Citadel should come back to East Park • More off-street parking is needed near shops • East Park is brilliant • Holderness Rd is good for buses but away from the main road the bus service is crap • Longhill is underserved by shops • More town parking required and more parking along Holderness Rd where all parking is usually taken up away from double yellow lines. • Lack of cycle lanes in some areas, if no cycle or bus lanes then cyclists have no choice but to go on pavement for safety • Need more open spaces to play in- no play space near Longhill- more higher quality play space required • Any new housing needs to be affordable

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 299

• Major routes close to the City Centre look bad • There is a need for a continuous bus lane along Holderness Road • The area around KC Stadium is shabby- could do more to link area up with Stadium • Need to do more about flood prevention • East park is good • Want more housing in city centre • Post office closures a problem- need to keep post offices open in service hubs • Crime/vandalism/pollution is a problem • There are not enough big parks • East Park is brilliant – other areas of the city need improving • Problems of anti-social behaviour, nuisance neighbours needs addressing • Trees cut down on Summergangs Road need replacing, parking bays need finishing • Certain areas seem to have all the money spent on them – how are priorities decided? • More cycle paths are needed • Old Town dry dock & fruit market – retail a good idea, not offices – enough at Island Wharf • Traffic and access problems in Sutton Village since parking bays were changed from side-on to end-on • Hull City promotion can only be good for the economy – but poor appearance of Anlaby Road and Spring Bank • BT should be able to come to city – KC needs competition • Short stay parking is needed for Holderness Road shops • Get rid of the big screen in the centre • Redevelop Queen Victoria Square • Lack of benches in East Park Response to the Hull Core Strategy issues and options report, June 2008 October 2008 300

• Too many pubs • Need more / better policing • Need to tackle empty shop fronts – maybe put bright pictures in the windows Queen Victoria Square – 30 July 2008 • The real heart of the city is the KC Stadium but it needs to be bigger now that City are in the Premiership. • City centre needs better nightlife and more café culture. Less people are going to pubs due to smoking ban. • Museums are too much centred on local history. What about world history! • Not enough good quality open space and more specialist provision needed for disabled children. • Shops and provision generally okay. • Supports Castle Street improvements especially cut through proposal. • More priority should be given to employment /job creation proposals. • The city needs better drainage system to prevent floods happening again. • How about using ballot boxing as another method of consultation on our plans? • City Centre living conflicts with evening economy • Need to do more to realise benefits of technology • Excellent transport links • Need more youth clubs and places for people to go – activities to reduce trouble • Major issues regards the City Centre approach, particularly St Stephens and the new interchange. Impact on local traders and churn of existing retailers rather than drawing in new traders • The public transport ‘loop’ should not be abandoned now we have the new interchange • Need to think beneath the gloss of the big projects and what is really happening • more jobs are critical issues in retaining and attracting people to the city, especially for heavy industrial workers

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 301

• can't find a job in the city so a vibrant economy is essential • need to plan to integrate and bring about change for the city rather than ad hoc approaches of the past • concerned about the adverse impact of St Stephens on shopping in town centre - a lot of churn rather than new investors that were promised • problem of area around stadium/Anlaby Road highlighted which needs urgent attention • there must be potential for a new motorway to the city by extending the M62 from North Cave examined alongside a new light rail system - as part of a new transport system - to alleviate Castle Street and likely to be cheaper than Castle Street improvements. Alternatively, Castle Street could be widened to accommodate a left turn lane stretching back to Rawling Way to hold stationary traffic going up Ferensway • should examine the potential for a light rail system on parts of the existing rail network and consider costs/deliverability • There should be an ice rink in Queens Gardens in the winter • Run a cable car from Princes Quay to the Marina / Humber Quay. This would be functional and a tourist attraction. • Place a youth hostel in the city – preferably in the centre or if not Pearson Park • Basic things need sorting like derelict buildings • Better public transport providing access to out-lying settlements • Tram in the city centre to help disabled people • Bottleneck of railway lines going west – only two tracks. No planned improvements for the next 5 years • How are new ABP terminals going to connect to the railway line? • Get rid of the big screen in the city centre • More police / cut crime • Keep the city clean of things like chewing gum • Better transport to Castle Hill Hospital from all parts of the city • Wethouse (place for alcoholics to live) and rehab centres needed in the city (Hull Homeless & Rootless Project)

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 302

• Create more jobs • Create more places to visit/recreation opportunities • Open more art galleries • Create more job opportunities • Tackle drug misuse • Tackle areas of almost “slum-like” dwellings and rubbish dumping grounds. • Moved to the city in 2007 having lived in various places around the country and Hull compares well with these. It has plenty of green spaces, great museums and a vibrant city centre. Hull’s bad press is underserved. • How to make Hull better? – provide more work opportunities and better education. • Improve the sewage system (especially in the city centre) – smells are off-putting for visitors. • Try to retain the historic feel of the city centre and re-use old buildings in imaginary ways, for example, the Rank Hovis building could be used as a history centre • Build houses in the city centre rather than apartments • Create more community facilities, such as, health centres and schools for people who live in the city centre • Create more green spaces • Create more leisure opportunities, such as, a swimming pool in the city centre • Create more facilities for children and young people. • The key to a good lasting impression of a city is its entrance in and out. As the A63/Clive Sullivan way is Hull’s main entrance/exit this should be enhanced and thought given to the sort of buildings allowed to be built along this route. • How to make Hull better? – provide better sports facilities, education and job opportunities. • Support improvements in education provision • Address the problems of climate change and flooding • Improve public transport Response to the Hull Core Strategy issues and options report, June 2008 October 2008 303

• Create more employment opportunities • Encourage tourism, including making more of Hull’s waterways, the Market Place, Queen’s Gardens and Whitefriargate • Create more recreation facilities especially for young people. • Hull is adversely affected by its tight boundary – both financially (lack of council tax contributions from suburb residents who work and use Hull’s leisure facilities) and in statistic terms which continually result in its negative press. • Create more skilled job opportunities • Tackle climate change and flooding • 1st priority - tackle climate change and flooding • 2nd priority - create successful schools • 3rd priority - create more job opportunities • 4th priority - improved sport and recreation facilities • 5th priority- places we like to live or visit • 6th priority - better access to community facilities • 7th priority - improve the housing mix and the built environment, especially in the city centre, Anlaby Rd and Beverley Road. • Improve services and facilities in the rest of Hull not just the city centre • Tackle affordable housing • Re-introduce an open market to the city centre to encourage shoppers and visitors back • Protect city centre services and important/historic buildings • Improve public transport • Enhance the main routes into the city, for example, redevelop empty buildings along Anlaby Rd, Beverley Rd and Holderness Rd • Create more employment opportunities and investment in Hull

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 304

• Support local healthcare provision in accessible locations • Support improvements in education provision • Create successful neighbourhoods across the whole of the city • Create a better housing mix and provide affordable housing in easy accessible areas • Create more leisure/recreational facilities for children and young people • Hull has many positives in the retail sense, especially St. Stephens Centre however certain areas, such as, Whitefrairgate and Market Place need renovating. Re-introducing an open market could encourage shoppers and visitors back to this area of the city centre. • Create more off-road cycle paths – ‘encouraging and developing healthy forms of transport is needed in Hull’. • Needs more investment in schools and research into why they are failing at present • There is a lack of accessible large community facilities in Hull • More funding (which until recently was provided by HCC) and support needed for community run supplementary language and cultural schools • Tackle areas of poor quality housing • Improve social housing, for example, the housing of refugees, which is often done on the basis of finding the cheapest housing options rather than the most suitable • Places of worship • Improve support for places of worship and identify sites for expansion of existing/new facilities • Problems with A63 still to be resolved • Improve Park and Ride facilities • Create more off road cycle paths • Improve public transport provision • Investigate the viability of other forms of public transport, for example, trams

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 305

• Improve the mix of shops • Healthy Living • Limiting permissions for takeaways should be more strongly encouraged • Improve sports facilities, play areas and open spaces • Make sport and recreation activities more accessible for all, for example, improve women only swimming/gym sessions • Improve drainage systems • Attract more, higher value employment opportunities to the city • Address Hull’s negative image and constant bad press by highlighting its positive qualities. • Protect and enhance locally important buildings, listed buildings and conservation areas within Hull. Pearson Park – 2 August 2008 • Council houses - on Stanley Street - need improving. Wood cladding needs bricking up. This should be a priority before redeveloping the city centre. • Provide a big fun swimming pool in the city centre - like Doncaster Dome. Lots of chutes • More (art) exhibitions it city needed • Council gyms - equipment is out-of-date and not safe • Re city development - we should do less things but do them well. • More Council-owned internet cafes • Problem with broken glass on roads for cyclists • Need more tennis courts and football pitches in area (Pearson Park) • Make school more fun with more events • Affordable housing that meets the needs of disabled people • Improve Bond Street & Albion Square & Kingston House

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 306

• Need to light up the Pearson park to make it safer at night • There should be an extension of the Beverley Road alcohol free zone • Need for seating around water in Pearson Park • There are environmental health issues with wheelie bins • There is enough open space- we just need to improve what we already have • Impoundment of River Hull a good idea- boat rides- would like the Council to go to Portsmouth to see what they have done with their water frontage • There is a need to improve the river frontage • Office block remains empty at Humber Quays- should have been housing instead to take advantage of the location • Should be disabled access on the Humber frontage all the way to the Humber Bridge • More Park and Ride is required on Beverley Road and Hedon Road • Improve facilities at Walton Street car park including toilets • Should have congestion charging within City with a lower charge for less polluting vehicles • Need to have a visible police presence to make Pearson Park safer • Most development needs to go on brownfield sites • Traffic flow on Castle street is too slow- congestion • Clough Road and Freetown Way junctions with Beverley Road- need better pedestrian facilities- ‘green man’ lights to show when it is safe to cross. • Better enforcement of zebra crossings is required • Street signs in the City Centre need improving some streets are left without their name signs • There are crime issues along Wellington lane • The footpaths need improving in Pearson Park

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 307

• Passageway near Netto off Beverley Road is dangerous- a crime hotspot • More community facilities are needed- a mixture of facilities for all age groups. • Want less bars in Princes Avenue • Need better access to a major supermarket- nearest one is Tesco - St Stephens • A local sports centre for Princes Ave would be good - nearest one is Ennerdale • If the City was more attractive for nightlife opportunities, there would be less of a need for bars/clubs etc in residential areas. • We need to harness tidal power by installing turbines in the Humber • Bring back trolley buses • There is a need for controlled parking zones around the Princes Avenue area so that residents can get a space to park up. • For non-english speakers, there is a big communication problem with the Council. Simple translation services or use of pictograms to communicate would be useful. • The council is only concerned with council owned properties, such as, council housing. Private landlords are not held accountable for the upkeep of their properties, state of gardens and rubbish removal. The respondent is shortly leaving the Newland Ave area as they feel it is slowly becoming a slum area due to these problems. They feel that Hull’s negative image is justified. • Support improvements in education provision: • encourage staff retention • tackle truancy • tackle anti-social behaviour in schools • impromptu inspections • provide greater opportunities for non-academic students, such as apprenticeships • More job opportunities • Improved sport and recreation facilities

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 308

• Tackle climate change and flooding properly • Look into the use of tidal power Northpoint – 9 August 2008 • Council houses are not renovated quickly enough - start job but never finish off. • St Stephens is not nice- it is not providing new shops as they have all moved from Whitefriargate. There are no shops for the older generation. • Better policing needed as there are high crime levels in neighbourhood • Children need to stay in education longer as they do not have the skills to get a job • The Saltend incinerator is built already at Driffield and waiting to be transported to Saltent • Sewage works at Saltend is causing a smell to rise up through the floors of peoples homes along Hedon Road. Yorkshire Water do not do anything about it. • We need more wind turbines in the City- they are very relaxing! • We need another supermarket at Northpoint as the nearest one is at Kingswood which can be an expensive taxi ride away for the mobility impaired. • Flood risk issues are important- need to protect against flooding • The old Coulford School needs turning into greenspace as there is a lack of playing space around Northpoint- nearest is 20 mins away by foot. • Have to pay to play football at Ennerdale • Council Estates need keeping better- grass cutting and making nicer • Waste collection is an issue- Black boxes sometimes do not get collected when they should have been. It is ridiculous that no catch up collections were made over Christmas. Dustmen should be on a contract which obliges them to collect at Christmas/bank holidays etc- it is a service the Council should provide. • Recycling bins outside terraced houses in inner areas makes the area scruffy • City centre has improved, now more cosmopolitan – museums, marina

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 309

• Car parking too dear, train from Cottingham is quick, but expensive for a family • Bus lanes are good • Sculcoates area much improved – new housing, cemetery • Regeneration of inner areas is good, instead of building on greenfield land outside the city • Marina dock needs dredging • North Point provides a good choice of shops and market • City centre is better than it was, but St Stephen’s is for younger people • The council do a good job • Provision of play areas for children is good • Ings Centre is good – particularly Netto • Longhill has few shops now • Greatfield is left out of everything – not included in Holderness Road improvement area • Shops closing in Greatfield, no community centre or medical centre • Drains in Greatfield still flooding – not sorted out yet • Whitefriargate is declining, centre is shifting towards station • Big screen is a waste of money and ruins the view along King EdwardStreet • East Park is very good • Freedom Centre on Preston Road is very good • Greatfield is becoming a dumping ground for problem families • Buses are good • Jobs are available – there are families where each generation works, and others where each generation doesn’t work • University is good for the city, some schools are good – it’s down to the individual how well they do Response to the Hull Core Strategy issues and options report, June 2008 October 2008 310

• There’s good and bad points to Hull. There’s a lot of good stuff happening in Hull and things are changing but it’s not happening quick enough, things are slow to change especially round here. Last years floods are still a big issue. • Scattered shopping across the city. North Point just caters for women’s shopping, there’s nothing for kids and men. It needs sports shops and men’s clothing stores. It’s the same with St. Stephens’s shopping centre in town. • Disabled access to modern shopping centres is terrible, getting up and down pavements, crossing streets in a mobility scooter or a wheelchair is a nightmare especially in the town centre and here at North Point. • Plenty of positive things happening in Hull – we especially like the Marina, the free museums and the Deep. Although they have spoilt Wilberforce House, the mixture of modern graphics with sound effects and the old buildings/historical interiors don’t work. Hull has nice greenery along the sides of many of its roads which look good, but there are not many quiet areas where we can sit and enjoy nature, at the moment we have to go to the cemetery. Hull needs designated quiet areas where loud music, mobile phones etc are discouraged. Floods and the risk of further flooding still an issue, we are not confident when there is heavy rain (live in a bungalow which was flooded last year and out of house for 10 months while it was repaired) and problems with the gutters still exist especially on Howdale Rd. Because of this we are looking to move from the bungalow. • Risk of flooding still a concern, we have not been told what measures have been taken to stop it happening again. • Kingswood – needs a primary school within walking distance of the new houses and a new secondary would be a good idea. There are too many flats being built in the city centre because a lot are still empty and are too expensive for most people. However these new buildings and conversions have made the city centre look more attractive. • Good things about Hull - not a lot, I have lived here all my life and would now like a slower pace of life, less hassled, maybe in the countryside. Although Hull has been good for my daughter who has learning difficulties, her needs were not addressed by the primary school she went to but her secondary school (not a state school, but part funded by the council) has been very supportive. • Born and bred in Hull but feel very let down by the Council over how it handled the repairs in the wake of last years flooding. No communication with the council or the contractors along the way – our concerns were not listened to (major problems with the standard of work from the contractors, including having to refit the kitchen several times). • Waste collection problems especially at Christmas and the other bank holidays. • A major way to improve Hull would be to stop people drinking on the street, it gives a very negative impression of the city. • A better mix of shops is needed at North Point including a new food store like an Asda or Morrisons

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 311

• Concern about the influx of immigrants to the area in taking jobs and housing • Areas subject to demolition need improving in the short term • City needs to be cleaner! • Access to shopping is poor in the area. I have to go to Asda (Kingswood) to shop which is too far and don’t have a car. Taxi’s are too expensive. • Area around North Point needs improving in terms of more green areas and things for younger people to do. • Important that main shopping centres across the city are improved so as not to drag the city down! • City must move forward and improve. • City needs greater ambition and should not be critical of what is being achieved. People are too quick to criticise and not enough thought is given to what has been achieved. • Buildings are important but population mix needs to change to make a difference. • Vital that the city has a plan to ensure new opportunities happen! • Flooding and climate change – confidence is still low in last years affected areas when it rains. What measures have been included in the Core Strategy to tackle potential threat of flooding to new properties? • Create successful neighbourhoods where people respect each other and want to live. • Create more leisure facilities for young people • Tackle flooding issues • Create more facilities for older people • Improve the appearance of Hull’s streets and provide large rubbish removal facilities • Improve local community facilities, such as healthcare provision and emergency pharmacies • Tackle flooding issues • Create more sport and recreation facilities, especially for younger people, in the heart of local communities • Create successful neighbourhoods, with good community and recreation facilities Response to the Hull Core Strategy issues and options report, June 2008 October 2008 312

• Tackle flooding issues and drainage problems Customer Service Centres Orchard Park – 29 July 2008 • No supermarket and Tesco (Hall Road) too far. • Orchard Park Centre is in a poor state. • No shops. (an issue repeated by a number of people) • Need more spending on services. • Don’t want a health centre building (referring to the new NISC building) we already have one. • Need to start early to educate children from a young age to produce a better future. • Limited greenspace Calvert Lane – 1 August 2008 • Create more attractive neighbourhoods – especially tackling fly tipping in residential areas. • Tackle areas of fly tipping • Create more locally accessible community facilities, such as maternity services Walker Street – 6 August 2008 • Concern about immigrants taking away local job and housing opportunities • Need housing that meets people’s needs now, not at some point in time in the future! • Fear of crime and making people feel safe are important • Priority should be to create greater mix of people in the city and better quality environments – its not just housing that needs improving • A lot of housing here is ‘last choice’ and struggle to get a property • Area has great parts to it but the majority is poor quality environment • Area needs better shops, open space, pub and club!

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 313

• Council housing in the area is poor! • Area is a focus for immigrants because people feel safer if they live close to those that share the same culture and background • Nothing has been done to improve the quality of life here including poor George Street – 8 August 2008 • Night life in the city centre is OK • St Stephen’s has only taken shops from elsewhere in the city centre – better shops are needed • Don’t go to parks • Buses are OK • More jobs are needed • Housing is OK • But a lot of improvements are needed in Hull • The city has too many drug addicts and burglaries • Hull is a good place, the new buildings are good • East Park is good • Shops in the city centre are improving • Housing is improving, e.g. New Bridge Road • Bus service is good on main roads • Local shops are good, e.g. Holderness Road • Jobs are there if people are prepared too look • New development has made the city worse, e.g. St Stephen’s (mother) • New development has improved the city – particularly St Stephen’s (daughter) • Government & Council are bad, Council Tax is unfair

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 314

• Don’t use the city centre, use local area instead • Local shops closing down e.g. Longhill • Buses good but should be cheaper • Don’t use parks, but East Park is good • Bigger range of jobs needed, including jobs for people without qualifications • Homelessness is a problem • Too many drug addicts and foreigners • City centre has improved • Estates need cleaning up, council taking too long to improve property • Buses are good but too expensive • Parks are OK • Employment needed for unskilled current slump in building trade • Funding needed to take courses. • Housing is a problem – homelessness – houses go to immigrants instead • City centre is improving – cleaner, safer at night, retail is better • Parks are good • Buses are good – reasonable fares • Jobs are available if people want them • Queen Victoria Square needs cleaning up – big screen a waste of money • Housing allocation system is poor • City centre needs more toilets, facilities for prams and baby changing • Street lighting is poor, drains smell Response to the Hull Core Strategy issues and options report, June 2008 October 2008 315

• More parks are needed, and areas for young children • Buses are OK • Hull needs graduate jobs – most graduates have to leave the city • Big screen a waste of money • Local shops are OK • The Deep is good • More facilities for teenagers are needed e.g. the Warren • City centre is better now, e.g. St Stephen’s – more needed • Buses are good • Parks are good • More jobs are needed, factory jobs are taken by Poles etc • More tourist attractions are needed e.g. the Deep • Hull needs more large affordable housing. • Needs more houses for larger families • Needs more affordable housing and social landlords (Housing Associations) • Orchard Park (especially The Danes) needs regenerating. Holderness Road – 12 August 2008 • Shopping areas need improvement. • There are some good schemes in the city centre but we are let down on the periphery. • Support the redevelopment of some schools. • There is more congestion on Anlaby and Holderness Road. • Need additional or better / improved river crossings.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 316

• Better ring road. • Supportive of the need to improve education facilities around the city. • Support for improvements to service provision around the city – i.e. the hubs. • Need for future council / affordable housing. • Road treatments are not appropriate – not improvements congestion and rat-runs. More traffic volumes. • Hull is a great city when compared to other cities. • Vacant houses should be filled rather than building new ones. • Vandalism and issue – feeling of safety and security. • Really feel that there is a need to sort out the existing rather than build new. It is not just the fabric and materials – people are important • Problem of ex offenders being housed in Council properties • Will more facilities be provided for Gypsies and travellers – will more encouragement be given to the use to prevent illegal camps. • Parks are important but need to be usable, for example provide wardens. • Create more community facilities and leisure opportunities for younger people. Newland – 14 August 2008 • No comments received.(Questionnaires also distributed but no responses received) Ings – 19 August 2008 • There’s a lot of vandalism and other anti-social behaviour, especially by young people around the Ings area. The community is not as strong as it used to be, with people not showing each other enough respect. • The city centre has differently improved and is much more attractive than it used to be. After the shops shut it can still be a little intimidating although with St. Stephens’s shopping centre opening after 5.30 that part of town is more accessible and welcoming. • Flooding and whether the drains will cope in heavy rain is still a concern following the floods of last year. Will it happen again?

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 317

What measures have been taken to stop it happening again? Confidence on this issue is not very strong. • Things seem to be improving steadily in Hull, especially in the city centre, the new bus station is a great improvement. It’s also happening in the city as a whole and around here but it’s not always as obvious as the high profile schemes we see in the city centre. • We need more facilities and things for young people to do. More sports and recreation areas are needed. Young people do not feel their views are particularly listened to by the people making the decisions. Important things to young people such as sport facilities and after school/holiday activities are usually the first services to be hit when cut backs are needed. • Things are happening around the city, activity schemes such as canoeing in East Park for example are well attended during the holidays. These sort of schemes need to be invested in, expanded and encouraged. • More safe, easily accessible, high quality play areas are needed in the Ings area. The ones around us have broken and vandalised equipment on concrete surfaces. We would like to play on grass or soft surfaced play areas which are well looked after (no broken glass!) like the ones available in other parts of Hull and Cottingham. • Create more attractive neighbourhoods • Improve local community facilities and leisure opportunities for younger people • Create more community facilities for older people

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 318

Appendix 3 - HDF Forum minutes (extract from workshops), 10 July 2008

Group 1 – considered objectives and options 1 to 9

Obj 1 – Future pace of change

• Low growth – not aspirational enough. • High growth – not realistic. • Options need to be deliverable so moderate growth option preferred.

Obj 2 – Future development needs

• How will the city be able to attract mid-affluent families? • Need to build on significant opportunities that exist including re-using previously used land and buildings and concentrating development rather than dispersing it. • Option 1 first followed by Option 2 if needed (in terms of urban extensions) • Where should land-hungry development/ industry be placed?

Obj 3 – Sustainable Development

• Only deals with new development? What about existing development? • Option 1 = sustainable development so this should be the only option.

Obj 4 – Sustainable Communities

• Castle Street is a barrier to East Hull development.

Obj 5 – Regen Priorities

• Already determined by Gateway? • We should not be spreading resources too thinly? Response to the Hull Core Strategy issues and options report, June 2008 October 2008 319

• Regeneration supported as stated.

Obj 6 – Climate Change

• Adaptation as well as mitigation. • What code for sustainable homes level?

Obj 7 – Flood Risk

• In accordance with SFRA. • Sequential and exception tests need to be taken into account.

Obj 8 – Transport

• Lack of cycling policy – why? • Safety issues. • Staggered opening hours could be an alternative.

Obj 9 – Infrastructure funding

• Option 1 – scoping report suggested as preferred way forward.

Group 2 – considered objectives and options 10 - 20

• A significant question concerned the impact of the housing credit crunch • Affordability – mix of tenure and type is key as well as the numbers to be provided. • Issue of new build size. Quality of housing is important not just shoe boxes! • How can Hull City Council intervene in terms of Houses in Multiple Occupation and bringing stock back into beneficial use? • Commercial properties – vacancy intervention.

Obj 17

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 320

• Need to set design sights higher. • Exemplary standards needed. • Design Statements might be useful but they are rather weak. What is needed is a proper design strategy in order to help deliver high quality places and buildings, which includes % for art and greater use of the Arc process to raise standards. • How is ‘high design quality’ taken forward by Planning Committee? • What are their parameters so others can understand these?

Obj 10 Option Sufficient?

• Issue of housing requirement figures confirming with Regional Spatial Strategy of should they come from the more recent Housing Market Assessment? • Risk – has any Council followed HMA approach through to prove soundness?

(Part 2) page 14 obj 16

• Integrated care centre not ‘super hub’! Refer to: Strategic integrated service plan, although this was not available to view on the web. Obj 13

• Holderness Road shopping centre – don’t reduce • How to address implementation of policy?

Obj 18

• Public and private gardens contribute to greenspace.

Group 3 – considered objectives and options 21- 22

Jobs and prosperity/learning theme Response to the Hull Core Strategy issues and options report, June 2008 October 2008 321

Obj 21

• Is it the Councils remit to look to delivery of land to employ secure development.

• Objective should add “secure development” to meet…. etc.

• No mention of education in jobs and prosperity objective – ‘knowledge economy’ specifically change of use of buildings for ‘higher quality’ employ land/jobs etc.

Option 21

Option A

1) Need to clarify meaning of ‘safeguarding land’ for employment use? Land in the right location is as important as quality of land/buildings. Priorities of development – shown as phasing at present. Feeling City Centre should be priority – agreement with current priorities indicated. Phasing strategy is needed so different agencies can target needs accordingly.

2) Should specific clusters be defined? • Do we remove the words ‘or alternatively’ – is this another option?

• Identifying particular sites – too definite maybe in wording suggest rather than prefer destinations for key sites (could put developments in other areas less desirable).

• Land should be identified for particular clusters to meet future needs so we don’t take an ad hoc approach like with Priory Park where uses don’t work well together.

• Is the Council taking steps to CPO/assemble land for land between St. Andrews and the City Centre – ABP land generally.

• Knowledge economy/creative industries/needs mentioning as one of the key cluster’s along with post/health logistics. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 322

Preferences – sensible combination of options

Option 22

• Learning and skills (very important issues for City and its successfulness/appeal to others etc) but not given much space – can planning deal with this alone, do we need joined up thinking?

• Should it have links to other strategies happening in the city?

• More objectives are perhaps needed.

• Options – mention FE as well as HE – combine FE, HE and job creating/developing skills.

• The University site on the spatial options map needs to be shown as an area of change and key strategic site.

• Do we need more schools? Not necessarily in terms of numbers but should be at the heart of the communities – 2 outside Hull admin boundary.

Option – need more room for university. Could Newland School for Girls site be offered to increase/enhance education. Need to specifically mention Hull University in options. Should there be more guidance for student accommodation as part of the University?

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 323

Appendix 4 – Yorkshire Planning Aid workshops feedback from young, elderly, ethnic minorities/faith and disabled communities

Young people detailed feedback

Hull Development Framework Core Strategy Workshop 1 Hull College. 2pm, Thursday 25th September. NC Media Y2 [Performing Arts and Media] students.

Attendees:

Joshua Barker HU2 0DY Rachel White YO25 5JW Emilie Brooks HU17 7AL Sadie Kelly HU8 9SJ Rachel Spence YO25 8LF Rozh Ahmad HU2 8AU Shane Simpson HU7 ODU Alex Ford HU10 7UH James Johnson HU7 4AQ Richard Savage HU6 9NP Tim Wileman HU17 7QW Jason Hicks HU16 4QW Terri Hampshire HU8 9JT Lauren Pearcey HU11 4BN Stacey Roche HU3 6QU Chloe Buckley HU5 H0Q

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 324

Place The Good The Bad

Beverley x2 Historical, small, peaceful. Nothing to do, full of old retired people.

Westwood greenspace, shops, friendly No jobs, travel for entertainment, near people. floods. Driffield Fields, new sports centre, nice people, lots Poor shops, old people, nothing to do, of pubs. have to travel for entertainment. Cottingham Fun, friendly, quiet, spacey, parks, modern, Trains, traffic peaceful, lots of memories. Willerby McDonalds breakfast, Jacksons, Bus stop Problem young people are increasing, to go to town in square, Woodheads, good police station at bottom of street, not for partying and chilling enough pubs etc. N Frodingham All my family live there. No shops, nothing but farmland, no way of getting out of the place. Marfleet [east] Near shops, nor far from city centre, nice Near rough area, not a lot for kids to do, area of houses, lots of buses, close to near to river [flooding] parks, close to leisure centre, quiet area. Stoneferry [east] Good neighbourhood, OK houses, new Industrial estate nearby, only one bus houses being built, good school nearby, service, nothing to do, no shops. doesn’t flood much. City Centre x2 Everything is close, good houses, green, No shops actually next to us, not enough everything is good. houses, drains always block.

Close to town, walking distance to college, Derelict buildings, not many historical close to schools and sports centre, buildings. community centre. Bilton Nice area to live. Flood area, not many shops/ Sutton Park Clean area, quiet, safe, good quality Bad transport, [only one bus service], not houses, no floods. enough recreational facilities, a big windmill.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 325

Anlaby Common Nice area, safe area, close to town centre, Floods. close to KC stadium, loads of shops and pubs [everything in close proximity]. Greenwood [north] Live fairly close to a sub-standard library; Loads of problem youths and poor I’m moving next year transport, nothing to do, on flight path, poor quality housing, crime, too close to Orchard Park West Hull x2 KC Stadium, Hull fair, close to shops, near Train line at back of house [shakes house], parks for kids, plenty of buses, decent house floods when it rains too much houses, swimming bath close. [“Chance Av bridge”?], roads really busy, small garden, narrow roads down to grass Hull fair, KC Stadium, food shops close, verge. near parks, houses nice, major bus lanes, swimming baths, restoration project, quiet Loads of run down houses, traffic, floods, street. no trees, loads of noise because of floods. Spring Cottage [east] Near primary school. No parks, not enough public transport, poor quality house, gets flooded when rains.

Discussion and Conclusions.

The group wanted to give priority to Jobs, Community Safety and Housing. During the discussion other topics were also covered.

Jobs.

• The students explained their difficulty in finding short-term jobs, even part time low paid. There are few flexible working arrangements and poor transport. 16/17 year olds had better chances as they could be paid less than the minimum wage. • There would be similar problems for careers. • When seeking jobs, “who you know” is most important. • Bad personnel practices [such as telephone interviews, applying on line and not responding to applications] are common. • Jobs for students should be close to the city centre. • The St Stephens development has killed off the city centre [shops moving out of the Princess Quay Centre]. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 326

• As regards public transport, circular trips around the city are difficult. It’s necessary to come into the centre to get elsewhere. Fares are too high. The “mega bus pass” helps but journeys are too long. • This course produces an output of about 50 students p.a. into the job market. Most don’t expect to find employment locally. More media/creative industries are required. • The centre and A63 should be the main areas for jobs

Housing.

• It was thought that the thousands of new homes to be built would not be for young people. • There are serious doubts that any homes will be affordable. • Most new housing is 3 bedroomed, but a good mix is needed to suit all. • There are problems of homelessness and also empty properties – don’t match up!? • Whilst it was noted that the Plan suggested 20% of housing would be affordable, there was concern that in the event of a change of Government this may not be maintained. • If there were more jobs, would housing demand increase and this mean higher house prices?

Community safety and facilities.

• Good street lighting is considered to be very important. • Attention should be given to road crossings. • Drug dealing is a major concern. • More police and more police stations in the community are required. • More imaginative leisure spaces for teenagers such as skateparks and playing pitches are needed. • An indoor music venue such as the Carling Academy at Newcastle is needed in Hull. • As regards more use of school buildings, it was thought that most kids would not want to go back into school at night. • There should be places for age 14+ as youth clubs are full off 9/10 year olds. • There was disappointment that prominent sportsmen from the local professional football and rugby clubs do not do more in schools. • There is a negative view of teenagers from community wardens who don’t interact positively. • There is a good skatepark facility at the Ings.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 327

Mike Dando / Alan Mitchell / Karen Bonsall. September 2008

Hull Development Framework Core Strategy Workshop 2 Hull College. 3pm, Thursday 25th September. Beauty Therapy Yr 3 students

Attendees. 10 students + tutor

Attendees: Name Postcode Rachael HU9 2UA Kelsey HU8 0NU Natalie Hutchinson HU6 8JN Staci Cooke HU3 3QS Lisa Preston HU9 4PP Kirsty Riches HU3 6QU Lizzie Wright HU13 9JH Leonie Foster HU17 5NJ Pauline Notman HU15 2EN Rebecca Marsham HU4 7ER Stephanie Greaken HU10 6IW

Where students are from.

Place The Good The Bad West Hull x2 Daily regular good public transport, A Lot Too many takeaways, too many kids of Pubs, restaurants, Close to shops. hanging about on streets. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 328

Quiet areas Lots of alcoholics and drug users. Hessle x 2 Good regular transport, Supermarkets. Trees, Flooding.

Shops, Public travel, Police patrols every Gangs of kids, Druggies, parks are night, near Supermarkets. always full of nuisance kids, Scared of robbery / mugging.

East Hull x 3 Shops, Feel safe, Not far from Town Drug users. Centre.

Shops, Feel safe, Regular buses, not far Drug users, Crime. from Town Centre.

Restaurants, Local Parks, Regular Transport, Local shops. Local drug and drink users, Crime, Take- aways.

Article I. City Centre x 2 Lots of shops, Good Transport. Crime, Vandalism, Drugs, Violence, Loud atmosphere. Some good shops, Building housing / apartments in centre to attract a Some shops left vacant but new areas residential area, Park & Ride on west being built, Parking difficulties for side of City, Some Theatres. workers, No park & ride on East side, Do not feel safe at night.

North Hull Travel good, Nice houses, Shops nearby. Noisy kids, Nowhere to go, Litter everywhere.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 329

Article II. Willerby Transport; Quiet; Sports Centre; Shops; Nothing to do; Scared of Robbery; Pubs Gypsies; Crime; Out of the Way.

Discussion.

The group chose to prioritise Community Safety and Housing, however during the discussion other topics were also covered.

Community Safety and Facilities. • There was a general agreement that it felt unsafe at night. • It was felt that alleys were particularly unsafe. • Better design and better lighting were required. • More police and wardens were required at night. • More cameras would increase safety. • More emergency contact points / alarm buttons were needed. • There should be more police stations out in the community. • Places for young people to go are needed e.g. youth clubs and community centres. • There should be special places for age 14+ • Queen’s Gardens feels unsafe; It was felt that lighting needs increasing / improving, shrubs need cutting back, the area needs securing more with fencing and more police presence was required to combat this. • There should be better joining up of facilities, e.g. Doctors/Pharmacies. • It was felt that there was not enough checking for drugs at the door of nightclubs; it was perceived that drinks were being spiked in clubs. • More Taxi cabs are needed at night. • Buses are felt to be less reliable at night – with a feeling of not being safe when transferring from one bus to another. • Retail in St. Stephen’s duplicates what is in Princess Quay • Shops moving out of Princess Quay – empty retail units. • Any future retail development should encourage more unique, individual / boutique type shops and less high street names. • It was felt that there had been a missed opportunity to market Hull for tourism. • Carnivals to attract people and celebrate the area should be organised regularly. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 330

• It was felt that there was currently little to attract people other than the Stadium, Hotels and Shops. • More affordable, big name entertainment should be brought to Hull. • Need a Spa / Leisure Centre to attract people • The opinion is that there was currently a general lack of Beauty Therapy career opportunities in Hull. • The consensus was that local Councillors showed little pride in Hull.

Housing. • Access to affordable housing was felt to be a major issue for young people. • It was felt that private landlords prefer older people. • The influx of economic migrants placed pressure on availability of affordable housing. • New housing should be built in ‘good areas’ • Half the group felt confident that they would still be in Hull in 10 years time. • There should be a preference for major redevelopment on derelict / former employment use land. • Building should be concentrated along the A63. • Better leisure facilities / good quality housing etc. will make it more attractive for employers to come into the Hull area. • Young people feel that they should be able to access information and advice (e.g. workshops) on how to access housing and on how to manage finances. • Affordable housing should be built at a density of more than 20% • There should be cheap, single accommodation, not in the City centre unless made safer. • A need for student accommodation for F.E. students was highlighted. • The majority of the group thought that housing provision available approximately 1 mile + (20 minutes travel) from the City centre was the most preferable. • Despite government guidelines on reduced parking, respondents felt that people still want adequate parking where they live. • A Park & Ride is required on the east side of the City to further alleviate City Centre traffic congestion

Alan Mitchell / Karen Bonsall.September 2008

Hull Development Framework Core Strategy Workshop 3 Hull College. 4pm, Thursday 25th September.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 331

Sports Group students

Attendees. 8 students + tutor Jade Holiday – HU7 5AR Lauren Suddaby – HU5 4ES Phil Welsh – HU16 8EZ Alex Davis – YO16 4TP Sophie Littlewood – HU13 0BN Melanie McIllwraith – HU3 3BY Abigail Farrah – HU9 5UR Andy Pattison – HU3 1PN

Representing Planning Aid – Mike Dando.

Where You Live – Good/Bad

Place The Good The Bad West Hull x4 Shops x3 Too many drug addicts Pubs x2 Drugs Nothing Dog fouling x2 Parties Too many illegal immigrants Mum being a hairdresser Nowhere to go Loads of hairdressers Adolescents drinking round shops Gangs Fighting People Too many Police

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 332

East Hull Shops close Too many drug addicts and tramps Fields everywhere Centres where kids go Easy locations for buses North Hull (Avenues) x3 Loads of gangs to hang around with If you walk out later than 8pm you’ll Loads of parties x2 probably get stabbed Shops Drunk people Hairdressers Thieves Doctors Drug users & needles all over Dentist Dog fouling everywhere Schools No clubs Lots of football pitches Nothing close by to do for fun Nice pubs

Bridlington The South Beach Nothing at all to do Nightclubs

Discussion and Conclusions.

The group wanted to give priority discussion to Sports & Recreation.

Housing.

• If 20%+ affordable housing is possible then it is supported – but much scepticism re delivery

Sport & Recreation

• Important to protect green open spaces in the city • Only provision for rugby & football in Hull – hence their success • Should be provision for other sports – volleyball, tennis, baseball, rounders, basketball, snooker, cycling, athletics Response to the Hull Core Strategy issues and options report, June 2008 October 2008 333

• Need for some Olympic standard facilities • A swimming pool in every secondary school • Need for quality and variety of provision • Parks with pitches should have changing facilities – small football clubs tend to have no facilities whereas amateur rugby clubs do • No sports-related activities/facilities for the very young, eg gyms • Poor cricket pitches • No golf clubs • More sports facilities will = lower obesity levels

Hull Development Framework Core Strategy Workshop 4 Hull College. Tuesday 30th September.

Group 1 – Starter Tracks/Foundation Studies students

PLACE GOOD BAD Newbridge Road Lots of takeaways. Not many shops. Cleveland Street Linneus Street Orchard Park Crime Longhill Holderness East Park. Craven Park Road/Eastholt East Hull Baths Good public transport and access to city centre Bransholme Cinemas, bowling and eating Crime places at Kingswood. Bilton Grange

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 334

Section 2.01 Sport and Leisure • Ice skating and swimming facilities are good. • Need more adventure activities (eg quad biking, paintballing and somewhere to ride off-road bikes where you won’t get into trouble.) • Need more places to go and watch sports such as motorbiking. • More fishing ponds.

Section 2.02 Community Safety • People hanging about and drinking on street corners is a problem, particularly in Preston Road and Holderness Road (Preston Road is worse). [Some mention was made here about gates being put in – nb alleygating]. • Why do people hang around on street corners? Nothing better to do. • Drugs are also a problem. • Some people thought there were too many police on the streets, and that another solution to the problem needed to be found. Others thought that there weren’t enough police. When put to a vote, 2 people thought there were too many and 2 people thought there weren’t enough. • Wardens and ambassadors – may be a good idea.

Section 2.03 Shopping St Stephens: • Always cold. • Nothing to do there. • Just a cut-through to other places. • 24 hour Tesco is good. • Cinema is good, you can sit close to the screen. • Staff are rude. • Difficult to access for people in wheelchairs, no lifts. If there’s a fire, no easy way to get down stairs.

(a) Princess Quay • Generally agreed to be better than St Stephens. • Can spend a long time in there – shops, places to eat. • Not cold. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 335

• Bigger range of shops. • Easy to get to, close to public transport. • Can meet people there, as it’s easy to find your way around and you can see around it more easily, whereas St Stephens is all one long row of shops.

General: • Would like an out of town centre like the Metro Centre in Gateshead. Easier to park. • Prospect Centre should be improved.

Section 2.04 Transport • Bus fares are too expensive. • Park and ride would be a good idea – can park for free and just pay for bus. • Housing • Too expensive to buy a house where you want to live. • Would like more big houses with gardens – generally agreed to be place where most of the group would eventually like to live. • Too many flats in Hull. Posh flats near the river not suitable to young people from Hull.

Section 2.05 Jobs • Would like well-paid jobs. • Worried about immigration and lack of jobs as a result. • 2 or 3 of the group wanted jobs in the construction industry. 1 wanted to work with children, 1 wanted a job in engineering, and 1 wanted to work in a computer game shop. (1 wanted to win the lottery so he didn’t have to work).

Group 2 – Btec NC Media Y1 students

GOOD BAD PLACE Nr Sutton Anlaby Park Road (West Hull) Antisocial behaviour

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 336

Poor range of services (all pubs and take aways etc) Old Bilton Grange Beverley Road Some nice houses Litter (need more bins) Derelict buildings Drunks Holderness Road/Newbridge Road Quiet streets off main roads Range of shops East Park Problem youths Woodford

Chants Avenue Hall Road Kingswood Entertainment and food Using ‘green belt’ [I think the person who Shops raised this meant ‘greenfield’/not Nice houses (new estate) previously developed land] to build houses on. Possible flooding problems for new houses.

Greenwood Avenue Walton Street Several people were from villages and Lots of older people. towns outside of Hull (Willerby, Thorgumbald, Withernsea, Beverley, Bridlington & Hornsea)

Section 2.06 General points • Hull gets a lot of bad press, eg being named in ‘Crap Towns’ and as one of worst places to live in UK, so this makes people ashamed – need to create pride in the city. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 337

Section 2.07 Healthy Living • Teenage pregnancy a problem all over Hull. • Drugs is a big problem – easy to get hold of, policing is a problem, drugs etc socially acceptable, can go into toilets of some clubs in Hull and there are people selling and taking drugs. Not something that can easily be sorted out, a cultural change is required. • Need more NHS dentists, people can’t afford private. • Long waiting lists for dentists and doctors and health centres. • Quality of care, especially in temporary/emergency centres. • Need cheaper gyms (Albert Avenue only £1, this is good). • Lots of people walk or take the bus – cycle paths and storage are important, and better lighting is needed on some routes. People generally thought parking in Hull was fine.

Section 2.08 Sport and Recreation • Need more parks and more pitches, astro-turfs etc. Need to be hardwearing. • Indoor centres for kids? • Community centres. • Separate areas for young children, teens etc within parks. • Publicity required to let people know about parks and leisure in their area. • Parks and outdoor areas should be near other attractions. • More small parks nearer where people live. • A lot of emphasis is put on making Hull attractive to tourists, but what about the people who are from Hull? • More adventure sports – paint-balling. • More bowling alleys. • Loss of facilities eg St Andrews, that’s why Kingswood is better.

Section 2.09 Community Safety • Problem youths are a problem. • Parks etc just get vandalised and destroyed. People are put off going. One person suggested that Hull do like they did in Castleford (on ‘Grand Designs/Big Town Plan’ that was on Channel 4 recently), and get local people involved in designing the

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 338

park, making the equipment and managing and maintaining the park so it doesn’t get wrecked – could give a sense of ownership BUT may cause territory issues, people think of it as ‘their’ park and won’t let others in. • CCTV not necessarily solution. • Need proper police not PCSOs and wardens, who are ineffective because they have no powers of arrest and everyone knows this, so don’t respect them. • Orchard Park was thought to be one of worst areas of city for crime. • Clusters of people – intimidating.

Section 2.10 Housing • Mix of housing types needed. • Help for new starters in getting homes. • Council houses – people have no respect for them – high turnover in some areas, people wreck the house, get evicted, new people are moved in, same happens again. • General consensus that shared ownership schemes [which were explained to the group by Jill and Emma] and houses sold below market value (affordable housing) were a good idea. • Derelict industrial areas good for housing (Chamberlain Road and docks, loads of sites). • Refurbish existing houses instead of building new. • Enough flats? Gardens, small.

Section 2.11 Employment • Need more part-time jobs so that college students can work and study – one person had been turned down for a job because they wanted her to work full time hours so she wouldn’t have been able to attend college. Important for parents also. • Employment in Hull mostly shop work. • BBC centre good, but media jobs mainly located out of Hull. • ‘Dead end’ • Hull Daily Mail offered some media opportunities, but limited. • BBC, newspapers etc want people with lots of experience, hard to get experience if no-one will employ you. Could set up local community TV/radio channels or similar to employ young people who wanted to work in the media and give them the experience to move onto other media jobs.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 339

Group 3 – Hair, Beauty & Catering course students Attendees:

Amy Nicholson - HU5 5QS Rachel Neal - HU5 5EL Emma McNamara - HU8 9RZ Paris Wilkinson - HU7 3DE Ellie Tadman - HU8 9DS Samii Thompson - HU10 6SR Charlotte Roberts - HU4 7BX Jessica Darcy - HU4 6HD Lindsay Francis - HU18 1HZ Emma Smith - HU8 9AT Becky Wilson - YO25 5PL

PLACE GOOD BAD West Hull KC Stadium, and pubs/bars in the Problem youths (inc Anlaby) surrounding area Run down Rough Crime and people drinking in the streets Immigrants

East Hull The new housing on the Preston Road estate Problem youths East Park Crime Woodford Leisure Centre “Pointless” features The new skate park The new park on Ings Road Good pubs Lots of buses Good shops

Longhill

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 340

North Hull North Point shopping centre is a good facility (In Bransholme and Orchard Park: ) (inc Orchard Park, The Kingswood leisure and retail Drinking, drugs Bransholme and Beverley development – lots to do Teenage pregnancy rate Road) The new housing on Kingswood Older housing in a poor state, particularly on Bransholme

Employment and Education • Job opportunities are limited – particularly for those looking to enter the beauty industry. A bigger range of jobs, with better salaries are needed in the city. • Immigrants take all the jobs there are, but maybe they are just taking the jobs that other people who are actually from Hull won’t do. • Lots of people are claiming benefits, but some people are just lazy! • “EMA” for all would encourage people to stay in education, at the moment only available to people from certain backgrounds. • Courses where you gain experience alongside teaching are a really good idea as lots of employers want people who have experience already. • Colleges should offer a bigger range of courses so that there are courses that suit everyone. • There need to be more college places so everyone who wants to go to college can do. • It’s great to study in the city centre. • The other expenses associated with studying need to be considered – eg. eating during the day

Healthy Living

• There are not enough hospitals in Hull – particularly with A&E departments. Hull Royal needs pulling down and we need lots of smaller, more local hospitals. • There are not enough NHS dentists. • There are plenty of doctors but the service isn’t good enough – surgeries should have more staff and operate/open longer hours.

Housing

• Perception that immigrants given priority. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 341

• Shared ownership schemes a good idea – everyone wants to buy their own house rather than renting... Hull needs more affordable homes. • Cheap houses are in horrible areas. If investment directed there then the areas would get a bigger range of people living there, not just problem youths. • Refurbishing existing housing is a better idea than just building new ones • Young people want small houses with their own small gardens, although flats would be second choice. • New housing required everywhere across Hull. • Building in your back garden (Infill development) isn’t a good idea most of the time, and the houses are always expensive. • Building on old factory sites, like Wincolmlee a good idea as long as they don’t just build trendy warehouse developments that are too expensive. New houses need a range of facilities close by – like a few pubs and a local shop.

Transport

• There’s always road works everywhere. • Buses need to be regular all through the day, not just loads between 8 and 9 in the mornings. More are needed on evenings and Sundays. • People like to walk, but are sometimes wary of doing so at night. • It should be free to park at hospitals. • Colleges and schools should have more car parks. • Parking is expensive during the week, it needs to be cheaper. • Bus fares are really expensive – if buses were cheaper and more reliable they’d get used more. • The Park and Ride at Priory Park is good. East Hull needs a Park and Ride though. • The roads are always busy going into town in a morning and on a night – seeing the buses going faster in the bus lane makes you think about taking the bus next time. • Idea of making some routes bus only, eg Holderness Road, is ok but you would need to make sure the bus services are really good and think about how it will make cars just go on other roads like Newbridge Road. • East Hull has good bus services but West Hull doesn’t. • Expensive transport can put people off working, it uses up all their wages. • Too many buses on the same roads, what about a grid of routes.

Community Safety

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 342

• Get rid of problem youths by building more community centres, so they have somewhere to go, more CCTV cameras, more “proper” police not Support Officers who don’t have enough powers. • Drugs are a problem on the street and in places like nightclubs, eg Welly. • Lots of people hang around on the street drinking. • People shoplift to feed habits. • Better lighting will reduce crime. • Open spaces where everyone can see what you are doing are better than alleyways and underpasses where you can hide. • Public toilets are horrible and people get raped in them, what about only opening them during the day and having more attendants? • The station is scary at night.

Flood Risk

• It’s a bad idea to build where we know it flooded last year. Kingswood is really bad because of the river, and its marshland. • Flood defences need to be improved, and sludge needs to be removed from the river banks. It’s better to try to stop it happening again than just keep spending more money cleaning up when it does.

Hull Core Strategy College Workshop 5 Hull College

1st October 2008, 11:00am-13:00pm Mike Dando and Christopher Hudson 1st Session – 11:00am – 12:00noon – Business Students - Attendees - 24

Where You Live – Good/Bad

Place The Good The Bad North Hull x4 Close to many different areas of Hull Roebank? Arcade empty Shops are fairly close by Travellers Asda (Kingswood Close) Gypsies moved next door Response to the Hull Core Strategy issues and options report, June 2008 October 2008 343

Housing is ok Crime x2 Easy bus access Football field got covered in trees Nearby bus stops Too close to Orchard Park Nightlife Too many unpleasant people Closeness to town Immigrants Student accommodation Anti-social behaviour The only house down the street (party!) No bus travel for one mile

West Hull x8 Rugby/good rugby team Poor housing Close to everywhere Not attractive Safe place x2 Not very nice sociable people/horrid Nice houses x2 people Hull Fair x2 Crime/assault x4 Close to Hull centre Thieves Good shops Not considered a nice place to live Shops nearby x3 Bad community Shops, excluding takeaways Not good community facilities Good bus networks Expensive transport Transport Drunk people from pubs at night Regular transport x2 Noisy trainlines Public transport Busy roads Schools ok Nothing for children Too many takeaways Low employment Young idiots Joyriders Poor schools Underage drinkers

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 344

East Hull x5 Good standard of living Hull KR x2 Good bus route Crime around the area All family live in East Hull Litter Good houses Decent living, ie shops Supermarkets Gym East Riding Entertainment Mainly druggies Seaside Crime Sea air Police x2 Family area Feuds Nice street where I live Lack of jobs No people – low population Tractors on road Nice market towns – Pocklington etc Lots of farm vehicles Close to York Close to Hull Good access to A1, M62 Lack of public transport x2 Countryside x3 Little public transport – once a day Nice housing but expensive Rubbish transport Few pubs Not a good bus service – very irregular Plenty of shops Travel Quiet (Preston) Buses too expensive Tidyish (Preston Kids getting drunk on streets Tidy Local shops closed for new houses Quiet x3 Shops Middle of nowhere x2 Flood affected houses No trouble or crime x2 Graffiti Stabbing recently Always fights in the pubs Drink & drug violence Theft Nowhere to get youths off the street Nothing around

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 345

Attractions Facilities Expensive Quiet Scruffy areas Old run down nightclub My neighbours No good pubs No pubs or entertainment Elderly Expensive housing Traffic No Government services other than bins

(a) Affordable Housing

• Move away from Hull? • Hull going downhill? • Many more houses should be affordable. • Houses should be cheap and affordable Response to the Hull Core Strategy issues and options report, June 2008 October 2008 346

• Why are particular demographics placed into certain areas? • Could houses be built upwards as opposed to outwards? • Why build new housing when old homes are being demolished? • Majority of people in group wanted 30% affordable housing. • There should be a mix of property types. • Issue over a claim that banks could reduce lending for as long as 15 years. • Would the provision of affordable housing actually benefit us? • The regeneration of old homes is taking too much time. • Where will people be relocated if they need to move from a property that is being demolished. • Don’t want extra housing • Why not attract businesses to Hull as opposed to adding extra homes? • What about using green spaces? • Why rebuild rough areas? Wouldn’t it be better to reduce crime first? • No one wants to buy property in Bransholme • Bransholme full of problem youths, crime. • Bransholme needs opportunities. • ½ houses going to foreigners. Why? • Only a few of participants aim to spend rest of life in Hull or the East Riding. • Why would 18,000 people move to Hull if there are no jobs and businesses are leaving Hull?

(b) Flooding

• Avoid flooding properties by not building on floodplains. • What about preventing flooding? • Build upwards to prevent flooding (but can families live high rise bearing in mind past experience).

(c) Community Safety

• Crime needs reducing • Measures to reduce crime could include CCTV and electronic monitoring • How should development look to avoid theft? Response to the Hull Core Strategy issues and options report, June 2008 October 2008 347

• Safety Issues – Darkness issue of safety. Lighting is an issue. • Stalking. • People safer being overlooked. • More police stations needed with proper police as opposed to PCSO’s. • Why have cop shops only open temporarily as opposed to full time? • Move trees to make CCTV clear. Put CCTV where it is visible. • Hull Smells Like Death!

2nd Session – 12:00noon – 13:00pm – Health and Social Care Students

Attendees:

Becky Hanson HU10 7HS Laura Bray HU5 4NH Paige Wood YO25 5XA Alex Gallagher HU3 2LA Josie Atkin HU5 4DP Amy Woods HU11 5BH Chloe Smith HU5 2EU Emma Clarkson HU8 0HJ Rebecca Chapman-Holt HU7 4DU Emily Hepple HU4 6JH Nicola Pettit HU4 7NZ Jasmine Musgrave HU6 7LY Rebecca Forward HU6 9JP Lauren Ricketts HU8 0JP

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 348

Where You Live – Good/Bad

Place The Good The Bad North Hull x2 Transport x2 Nothing to do Housing x2 Community safety Schools x2 Not enough shops East Hull Good shopping areas Bad housing Shops Housing Shops nearby Crime Good swimming pool Travelling – too busy x2 Housing x2 Chavs Schools x2 Park & greenery

West Hull x3 Near town centre Too many foreigners, druggies, alcoholics, New houses rude people Lots of housing Messy streets Near bus station, train & route to airport Not safe x2 Opposite hospital Nothing to do Shops around x2 Not much in way of open spaces Schools nearby x2 Housing can be expensive Recreation facilities Vandalism of centres & recreation places Didn’t really get flooded Not very healthy living Big open field behind the housing Bit boring – not much to do Parking Greenwood x2 Shops nearby Not enough greenery Park & greenery nearby Problem youths Multicultural Crime Good local pubs Needs more leisure Lots of schools Nothing to do Transport Not safe GPs

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 349

Food (takeaways) Anlaby x2 Different things to do Not many buses up to my house Feel quite safe Not much to do during the day, ie youth Places to go to & socialise, ie ice arena, clubs etc cinema, football stadium etc, however will have to get a bus Hospitals nearby

Driffield Small Nothing to do Quiet Hospital never open No public transport from villages

East Riding Low crime Lack of transport Quiet No recreational places Green In the middle of nowhere Safe Too far from town centre Local school

Community Safety

• Kosovans abusing women. • Lighting schemes in design • Introduce facilities for young people. • Increase police presence. • Police don’t do anything • Sonic alarms outside shops are not effective. • Design streetscapes to prevent crime. • More alleygating should be introduced. • But why should people pay for alleygating to be introduced as opposed to Hull Council? • Remove vegetation to prevent crime – but not all at the expense of quality of area.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 350

• Have clear pathways which are overlooked by other housing with clear lighting.

Healthy Living / Health Facilities

• Evenly spaced health facilities. • Accessible to all by locating health facilities on bus routes with regular bus services with bus stop outside facility. • Lot of people can’t get to doctors (due to lack of transport). • More dentists are needed. • Late night surgeries – longer opening hours needed. • More night buses to serve health facilities. • Less takeaways – too many in Hull. • Could takeaways be barred from serving pupils on school lunch breaks? • What alternatives to takeaways could be provided? • Majority of participants believe that takeaways should not be located near schools. • There are not enough nightclubs in Hull. • Intimidating drunks near pubs which should be restricted in residential areas. • Could too many pubs deter people moving to an area where those pubs reside? • Pubs would prevent street drinking. • Big differences between ‘local’ pubs and city centre pubs – city pubs a place to get drunk whereas a local type pub is more of a place for socialising. • More pubs should open in town centre and opening hours should be extended and encourage flexibility as opposed to having everything close at the same time. • Don’t have all nightlife amenities together. • Rivalry and hatred between West Hull and East Hull.

Sport and Recreation

• Nothing to do recreationally. • Some places have everything whereas some have nothing. Amenities should be evenly spread out. • What about putting sport facilities next to takeaways? Response to the Hull Core Strategy issues and options report, June 2008 October 2008 351

• Perhaps adapt PE at schools to include Gyms and maybe open sports facilities to wider local communities. • No proper football pitches. • Pitches not lit at nights. Floodlighting needed. • More grassed areas. • Astroturf pitches as opposed to grass. • No sport facilities other than basic pitches, eg: need for changing rooms. • If pitches lit it makes things safer. • Nothing sport wise other than football or rugby. • Nothing for school leavers. • Have places for gangs of youths to hang around, but not too formal eg: youth clubs perhaps as basic shelters? Somewhere to chill without people bugging them?

YOUNG PEOPLE FOCUS GROUP On THE FUTURE PLANNING OF HULL Station Hotel, 1st June 2007

SHOPPING/LEISURE/OPEN SPACE

SHOPPING • Higher security in shops • More independent clothes and music shops • Good coffee shops • More indoor places for activities and shops • Too many pound shops • Mixture of shops … cheap/expensive shops • More affordable shops • More shops for fat people • Layout of shopping areas is not spread out enough

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 352

• Healthier food shops • More restaurants • More shops outside of the city centre • Shops within the town centre should be closer together o Pedestrianisation o Better disabled access o Link up centre with facilities on the out-skirts

LEISURE/OPEN SPACE • Don’t feel safe (drugs) • More security at under 18 nights at clubs (youth rivalry) • More community wardens around the park • Safety x 2 • Bus prices have gone up • Better access to the park • Need for night buses • You have to walk to the ice arena • Tennis courts in the parks • Skiing facilities • Not enough leisure facilities • Clubs for older kids (teenagers) • Change the ages of places like Welly and Pozition • The youth service isn’t good. Should be more activities • More facilities for young people • Swimming facilities • Sculpture art can be used for practical reasons…like skating (example in Paris) Functional and pretty • Make Hull BETTER

• More parties in the parks in summer • More CCTV and more events in parks and open space • Bullies in open spaces – break down barriers between groups Response to the Hull Core Strategy issues and options report, June 2008 October 2008 353

• Graffiti – have walls set up for graffiti • More CCTV cameras and park keepers and security guards • Football pitch • More bins down streets • Make more parties in the park • Enough to do in Hull, e.g. Bumps. Not everyone wants to go to youth clubs • Leisure is ok, but it’s pricy • More youth clubs for young people. Use the facilities in the building better on the estates • Things to do, but they’re expensive (Breeze Card, Leeds [Free card for under-19s – get discounts on certain things]) • Youth clubs – more opening times • Too expensive • Not enough youth clubs and night clubs • No club in West Hull • Make an art day in West Park in the summer • Park with swings • Better swimming facilities • More security cameras, guards and park keepers • More access to parks • Discrimination and fighting in open spaces because of not enough security • Wardens • Buses going to where we want to go! • Youth clubs should be on Monday and Wednesday and Friday • Taking CCTV cameras • More litter bins – safety issue • Benches on fields and sides of road • There is a park behind my house • Cleaner parks – no dog shit • More security, safety in the streets, more children will play on them • When developmental projects, youths should be involved by using a youth voting policy • The Council should be responsible for creating activities in parks e.g. Grass Roots and Gay Pride • Higher security in Queens Gardens Response to the Hull Core Strategy issues and options report, June 2008 October 2008 354

• Something like Xstem • Later closing time of local parks, higher security

TRANSPORT & ACCESSIBILITY

Park & Ride - Discussion re Park and Ride – acknowledged that 1 at KC Stadium already but feeling that not well used. - Is there one a Hull KR? - Could there be one on each main road into Hull, all going in to St Stephens Development? - More parking in town…better location of park and ride

Cycling - Discussion re cycle lanes – need to be more distinct where on roads. - Better/safer to have cycle paths on pavements. - Need for one on Beverley Road. - Hull is so flat it lends itself to cycle lanes. - Cycle parking needs to be safe and secure, including at schools. - Cycle Lanes – Pavement o Widen roads – feel safe cycling - No cycle lanes, and it’s safer to ride on the pavement than the road. Would be safer if there were more cycle lanes.

Trains/trams etc - Discussion re idea of a Hull tram system. - Suggestion re monorail from station to KC stadium or train halt at KC. - There should be more train lines into/out of Hull Station. - Young people are not really train users - Need for Trams

Buses Response to the Hull Core Strategy issues and options report, June 2008 October 2008 355

- Need cheaper fares for young people and/or student/youth discounts - Cheaper bus fares on Sundays/Saturdays - Bus time-keeping is an issue – partly put down to traffic levels - Services should be more frequent - Problems with use include chavs & moshers, dirty vehicles, safety issues, sometimes grouchy drivers - Link up services, eg to get to ice arena - Better bus service o Buses that are more frequent o Better equipped for disabled people…lower for disabled access o Bus Lanes:- Further out to residential areas o Safety: - Bus conductors Seatbelts - Late night transport - More frequent buses on a night - Cheaper fares - Student discount and young people’s discount cards

- Buses: o Enough buses o Slow if lots of traffic o If more people use the bus – less traffic and Carbon Dioxide o Put prices on buses down, more people will use the bus so less traffic o Bus station has moved temporarily. Confusing – where to get the bus? o New bus station – better if indoors o Bus station and bus stops need clear information so you know where to get your bus o Not enough space for prams and wheelchairs. On double deckers, could have all seats upstairs, but only a few downstairs for elderly people, with more space free of seating for prams and wheelchairs.

Car etc Use - Car parking – city centre parking should be free/cheap on Sunday or 1st Saturday of each month. - Bridge toll is very expensive – prevents people coming to work/shop in Hull Response to the Hull Core Strategy issues and options report, June 2008 October 2008 356

- Suggestion re motorbike lanes on roads. - Need for emergency vehicle lanes? - Lorries delivering to shops in city centre drive on pavement – dangerous: o Have different delivery times when people aren’t in the city centre - Too many car parks – people should use public transport

Taxis: o Rank right in the middle of Hull o Expensive o Can be dangerous at night o Very busy on a night – need more places in town to get taxi from o Late night bus is cheaper than taxi, but dangerous

Issues at particular locations: • Marina/The Deep: 1. Maybe need more police 2. Car park and buses to get there • KC Stadium: 1. Easy to walk to 2. Hard to find the r9ight entrance • Ice arena: 1. Difficult to get to 2. Lots of traffic 3. Concerns about safety walking to the ice arena – people drinking on paths, prostitutes 4. Need more police in this area, and on the way from town to the ice arena – none at the moment

HOUSING & JOBS

JOBS

- No job opportunities in Hull - Hard for young people to get jobs – firms want experience – you’re either too old/young or over/under qualified Response to the Hull Core Strategy issues and options report, June 2008 October 2008 357

- Need jobs which give young people leaving school a 1st meaningful experience of employment - Comment re ‘age discrimination’, eg in HMV, pubs because of products being sold – but could train people in other skills within those firms first till old enough - Middling types of jobs available - Some young people who wanted, for eg, midwife, social work, language type jobs said they were likely to move – need more jobs for people with qualifications to stop them leaving Hull. Others thought that those jobs would be available in Hull when they wanted them - People who want service type jobs (eg hairdressing) said they were likely to stay - One person indicated desire to work in but live outside Hull - Wages low in Hull – many minimum wage jobs. Eg of Top Shop Manager earning £16K/year - Lot of low paid, labouring, sales rep, bar etc jobs available - Need training opportunities – eg training on basic work skills such as working with people, till operation - Need for somewhere to start own business – premises to rent, starter units. Starter business premises probably not available at right price - Need jobs not just in the city centre - Comment re telecom monopoly in Hull – KC Comm – difficult for other firms to break in. - No choice of jobs within sectors – no competition. Hard for independent retailers to establish in market where bigger competitors - Need to treat employees well - Comment that only a limited range of car parts are available in Hull

HOUSING

• New settlements should encourage a mix of people living together…avoid similar types of people living together. o Affordable housing…mix of tenure o More ‘to let’ housing • New housing development should… o Be located near existing schools/jobs o Leisure facilities integrated o Shopping – corner shops/meeting places (cafes/community centres) Response to the Hull Core Strategy issues and options report, June 2008 October 2008 358

o Be built near existing transport networks…quick and easy • There is enough housing…improve existing neglected housing stock • Knock the old houses that can not be habited down and replace with modern alternative • Encourage city centre living o Affordable places…encourage young people to move in • Housing market out of financial range of young people

• House prices increasing – increase wages, attract investment to Hull • Affordable housing: o Terraces are already more affordable o Cheap housing – horrible? Would have to do a lot of work on them • Invest in improving housing stock • Housing – quiet, villages. • Variety of housing styles, not like a ‘toy town’ • Mix houses, don’t separate housing because it causes stereotypes of people in different housing types • About 50:50 affordable and non-affordable housing. • Affordable housing should be for everyone, not just young or old people. • Houses with big gardens • Facilities needed to create a community: o Housing near transport network o Shops o Leisure o Jobs – stop commuting

• More affordable housing

SAFETY & SECURITY

In open spaces

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 359

Problems Solutions

Pollution of nature reserves, eg chavs leaving Put litter bins around Vodka bottles around)

Noise pollution Move factories away

Gangs & intimidation Give them somewhere to go

Graffiti Provide a designated graffiti wall

Arson/fires More Police to supervise

Dog mess More bins

Danger of being attacked More wardens

Intimidation of big groups/gangs Stop gangs/keep the peace

In retail areas

Problems Solutions

Secluded places Encourage far more visibility

Gangs hanging around front of shops and CCTV outside & more youth Scaring people facilities

Vandalism Shutters on windows/doors

Shoplifters More security guards

Littering More bins Response to the Hull Core Strategy issues and options report, June 2008 October 2008 360

Cash point robbery/fraud Chip & pin; safer areas for placing Cash points

Shops not young people-friendly Make them accessible

In housing estates

Litter More bins & CCTV

Fighting & shouting More Police & CCTV

Pollution Put residential areas away from Pollution

Nursing homes prone to crime Integration

Burglaries House alarms

Vandalism to people’s property CCTV & security guards

Bad reputation Reduce social stigma; mix classes, Integration

Squatters in empty houses Repair empty houses and ensure Residents are available to move in

In relation to public transport

Vandalism at bus station More security – CCTV

Children near busy roads More lollipop ladies & crossings

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 361

Problems at bus stations with druggies Better security

Buses – smoking upstairs & litter Security & supervision upstairs

Lacks of respect from children More educational values towards facilities

Bus station dark More lighting

Graffiti on bus seats CCTV & bus monitors/guards

Yobs intimidating people at bus stops More public patrols

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 362

REPORT FROM HULL CORE STRATEGY CONSULTATION WITH 15 MEMBERS OF HULL YOUTH FORUM

SATURDAY 20TH SEPTEMBER 2008

Summary of key issues

Although some differences of opinion in each of the groups, there was general consensus on the following issues:- • There needs to be a much higher level of affordable housing provision throughout the city; • Housing developments should be lower density, and incorporate more safe open spaces, e.g. homezones; • Safety issues at parks and open spaces:- these need improved maintenance and supervision, and there need to be more organised activities; Response to the Hull Core Strategy issues and options report, June 2008 October 2008 363

• Cycle routes need better signage and maintenance, and improved security for bicycle storage; • Independent shops in the city should be supported.

Group Reports

Early teens groups

Group 1 (Mixed):-

Green/Open Space • Find the space in their area, East Hull (Andrew Marvell School) peaceful, but don’t frequently use the local amenities – Barham Park/Ings Park/playing fields: “There are enough parks but not enough things to do.”

• The facilities of Barham Park in particular are considered to be poor; toilets appear to be always closed, park attendants have no presence – “Seem to stay in their building all the time,” and although there are swings and a bowling park, there are not enough facilities for youths of their age.

• The sense of safety is an issue. Although there are security cameras towards the entrance of Barham Park this has only moved the problem of antisocial behaviour elsewhere; other areas of the park are less well supervised and can feel intimidating due to congregations of large groups of older youths.

• A park attendant or cafe (to overlook the park area) would provide a greater sense of security and perhaps encourage greater usage.

• There are not enough bins in any of the parks or local streets which lead to litter problems in green/open spaces.

• Street/park benches are a good idea but are not well enough maintained and suffer from graffiti and vandalism.

• Grayfields Recreation Ground in particular is considered to be poorly maintained and prone to arson attacks and vandalism, which detracts younger people from using it.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 364

• Ings Park provides more interesting facilities, primarily being a skate park and summer events (rock concert) and is considered to be in a good location.

Youth Facilities/Sports

• The group would like to see a greater provision of outdoor sport facilities; there are too many football and rugby pitches and apart from the skate park, very little for those not interested in these sports: “It always attracts the same crowds.”

• Suggestions for other sport facilities are basketball courts, wrestling/martial arts [classes], adventure playgrounds for younger children, running tracks or more specifically athletic clubs or gyms that don’t just cater for older teenagers to capitalise on the interest generated by the Olympics.

• Whilst there are local swimming pools, they are, “boring” and so are not frequently used.

• Local afterschool clubs could also better cater for youth sport clubs. As it stands they only attract people from the local neighbourhood, as those that use the school bus are unable to stay after school hours due to the cost of transport. Suggestions include running additional after hour school buses and providing a greater variety of sport clubs.

Transport

• Young people would prefer to cycle to school and Hull city centre, but are deterred from doing so because of poor cycle storage. Although it is thought that a greater provision of cycle storage in town would only lead to more vandalism and theft (also an issue). What is needed is better security too – cameras or street wardens.

• The local cycle routes or bike tracks away from the centre and towards Horsley are good with tree cover providing a sense of security from traffic, but difficult to locate without local knowledge due to poor signposting.

• The bus is too expensive for young people, which prevents many from using it: “Under -16s should be free.”

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 365

Group 2 (Mixed):-

Regeneration issues

• Development should be spread throughout the City; support for new business start ups should be part of new developments.

• The older parts of the City should be made more attractive – don’t change their appearance, renovate them. Encourage individual shops in older areas, e.g. Whitefriargate.

Housing

• There are too many people in hostels, there needs to be a ‘next step’ on from there where people can have privacy. • There is a need for more affordable housing in nice environments - the consensus was that the percentage of affordable housing should be considerably higher than the Core Strategy proposes. • The group supported mixed tenure housing developments • Design issues: • New developments should be ‘safe’ developments. • Wardens are needed to patrol housing estates to prevent people drinking & taking drugs. • Family houses need bigger bedrooms – room sizes and storage facilities in new houses are inadequate. • Housing developments need to be less dense. • Support for Homezones – one of the young people lived on Preston Road which she felt worked well. • Main roads should not split a housing development in half. • More play areas are needed around housing developments

Late teen’s groups:

Group 1 (Boys):-

Green Space/Open Space • When asked about their views of green and open space in their neighbourhood Pearsons Park was considered to be the best area of green space in Wyke, offering a playground, pond and green house that are well used, especially in “sunny weather”. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 366

• In general Wyke has enough green and open space and does not require more parks, the priority instead should be to maintain what is there: “Make sure it stays there and is well preserved.”

• Instead, other areas of Hull, specifically being the estates on the outskirts, have a poor provision of green space which needs addressing. Orchard Park and Great Field in particular were mentioned as places in need of regeneration, too far away from the city centre and with nothing to do there, meaning people will not want to go there.

• When asked about how green and open space in Wyke could be improved, an outdoor swimming pool or paddling pool was suggested because the pond at Pearsons Park is too dirty for paddling, and it was agreed that this would be good for the summer, although there were concerns as to how well it would be used in colder weather.

• Further to this idea there were suggestions for creating a “beach area” to accompany a paddling pool or swimming pool, or possibly a “beach play park” for younger children, as a summer facility.

• Mentioned in connection to swimming pools was the need for an Olympic sized indoor pool in Hull.

Healthy Living

• The main issue of healthy living is cost: “There is nothing to do with no money,” “no healthy living facilities for young people.” Gyms etc. are too expensive to be used, and it is felt that there needs to be better access to healthy living facilities (like gyms and pools) for young people. It was suggested that this could be addressed with ‘youth membership’ schemes of discounted prices or more youth facilities, like an ‘Outdoor fitness centre’.

• When asked about their views on takeaways, the problem of cost was raised again. ‘Healthy foods’ are considered to be the most expensive, smoothy bars for instance will charge £3 for a drink, which is too much. Instead, schools should be responsible for providing healthy foods and such facilities as smoothy bars for the young, to make it affordable.

• Also mentioned was the lack of provision of clubs/bars for 16-18 year olds, as this age group don’t want to go to ‘teenager’ nights/events but are too young to attend 18+ events.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 367

Transport

• When asked about how they travelled in Hull in connection to healthy living, most either used the bus for journeys into the city centre or walked as Wyke is considered to be in a good location.

• The bus fare and passes are viewed as a good deal (£.120 to town), however there is a need for a student fare to cater for the 16+ age group that, “Have no money.”

• Most would prefer to cycle as an alternative but are deterred from doing so because of the volume of road traffic that makes cycling too dangerous. There is also a problem of on street car parking blocking existing cycle path routes with Spring Bank cited as the worst example of this. More cycle ways by the pavement and cycling confidence classes would encourage them to cycle.

New Development

• When asked for their view of new developments in the city there was a strong concern over the loss of independent shops in the city centre which is regarded as ruining the diversity, and subsequently, the appeal of Hull as a shopping destination. The ‘Prospect Centre’ was identified in particular as an example of this, containing “generic” shops that can be found in every city and town which will not attract people to Hull. There was also concern that the new Tesco development would lead to the closure of the local farmers market and art and crafts centre, again impacting upon the diversity of Hull’s shopping.

• Similarly, it was thought that there were too many cinemas in the centre of Hull (4 cinemas in the centre and only 1 elsewhere - Kingswood) at the expense of independent shops, which will only lead to the closure of 1 or more cinemas.

• The group were not in favour of new developments in general, considering the design of new buildings in the centre and marina area to be, “unattractive,” “too fancy” and “a waste of money.” Instead it was felt that development should be focused upon renovating empty buildings.

• The museum and library were considered to have more character and make better landmarks than the new developments.

• All were disappointed that young people did not have a say in the design of new developments in the city centre.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 368

Group 2 (Girls):-

Open Space/Healthy Living issues • In general the young people felt there was a poor environment on many housing estates, unsafe alleyways etc.

• One park – East Park – was cited as a good quality open space, but was too far away for all to use. Ings Park is a poor facility. A good facility would have a pool, football pitch, and activity areas for a range of ages.

• Cycle routes are a good idea if they are in good condition – e.g. the one to Hornsea.

Shopping

• Poor range of shops in Ings Centre was highlighted – mainly take-aways, no clothes shops, fresh food shops. The proposals in the Core Strategy to develop Ings Centre were supported.

Design/Greenspace

• In general there was a feeling that the public realm in Hull is dull – at a basic level better lighting is needed, but also more art work and colour. One suggestion was for a wall in Queen Victoria square which depicts the history of Hull in graffiti!

• There was criticism of the constant flow of news from the big tv screen, more variety of programme needed.

Housing

• Support for mixed tenure/size of housing developments, which should be near schools.

• Support again for much higher levels of affordable housing – suggestion that it should be nearer 75%.

• Suggestion that for every 20 houses there should be a park, which is constantly maintained.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 369

APPENDIX I

YOUNG PEOPLE’S SUMMARY ASSESSMENT OF THEIR LOCAL AREAS

Where do you live Good points Bad points

Favel Place (x2) Yet to be discovered Not many places for young people to go that are fun Corgan Street Near town Lots of drunk people running round

Marfleet Lane Lots of parks & fields to chill on Idiots on street

Wingfield Road Close to school No places to go Macauly Road Too many gambling shops Tescos development on Newland makes rents for local shops more expensive

Newland Avenue Good shopping Not much for young people to do Pubs & open space Marlborough Avenue Local shops, bars & an excellent park Badly lit Discrimination against youths from police

Waverley Road (x3) It’s near town Gangs Some good people in the area Damage of people,cars & houses Rubbish

Beverley Road Swimming baths Lack of lighting Shops Poor road safety Pearson Park Police station Response to the Hull Core Strategy issues and options report, June 2008 October 2008 370

APPENDIX II

WORKSHOP ATTENDEES

NAME POSTCODE Vanessa HU8 9NA Jamie HU8 9NA Rosie HU5 3JX Ellie HU5 2BY Natasha HU5 1DA Samantha HU9 4QF Jessiikah HU9 4RJ Saliha HU1 2ST Fauzia HU3 2NE Zakkiyya HU3 2NE Elen Crimlis HU8 9JN Rebecca Batty HU8 9JJ Ben Rymer HU9 9XW Andrew Martin HU8 9BB Robert May HU8 9SU

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 371

Detailed feedback from elderly people

Hull Core Strategy

Age Concern Seminar – Workshop 1

25th September 2008

Facilitator: Mike Dando

Attendees: 7

Derringham Bank (West Hull) x2 Great Field (East Hull) x1 Mizzen Road Estate (North Hull) x1 Sutton Park (NE Hull) x3

Situation now In Hull where they live - Good/Bad

PLACE GOOD BAD Derringham Bank • A quiet area x2 • Drugs x2 • Policing has been good this last year • No shops – have got rid of the gangs • No good for shopping – a lot of the • Don’t have to bother the warden – shops have closed he comes to us • Burglaries • House needs upgrading • Motorbike noise • Too much dog mess on the field • Pavements are in bad repair x2 • Roads are atrocious • Gangs Response to the Hull Core Strategy issues and options report, June 2008 October 2008 372

Great Field • Bus service • Litter • Refuse collections • Shopping • Warden • Crime • Post • Neighbours

Mizen Road Estate • The environment • Transport not very good at times • Shops • Roads get too busy at peak times • Not too much crime • No Park & Ride • Health

Sutton Park • Neighbours x2 • Traffic noise • Shops x2 • Litter • Green areas • Crime • Housing mix • Standard of education • Cycle paths • Employment opportunities • Transport x2 • Not enough houses for disabled • Health facilities x2 • Paths not cleaned enough • Nice area • Trip hazards • No trouble with children or • Refuse collection – bins not put teenagers back; have to go looking for them • Not enough things for children to do • Elderly not catered for • Ten foot to Sutton Road • 5 public houses • Bingo Hall • Dogs/people after midnight • Been asking for clean-up/ weeding etc since last year

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 373

Topics

Housing

• Lifetime Homes – all agreed important because of increasingly ageing population. High standards as important as size specification. • The need to apply Lifetime Homes criteria to existing properties undergoing refurbishment was also raised. • Some support for sustainable homes – would make it easier/cheaper for the elderly to heat. Some support also for solar panels. • Different sized bungalows needed for the elderly, ie choice not just a one size fits all approach. • Kids play areas on the back of new development – they are needed and MUST then be built when promised (ie s106s).

Health/Healthy Living

• Support for 3 new ‘poly-clinics’ in the 3 existing district centres (or maybe Kingswood rather than North Point). • Agreement that there should be no parking charges at these facilities or hospital. Need to link all to new Park & Rides.

Transport

• Support for all 4 proposed Park & Rides. Location is however important – eg N Hull/Kingswood P&R needs to be located in the fields to the N (ie in East Riding) not in Kingswood. This is too far in and will cause bottlenecks. • P& R infrastructure important – York model needs to be followed. • Community transport particularly important for the elderly – more buses, better network, better funding. Services shouldn’t stop at administrative boundaries.

Community Safety

• Full support for Secured by Design principles

Flood Risk

• Agreement with all plan says. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 374

• Important that Environment Agency advice is heeded.

Hull Development Framework Core Strategy – Workshop 2 Age Concern Seminar, Hull, 25th Sept

Group session – What is good / bad about your area? There were 6 participants in this group, who came from the areas of Hull as shown in the table below.

Place The Good The Bad East Neighbours Kids playing in streets (worried will get Environment knocked down) Good area to live in West KC stadium Council Tax Lots of community events High rents Neighbours Kids hanging round shops

North Carr Nice area Politicians Good transport links Largest green belt area Wyke Good shopping area Drunkenness rife Friendly people Lots of alcohol on sale Anti social behaviour

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 375

Discussion.

The group chose to prioritise Housing, Transport and Floods, however during the discussion other topics were also covered.

Section 2.12 Housing • Kingswood – build, but with vision, adaptable housing – flood proof! • Need vision on new build – should be accessible to all. Should be housing that can be adapted in the future. • Adaptations should be available as a matter of right, free of charge. • No rebuilding in the city, it is all conversions e.g. post office rebuilt as flats. • Newington needs redeveloping – there are social issues with kids damaging properties etc. • Already doing some work in Newington, this needs speeding up. • Council houses needed for rent – City council should have the right to build homes. • Re. Building on East Riding (edge of City). Has expanded 5 times since WW2. There is no more land to build on, where would 24,000 houses go, plus facilities e.g. schools, doctors, industry / jobs. • Not everyone can afford to buy, stamp duty, solicitors fees etc. add to issues. • Ghettos in some areas e.g. Springbank, comment made was ‘feels like Beirut’. • No more housing on river corridor.

Section 2.13 Transport • The Council has no Vision! • Whole of City is Grid locked. • Castle Street should have been a tunnel section in first place. Will cost millions of pounds to address. • Free passes are currently only off peak. For example, this makes it difficult to get to early hospital appointments. It is expensive on buses; it should be free at all times. • Bus companies don’t make best use of roads / times. • Better co-ordination is needed between transport companies • More circular routes are needed. • Need smaller, cleaner buses to prevent congestion and to help the environment. • Flexibility needed re. Transport – trams needed, running on overhead cables. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 376

• Tram system looked at before, but shelved on costs. • Abercrombie Plan should have been utilised and would have shown that the council was looking to the future – Believe it is still registered in the Guildhall. • Already subsidising transport (nb not sure if meant taxpayers or Council). • Transport should be cheaper and cleaner. • Realise that market forces dictate. • Buses were cheap when Council owned. • Humber Bridge needs to be free to develop the City. • Park & ride not well used in week – used mainly for football traffic. There is no safety for vehicles at some car parks. Network of CCTV cameras required. • Need more cycle paths – it is dangerous on the roads. Why was the vision of these stopped? It is now a £30 fine for riding on the pavement in Newlands Avenue – why just here? • More use should be made of the water for transport e.g. water barge, as is cheap. • Rail services should be in people’s hands not shareholders. The cost must come down.

Flooding

• The Victorians knew what to do – kept green spaces clear to absorb water and built dykes interlacing the city to drain water. • Floods caused by Yorkshire Water filling in the open dykes and drains that used to be across the area several years ago. • If restored the dykes/drains, would not have flooding, e.g. Kingswood would not have flooded. • Should not have built houses on wetlands e.g. Orchard Park, Brandsholme, Kingswood. • Short sightedness re. past practices by Council on development • Should be a law on dimensions of drainpipes used (should be bigger). • Councils don’t talk to each other. • Should be less paved areas and more use of porous surfaces. • Drains not cleaned out regularly, used to be round all time. • Hull is flattest area in Yorkshire. • Holland doesn’t flood – Have vision! Dykes! • To drop the flood barrier, they have to get a ‘specialist’ to come over from Leeds!

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 377

Other:

• Community Safety – The Community Warden scheme should be expanded. Having more of them will solve a lot of the community safety issues; CPSOs do not communicate with the wardens; in some areas the wardens are better than the police as they come to you to see if you are ok.

• Health – no health centre in West Hull. The nearest facility is the hospital.

• Shopping – Longhill Estate has no major shopping facilities; There should be a regular market down the middle of Whitefriargate, as it would bring in more people.

• Global Warming – Better waste management needed; Global warming has happened for thousands of years – it is cyclical.

Hull Core Strategy – Workshop 3 Age Concern Building

25th September 2008, Eric Stowe

Age Concern Members

Attendees: 7

West Hull - 2 people - HU4 6PR East Hull - 3 people - HU9 2PT HU9 3JY HU9 3PY North Hull - 2 people - HU6 8TN HU6 7BB

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 378

Situation now In Hull where they live - Good/Bad

POST CODE GOOD BAD HU4 6PR • Transport • Dirty streets • Shops • Parties • Safe • Loud music HU9 2PT • Housing and Housing Association • School and uncontrolled pupils • Safe areas • Poor pavements • Street lights • Litter streets • Near shops • Poor for disabled people • Near services e.g. GP • No local post office HU9 3JY • Housing type and choice • Police coverage • Transport connections • Access to NHS services, Dentists, • Security Opticians etc HU9 3PY • Housing • No Church • Community services • Not enough Green Space • Recycling • Crime - drugs • Shops • No litter bins • No dog waste bins HU6 8TN • Health facilities • Travel everywhere therefore • Training and volunteering expensive opportunities • Flood risk • Community profile • Poor shopping • Community wardens • Nothing for children and older • Good housing people • Friendly community • High unemployment • Lots of community centres but not in • One parent families our area • No industry • Drugs/alcohol • Low expectations

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 379

HU6 7BB • Housing Pavements all over, very poor • Shops • Transport • Schools • Open spaces • Lighting • Policing

• Topics - Housing

Good Bad • Like to see it in Inner City, but with more choice • No more like Kingswood • Like it to be more in keeping with Preston Road which was • Not in Hessle felt that was good • Not in flood risk areas • Rebuild existing estates but with more housing choice • Do not use or lose Green space • Not like Bransholme Estate - with no facilities and therefore more cars, more expense

General comments on housing

• Too many empty properties so why not do something with them? • Rented from private landlords are causing no pride, drugs, crime and no respect or pride in housing or areas • There is a poor mix of housing now with too many executive type flats being built and a lot are still empty • We need right choice in each area e.g. Housing Associations, Town houses, flats, lifetime homes, affordable homes. • We do not want high rise blocks, nothing above height of town houses i.e. 3/4 floors • No private landlords unless with good quality housing

Environment Response to the Hull Core Strategy issues and options report, June 2008 October 2008 380

Bad points only discussed as follows:

• Town centre not considered safe at night • Community policing not working • No presence on streets of police or wardens etc • The centre is swamped with police at weekends and the outer areas are left uncovered • Very poor street lighting all over • Cottingham looking to actually turn off lights at some point in the night to save money

Healthy Living

This was just considered very briefly, but generally all were quite happy with availability and choice of health centres and opportunities for leisure The green space had to be maintained to allow this Congestion was not bad where they lived

Finally, some general concluding thoughts that the group felt were really important:

1. Transport was considered to be really good, apart from one major problem - The direct bus to Hull Royal infirmary had been stopped and bad for elderly/disabled as you had to change at the Interchange.

2. Flood management risk must be done for the whole area and published and no more homes must be built at risk

3. Contacting Council - the Call Centre is causing problems and people are not getting replies from departments that are receiving the information from the centre or if they provide the information it is not accurate or detailed enough as when talking to a person in the relevant department. This is causing frustration and annoyance to the public and therefore not happy with services from the Council - therefore no trust

And East Riding

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 381

All felt that a large part of any problems is due to the conflicts between the Hull Authority and East Riding. There are double standards, not enough working together, conflict between neighbours on the same streets and services are run between the two, but not always to the benefit of the people that they should be providing the services for. This must be resolved before any new strategies are considered

Hull Development Framework Core Strategy Workshop Hull Age Concern. Thursday 25th September. Workshop 4

Attendees. 6 members of age Concern. Alan Mitchell, Planning Aid Volunteer.

Introductions and where people are from.

Place The Good The Bad Pickering – Ferens Quiet Flood risk HU93EA Clean Transport [isolated] Good property Health – Access to hospitals Pickering – Ferens Good shopping centre Council housing HU4 Housing [other than Council] Flood risk Health Pickering – Ferens Good housing Flood risk HU93LG Quiet Transport Health facilities and access to hospitals

Newington Well modernised houses Too much junk mail HU36ET Good shopping Good medical facilities

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 382

Good transport

Pickering – Ferens Plenty of green around us Everything good HU114DF Lovely neighbours Good landlords Pickering – Ferens Good neighbours Transport HU54BW Excellent housing Pavements Shopping

Discussion and Conclusions.

Housing.

• Bransholme needs employment. • New housing should be provided on employment land east and west of the city centre and employment relocated or otherwise provided in the north of the city especially Bransholme. [NB. Consider latter point as part of “Jobs and Prosperity” chapter.] • As regards mixing age groups in housing areas, 5 preferred separate developments according to age group and 1 preferred mixed areas. • All thought there should be more 1-person dwellings and more housing for 1st time buyers. • There was strong support for “lifetime homes”. • More than 20% of new housing should be affordable. • Houses should be built to “sustainable standards” to reduce impact on climate change and to ensure low running costs. • All thought that Housing Associations are very good landlords.

Housing Strategy

• There is a waiting list 14000 for “social housing”.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 383

• Building rates should be high in the early years especially for social and affordable housing in view of the need and long waiting list. • Good quality housing for professionals is needed to help keep families in the City. • More shared use of buildings and facilities would be beneficial.

Health.

• The PCT health centres in the neighbourhoods should offer specialised services and appointments with consultants that are currently held at the hospitals. • The Castle Hill hospital is an excellent facility but access from other parts of the city [especially east Hull] is difficult. The Home to Hospital bus service is helpful but journey times are too long. • Access to open spaces is important. • Support for facilities for more walking and cycling. • Safety and security is especially important for older people. • There is support for limiting planning permissions for “fast food” businesses especially near schools. • There is also support for limiting bars etc in particular areas. • Efforts should be made to keep families in the city. • Locating facilities such as health, shopping etc together was thought to be a good idea. • The use of empty shops for health facilities was suggested. • Disadvantaged communities should be targeted. • Cleanliness in hospitals and the general environment are important.

Flood Risk.

• Greenspaces should be designed to act as holding ponds. • Design standards should be adopted to minimise the impact of any future flooding. • There should liaison with the East Riding over preventative measures that could be taken outside of the Hull boundary. • The “drains” in Hull should not have been filled in. • Too much water is wasted.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 384

Community Safety

• “Secured by design” is supported. • Footpaths can be dangerous at night; good visibility and lighting on paths and open spaces are very important. • There is danger to pedestrians from too much cycling on footpaths. • Cycle ways should be included in new development. • Greater police presence is important.

Detailed feedback from disabled people

NOTES FROM HULL DEVELOPMENT FRAMEWORK WORKSHOP Held as part of Planning Training for Hull Disability Groups – Development Plans Thursday 28th June, 2007 at The Guildhall, Hull

Accessible Housing That is housing specifically designed for disabled people, which is wanted in the City

Is there a location-based need for accessible housing? i.e. location of such housing relative to infrastructure. Can this be evidenced via social services, housing or census records?

Variable geography of city in terms of land levels (i.e. height above seal level) is an issue for accessible housing. There are limited places where you can physically build accessible housing because of need to build up base for flooding reasons. Concentration in such areas however would serve to ‘ghettoise’ people with disabilities. The group therefore wanted accessible housing in all locations in the City, but with the logic that within all developments accessible housing would be located near to infrastructure eg shops, service and transport but integrated.

In the interests of inclusiveness accessible housing should not be limited by geography/infrastructure could add to locations in developments. Need for bungalows all over not just on outskirts of city.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 385

Lifetime Housing

A standard, adopted for all new housing in City of London, which are designed in such a way that people can stay in the house for a long time, with adaptations being cheaper than the non-lifetime designed home. Relevant because of sustainability and because of the amount council does spend on adaptations to the existing housing stock.

These homes are not specialist needs, for eg wheelchair users, but do allow for possible future stair lifts and even future through the floor lifts. Should planning policy extend to embrace such extra needs?

Press for a specified % of new homes to be of lifetime homes standard, the group recommended that this should be as near to 100% of housing as it was possible to achieve whether it be new construction or conversion.

Wheelchair accessible homes a smaller % (20%?) within the total. Only a small extra cost ((£1-£2K per house) to achieve this extra accessibility.

Concept of visitability? This was what the current Building Regulations are based on at the moment. The design should enable disabled people to visit all new homes – though unfortunately this is not the case and alterations to this standard can still be expensive.

Design & Access Statements

Should there be a policy requirement re standards and coverage?

Design

How buildings work needs to be thought about at same time as how they look – minimum standards will not give you an accessible design. Eg needs to be applied to redevelopment in Fruit Market area – input to SPD.

Listed Buildings – protected by national legislation, but things can be done within that context – good egs of disabled access exist.

Need to find creative design solutions that provide necessary access without, for eg, offending ‘back of pavement’ design requirements in certain areas.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 386

PPS25 requires flood risk assessment to be submitted with planning applications. This is something developers cannot avoid. Risk of flooding and design measures to mitigate risks have clear implications for accessibility. There is a need to fully understand the flood risk before beginning a design otherwise you get poor afterthought access or visually poor none integrated design

Street furniture/the public realm

Need ‘guides’ for the blind/partially sighted to prevent walking off pedestrian areas into parking bays.

So-called courtesy crossings can be dangerous to the blind/partially sighted – too much onus on drivers being expected to stop.

Colours of street furniture are important for blind/partially sighted – ‘wrong’ colours can render furniture effectively invisible.

Lighting – floor lighting can be confusing, eg on steps. Proper lighting increases the confidence and security of people with disabilities.

Importance of materials and layout in the public realm and within buildings cited – eg use of stainless steel is bad, difficult for visually impaired people to pick up, glint causes some people with limited vision total blindness increased use of glass for walls can be difficult to find doors, steps is a safety issue, type and style of seating, paving materials, not use low planters or trip hazards Play area design, including materials, is an issue both for young disabled of all ages (toddlers up to adventure play) and for disabled parents/grandparents watching/supervising children.

Transport Infrastructure

For some disabled people public transport is not an option, the private car is the only means of getting about for a lot of disabled people. Need for policy on disabled car parking provision. Eg disabled parking spaces in all the destinations of the City and major retail outlets – spaces need to be sensibly located in relation to store access points and city destination desire points, not where they are less convenient than regular spaces (nb as is case in one Tesco store mentioned!).

City centre parking ‘spots’ for blue badge holders need to be in the right places for users and to be reviewed so they don’t become redundant, eg when stores change hands/change access points into stores. Increasing pedestrianisation and reduction in city centre parking makes this ever more important. Blue badge only areas

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 387

Narrow pavements and drop kerbs lead to drops with too steep gradients to be easily negotiated.

Access Policy

Access Policies in Hambleton LDF Core Strategy and Policies LDD cited as too similar and vague.

Possibly look to Sheffield for good practice – Access Officer here is ‘hot’! (They do let him be involved in the decisions – George)

Press for an Access SPD in next review of LDS – to expand on/add detail to a Core Strategy ‘headline’ policy and supporting policies in City Policies LDD.

Access to countryside areas is an issue for Hull’s disability community.

Access to open space generally ditto – can this be addressed via Public Realm SPD?

Consultation with Disability Interests

Need for a requirement for developers to consult with Access Group/disability community on major planning applications (nb this is already in SCI – yes?). The bigger an application, the more consultation as a guideline?

Early consultation is better than prescriptive/’of its time’ (& therefore often quickly dated) design guidance, ie in SPG/D form.

DDA Duty vs Planning Requirements

Test of what is reasonable central to workings of DDA.

Disability Equality Duty/Scheme

Statutory duty. Positive discrimination towards people with a disability re public service functions, including planning. Under new legislation councils have a duty to promote disability, involve disabled people when they show an interest in being involved. Should be applied to movement around the city.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 388

Access Unit

Need to move from Access Officer to Access Unit!

Toilets

There is a need for public toilets, of all types, in the City. Should not be closing them down. Disabled people eg incontinent, insulin injectors, people with limited walking, wheelchair users, visually impaired etc do not want to be going into stores, shopping centres or pubs just to use a WC.

Also need to promote a ‘changing places’ public facility for adults which includes hoist and changing berth.

Hull Development Framework Core Strategy

Issues, options and suggested preferred option consultation document

From George Brentnall, access officer

Following on from the consultation day, provided through Yorkshire Planning Aid, I have listed below the issues raised and comments made by disabled people. Some organisations may well submit their own comments through Limehouse, the majority, for example visually impaired people are unlikely to do so;

1. Introduction - for a technical policy document the introduction will be accessible to many none professional people, which is important 2. Point 2.23, page 22; based on the community strategy - It would be useful also to highlight the 3 audience groups here. It shows that, to use the council’s words, the equalities “golden thread” is interwoven through all policy including this one. Then it will be clear in future sentences when it says eg “everyone has the opportunity to live in a decent home” we have a reference 3. following on from point 2 above, it would be useful to adopt the 3 audience groups specifically in this document because the community strategy only runs to 2011 and this runs until 2026 4. Point 2.26, page 23; “support equity for all” shouldn’t this read “equality of opportunity for all”?

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 389

5. Page 29, Objective 1 – you can not argue with this being the aim, as this will surely benefit everyone in the city, and logically it will need to be planned in a stepped approach 6. Broad guiding principles, A3/4 pages 44/45; sustainable development, “balancing the following”…..etc, these are good ambitions, however the comments following in A4 do not really include much around “social justice” input from the planning system needs to give a high weighting to inclusively designed schemes, schemes that older people, disabled people and vulnerable people are able to use (the interchange springs to mind as being a different design if it was ever intended to be inclusive) 7. objective 3 probably needs to go slightly further in that sustainable means for all now and beyond 8. Options 3, page 45; mainly support option 1, though again it needs to be made very clear in the preceding text that social means inclusive and an identification of the 3 target groups in the current One Hull Community Strategy. other options do not give sufficient weight to social justice 9. A9, Page 46; the concern over the Code for Sustainable Homes is that there are no minimum standards set for the ‘health and well-being’ section. Disabled people want to see included in this a 100% commitment to ‘Lifetime Homes’ standard. It needs to be made clear in this section about sustainable development that LH design is an essential part of sustainability. A recent report “every disabled child matters” has shown that over 50% of children are living in unsuitable accommodation. If we neglect LH and do not highlight the need for family bungalows and wheelchair accessible housing we continue to restrain the life chances, both socially and economically, of young disabled people moving through education and potentially into employment because they will simply be to busy simply trying to live 10. A11 page 46/7; support the first bullet point aim that “nobody is excluded”. A further bullet states “are accessible to all” which I am hoping here means in the widest sense and not simply about cars walking or cycling. It probably should say “are accessible and inclusive of everyone” 11. Objective 4 and Options 4, page 48; creating sustainable communities is about more than included in the objective and I am not sure that 3 options meet the objective 12. A23, page 50; lists 5 significant initiatives, some of which are not truly embracing inclusion, and therefore sustainable developments over design, fashion and possibly now economics. This core strategy needs to lead and be very firm in what it expects from sustainability and inclusion to ensure that other Masterplans and strategies fit with the aims, objectives and options contained in this core strategy 13. A27, page 53; discusses “improved street design so that they are pedestrian friendly” there is broad agreement that this should happen, however there is also a major concern from many disabled people that this simply means mixing together pedestrians with vehicles and cycles. Some of the proposals for streets in recent housing designs have been poor with regard to equality of opportunity for some disabled people to use the streets. Manual for Streets clearly states that a Local Authority must comply with their Disability Equality Duties of 2005. The document also goes on to remind Authorities that if they do not comply with their duties they run the risk of a claim and, with the awareness now of many disability Response to the Hull Core Strategy issues and options report, June 2008 October 2008 390

organisations in Hull, this must be taken seriously. MfS also makes it clear that the Authorities DE duties are retrospective, this could therefore cost the Authority huge sums of money to correct poor design if street design is not inclusive of all disabled people. It needs to be made clear that it is not a one design fits all approach that will be suitable, disabled people need the opportunity to buy homes in any street, shop in any local centre and take leisure in locations of their choice 14. A27, Page 52; “better lighting” is supported in principle; again it needs to be suitable for the needs of disabled people and appropriate to its location. For example floor lighting simply dotted about can, simply for decorative purposes, be very confusing 15. Objective 5, page 54; is supported 16. Option 6, number 6,page 58; reads like the intention is to limit the use of cement and locally sourced materials 17. Risk of flooding section, page 59 onwards; – SFRA findings will mean that there is likely to be difficulties in providing equal and inclusive access and facilities in new developments in certain parts of the city because of flood risk. It should be included in this section that creative design will be needed to overcome some of these problems. Rear access only is not an option to public buildings or to new housing. The proposed Fruit Market development is an example of these difficulties which need to be overcome and should be highlighted in this document. In the Fruit Market for example there is a desire to follow back of footway elevations, flood risk will require action to reduce the risk and access for disabled people is a requirement along with our Disability Equality Duties. 18. Objective 7, page 62; appears to be unrealistic simply because of the location of the City, the aims for the City Centre Masterplan, plans for the fruit market etc there is also conflict between this objective and one of the measurement proposals, re granting permissions after Environment Agency sustained objections. Objective 7 should therefore be realistic. It should be possible that areas can be designed to minimise the impact of flood and should be included 19. Transport – do not forget many disabled people currently do not have a realistic alternative to using their own vehicle 20. Objective 8, page 65; what does “improve accessibility” actually mean here for disabled people. Disabled people link accessibility to disability 21. B Quality of Life – B3, page70; 20% of Hulls population are disabled people. Obviously the type and level of disability is hugely variable as are their needs in all aspects of life, however their housing needs should be clearly included along with the needs of older people in this text 22. Wheelchair accessible housing; Nowhere within the quality of life text is there a commitment to the provision of any housing designed to wheelchair accessible standards, this should be included 23. Housing type, B33, page 80 on – in addition to the need to commit to a level of specifically designed wheelchair accessible housing; perhaps a percentage in developments over a certain size, there is also a need to commit to family bungalows within this section, again perhaps a % in developments over a certain size or alternatively identify areas, due to

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 391

flood risk, where these should be a priority development. Please note that ground floor flats are not an alternative to a family bungalow, they are different aspirations in the quality of life. The recent ‘Every disabled child matters’ report suggests that disabled children are worse off than any other group of disabled people because of the lack of suitable housing, size of properties, size of rooms and quality of design. The report recommends that authorities need to address this problem in their strategies. We haven’t and we need to 24. B38, page 82; states that “new proposals could take into account the need for ‘Lifetime Homes’ standards”, this is unacceptably weak. We need to commit to 100% lifetime homes standard. It fits in with needs of disabled people, meets sustainability needs, meets the needs of an aging population and saves millions pounds which local authorities spend on alterations to homes. It will be true that in some cases, particularly with conversions, that it will not be achievable, this can be argued by the developer in the Design and Access Statement and the argument judged accordingly. In new build it should be very difficult to put up an acceptable argument about not reaching the whole standard 25. Whilst Building for Life is supported in principle it is not an acceptable alternative to ‘Lifetime Homes’ standards with regard to access and should not be considered as such. Many award winners on the Building for Life web site would not be considered to be inclusive design by many disabled people. 26. There is again the possibility of a challenge under the authorities Disability Equality Duties to promote the equality of opportunity for disabled people if ‘Lifetime Homes’ standard is not a firm 100% commitment because again we will be deciding where disabled people live, not them and therefore not promoting equality of opportunity. 27. Housing density and design, page 83 – the need for homes fit for disabled people, disabled children and families will and should have an effect on house type and design. Many disabled people have a major concern over the 3 storey homes, which have little or no facility at ground floor level and are therefore basically poor with regard to access and should largely be discouraged. Often integral garages are converted to living rooms, and then later we get requests to mark out parking bays fro disabled members of the family as parking close by cause’s accessibility problems. Density may have an affect on providing suitable level access into some properties and is a potential argument by developers in not reaching the lifetime homes standard, provided densities are realistic Can garage to habitable room conversion be stopped through planning? 28. B46; do not wait 29. Objective 11, page 86; support the objective of an appropriate housing mix, provided that the text makes it clear that we mean truly inclusive and homes of all types with provision suited to everyone’s needs 30. Options 11, is overall restrictive and unlikely to meet the objective, we need family bungalows, (every disabled child matters report) 31. the design of apartments will need to improve to make them sustainable with regard to access for disabled people 32. gypsy and traveller; sites need to be near hubs of facilities, there is ageing and disability in this community which needs to be suitably catered for too Response to the Hull Core Strategy issues and options report, June 2008 October 2008 392

33. Objective11, page 86; shouldn’t this be based more around opportunity and choice of housing type to suit the needs of all existing and potential residents? 34. Options 11, C1, page 87, is basically supported with required alteration – “ensure that all new housing is built to Lifetime Homes Standards. It is important that riders are not added about “unless there are over-riding reasons why this should not be the case” which has currently been proposed in the final draft of the NASA plan. With a rider like this it is ultimately no commitment to Lifetime Homes, it is too open and will no doubt include complaints about economics, flood risk, designer desire, fashion, materials etc. Anything less than 100% commitment is unacceptable. As previously stated if there are genuine reasons why Lifetime Homes Standards can not be met in full, these can be argued if and when they happen in the D&AS 35. Option 11, recommend that Lifetime Homes Standard adopted is that based on Joseph Roundtree 36. Option 11, There needs to be an element of policy which will lead to the construction of wheelchair accessible homes both single/carer occupancy and family. In addition these types of properties need to be both for rent and sale and located in different areas of the city 37. Option 11, see also Governments, communities and local government, “A national Strategy for housing in an ageing society “ 38. Objective13, page 102; would support the idea of ensuring all communities have access to the basic daily needs close by. It is important to many disabled people, if shops and other facilities are nearby it can help reduce the sense of isolation some disabled people have when no facilities are nearby and reduce reliance on others to provide assistance. Local facilities in mixed developments can also take the pressure of the need to travel which some disabled people can find very difficult or costly. 39. Option 13, support mixed developments for reasons stated above 40. Option 16, 3, support the idea of grouping and integration, particularly during the conception of new communities for example Gateway projects, this should include planning positioning of housing types eg bungalows, wheelchair accessible housing etc nearer to transport routes and medical facilities 41. B141, page 114, disabled people, involved feel that the current Local Plan is weak on commitment to inclusion, housing type, design etc and dated in terms of aspiration. There is no support for this to be used as policy base or design base 42. B142, page 114; disabled people had hoped that Design and Access Statements would be a positive step towards inclusion, leading developers to think more, however currently many of the access sections have been very poor in quality often containing little or no consideration of a though process and often even when they do the access statement almost seems to be produced to justify the design or concept. Is there anyway that a standard could be adopted through the core strategy related to the cost of the development. Currently it is too easy for developers to say that the ramp meets Building Regulation standard without actually considering how disabled people will actually use the facility (examples, bus station again, bridge over River Hull) Response to the Hull Core Strategy issues and options report, June 2008 October 2008 393

43. Following on from the above, few developments have been put before disabled people, including major ones. We need to be encouraging this, through this strategy as the guidance on the production of D&AS recommends. Again our Disability Equality Duties also require us to do this, if disabled people demonstrate that they want to be involved. We also need to give the comments of organisations of disabled people suitable weighting. If something is not accessible it can very difficult and expensive to put it right alternatively, effectively many disabled people become excluded 44. Option 17, 1, page 115; many disabled people have expressed a view that they have a desire to maintain the history of the city, with sensitive modifications to buildings, streets and places etc. local character assessments should take into account the accessibility of all facilities and an understanding of how they can be altered to ensure that they are fit for the whole community 45. Option 17, 2; agree that the SPDs need to be reviewed. The majority do not demonstrate an acceptable level of inclusion and a number are outdated and incapable of reflecting the changing aspirations of disabled people 46. Option 17, 4; “on its own design merits”- only if access part of D&AS actually shows that organisations of disabled people have been consulted and their views suitably addressed 47. Option 17, 6; support the principle that “all development is accessible” assuming that it means to all the community, however there is a definite need to declare “accessible to the highest standards” 48. Objective18, page116; this is does not seem to be a particularly clear objective 49. Options 18, page 117; these can be broadly supported, there is a huge need to help tackle fitness related disability but also to enable disabled people within any community to have nearby access to green space which could hopefully add to quality of life and reduce isolation and resulting mental health problems. Remember that physically disabled people who receive disability living allowance, mobility section will struggle to walk beyond 100m 50. Objective19, page118; as previously expressed, many disabled people have expressed an interested in the historic parts of the City and its heritage and do not want it destroyed, including more support for locally listed buildings. The idea of maintaining these historic buildings and making suitable to improve access for all should not be mutually exclusive and should in fact be positively promoted. 51. C jobs and Prosperity, page 124 on; disabled people are more likely to be out of work than the average, if a wide range of job types are encouraged into the city then disabled people generally will have more opportunity to break the unemployment-poverty cycle 52. D education, learning and skills, page 144 on; more inclusive education is improving the long term prospects for many disabled people. The Building Schools for the Future Scheme really does need to address education for all, including life long learning and re-training. Earlier applications failed in design to recognise how disabled people are likely to operate in the designs they put forward (poor quality access statements and understanding of disability). Poor design, eg too much walking inside a building will only lead to difficulties and failure for some disabled children

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 394

Comments from different faith groups and ethnic minorities Thursday 28th August 2008, Guildhall, Hull.

Education

• Need new build community centres with large hall 200+ people and crèche. • 12 different communities e.g. Polish, Bosnian, Chinese run supplementary language and cultural schools. Council recently stopped supporting the schools for venues and staff. • Concern that economic drive over ruling minority community needs. • These schools are priority for some communities. • Need funding. • At the moment sharing spaces or renting – expensive. • If Council made a space available- multi ethnic- then could be shared. • Used to be Endeavour High School open on Saturdays and used by different groups. • Why has the funding been stopped? • Location should be near to the city centre so easy to get to. • Needs to be big – lots of children and suitable – need to find out each groups needs. • Education league – Hull still quite low down. Need more teachers / investment. Study whole programme to see where failures are. Need to do research. Key – future of Hull.

Housing

• Older houses are empty, bad conditions. In general need cleaning. • Have done quite a lot with housing e.g. St Georges Road, Newington and St Andrews. • Gateway – housing refugees. Feedback that insensitive to people’s needs – houses for 1 year contract. Suffer racial abuse. Put where cheapest not most suitable.

Places of Worship

• Not just purpose built, also need provision in gyms, health centres, hospitals, other public places. Need prayer rooms, multi- faith. • Central mosque outgrown. Need land. Support from council to identify buildings / land. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 395

• Massive increase in ethnic minorities but facilities not changed to reflect this. Still going on 2001 census figures. • Feeling that hard work for groups to do anything, to get funding for anything. Need Council to be more open. Not just talk but action.

Transport

Options: 1. A63 Castle Street. BP development affects this road. Lots more lorries. Have own port which could use. Castle Street has too many traffic lights. 2. Park and Ride. Depends on cost and where they are. Are the current ones used? 3. There should be more cycle paths.

• Buses don’t respect timetables. Bus fares very high – big problem. Manchester magic bus – cheaper e.g. 60p anywhere. Should have one like this. At the moment £1.20 for 3 / 4 stops. • To cross the city can’t get one bus. Need to change at bus station. Wait in between. Difficult to change. Bringing you into the city into rush hour traffic. • Need tram system. • Need more traffic wardens e.g. around the stadium. Problems with people parking with no pass – get blocked in. Stadium should use Walton Street P&R.

Shopping

• Better shops needed. St Stevens – empty units – cold. • Big scale industrial developments needed to raise employment.

Healthy Living

• Idea of limiting takeaways is not positive enough. Need more action e.g. sports centres. Parents give the children money, but unhealthy food is a lot cheaper than healthy food. This needs changing. Outdoor fields are not kept well, e.g. dogs, and indoor centres are too expensive. • Need places for children e.g. cheap sports centres. E.g. Kingston Youth Centre – not big though. Need places to play volleyball / football. Response to the Hull Core Strategy issues and options report, June 2008 October 2008 396

• No central sports centre with big sports hall. University facilities not accessible and expensive. • Women only swimming sessions are difficult to get on a regular basis and at the moment the group can only get once a fortnight at 9am. Need women lifeguards. • Beverley Road is central and such sessions would be good here. Council should provide this as a standard option and not as something you need to pay for specially. Also women only gym facilities needed completely separate from the men e.g. glass screen in between no good. • More cycle paths are needed and somewhere to chain bikes at schools. Routes should be on pavements to make it safe for kids. Idea – rent bikes at different parts of the city as in Barcelona and Paris. Pay monthly. Need to think about road safety and theft.

Drainage

The systems need cleaning, at the moment in city centre they flood easily and smell e.g. nr Debenhams

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 397

Appendix 5 – Feedback from statutory Stakeholders on Sustainability Appraisal of the Core Strategy ‘issues/options’ report.

SA of Issues & Options – Organisation/ Person Comment Council’s Response Section General English Heritage As you will be aware, in terms of the Observation noted. historic environment, we considered that Scoping Report identified the majority of plans and programmes which are likely to be of relevance to the development of the Core Strategy for the City, that it put forward a suitable set of Objectives and Indicators, and that it established an appropriate Baseline against which to assess the Plan’s proposals. In general terms, therefore, we believed that it provided the basis for the development of an appropriate framework for assessing the significant effects which the strategy might have upon the historic environment.

Given the nature of the document being examined and the stage which it has reached, we would broadly concur with the conclusions about the likely effects which the various elements of the strategy might have upon the historic assets of the Plan area. General English Heritage The only comment we have on the This will be included in the SA Report is as follows: Report and subsequent Scoping Reports. The ODPM guidance on Sustainability

Response to the Hull Core Strategy issues and options report, June 2008 October 2008 398

SA of Issues & Options – Organisation/ Person Comment Council’s Response Section Appraisals of RSSs and LDDs under Task B1 states that it is important for the Objectives of the DPD to be in accordance with sustainability objectives and advises that the DPD Objectives should be tested for compatibility with the Sustainability Appraisal Objectives. Whilst the Sustainability Appraisal has assessed the Options of each of the Plan’s Objectives, it has not tested how sustainable each of the Objectives themselves might be.

Response to the Hull Core Strategy issues and options report, June 2008 October 2008