PNW00177 Outer North East MX2-39

Ref: PNW00177 HMCA\Topic: Outer North East

Subject: Site in the plan

Site: MX2-39 - Parlington Estate, Aberford

Agree with proposed use? No

Soundness

Consider the plan sound? No

Test of soundness addressed: Positively prepared Effective Justified Consistent with NPPF

Changes required to make sound: n/a

Issues

Issue: Other - flood risk, loss of argicultural land Flood Risks Water from the Parlington Estate drains into the Cock Beck predominantly with lesser volumes draining in to the Crow Beck. Both flow through Aberford; their confluence is close to the centre of the village. Aberford has been flooded regularly in recent years. Increasing the volume of water discharging into these rivers would increase the risk of flooding not only at Aberford but also further downstream at Tadcaster where the Cock Beck meets the river Wharfe. Tadcaster has been severely affected by flooding as recently as December 2015. The submission relating to site MX2-39 proposes the use of a ‘former “ornamental” lake’ to balance surface water run off. The lake lies within Parlington Hollins an area designated as part of the Leeds Wildlife Habitat network, a site of ecological and geological importance and an ancient woodland, thereby being a UK priority habitat. The increased risk of flooding both locally and further afield and the inadequate plans for mitigating this means this site should not be allocated. Loss of arable land Contrary to the statement in the submission by M&G UK property fund that the agricultural land is of little value Natural England’s map ‘Yorkshire & The Humber Region 1:250 000 Series Agricultural Land Classification’ indicates that land in this area is of very good quality. National Planning Policy guidance paragraph 112 says “…local planning authorities should seek to use areas of poorer quality land in preference to that of higher quality.” Building on site MX2-39 would directly contradict this guidance.

Issue: Highways and transport The promoters of MX2-39 anticipate that 97% of the trips made by vehicle from the new town would leave via a single access point towards junction 47 of the A1/M1 link road and that presumably the return trips would be made in the same way. Currently at peak travel times junction 47 is dangerously inadequate to manage the volume of traffic flow. Vehicles exiting here from the direction of Leeds (67% of the predicted trips) routinely have to queue on both the hard shoulder and lane 1 of the motorway. A minimum planned build of 1850 homes would, at a conservative estimate, generate 2775 trips each morning and evening (assume an average of 1.5 journeys per household). This would increase the traffic volume at junction 47 by 1859 trips which is unsustainable. Traffic heading south east on the A656 would increase by 222 trips. This road has a junction with Church Lane Micklefield where sight lines are very restricted and a junction with Peckfield Lane industrial site which is heavily frequented at peak times by HGVs. All other roads around the proposed development are classified as B roads or are unclassified. On the B1217, Aberford Road/ Collier Lane there are two locations where traffic accidents regularly occur; Hook Moor crossroads and close to Wakefield Lodge. Increased traffic use would further increase the risk of serious accidents. The promoters of MX2-39 suggest that 2% of traffic might leave the site via Parlington Lane on to Long Lane/Barwick Road and towards Garforth. Long Lane/Barwick Road is an unclassified country road. At two points between the proposed egress and Garforth it is single lane (crossing Cock Beck and passing under the Leeds-York railway line. At Town End Garforth this road joins the A642. This is a busy and heavily used road particularly at peak times and could not meet the increased traffic demands effectively. Clearly Parlington’s location does NOT provide excellent strategic road access. Public transport Site MX2-39 is located in the Outer North East HMCA as identified by Leeds City Council. There are no rail stations within the Outer North East area. The nearest rail station at Garforth does not have the capacity to cope effectively with current levels of use at peak times. There is insufficient parking for rail users. Trains are regularly over crowded. Increasing the number of commuters using rail services is unsustainable. There is one bus service per day which passes the proposed site entrance. Accessing other bus services would require walking at least a mile. This would not be feasible for the elderly or disabled or parents with young children. Thus residents of the new town would be dependent on car travel and would exacerbate the road traffic problems identified above. Developing this site would require very significant investment in road and rail infrastructure and major improvements in public transport services. None of these are within the remit of the proposers of the development. The plan is unsound.

Issue: Schools Secondary school provision in the locality is already oversubscribed. Local authorities are no longer able to open new schools. There are no plans for how secondary age pupils living in the new development will receive an education. The NPPF states that infrastructure must be in place first. New primary school places would also be required. This is alluded to only in terms of a contribution within the proposal. The plan is poorly prepared and unsound. Issue: Greenbelt The Parlington Estate is a key component of the Leeds Green Belt, serving an important function in ensuring the city and its satellite communities do not merge with consequent loss of greenfield land. It is a particularly important part of the Green Belt due to it containing Grade A agricultural farm land and several Grade II and II* listed buildings. It is a designed landscape unchanged over centuries. The proposed site contains Ancient Woodland and any change of status would damage this, and a designated site of Special Environmental and Geological Interest (SEGI) and is an integral part of the Magnesian limestone Green Infrastructure corridor as defined by Natural England and incorporated within Leeds City Councils’ Adopted Core Strategy; Building a new town at MX2-39 a few hundred metres from Barwick and Aberford is a gateway for future encroachment and the merging of Barwick, Aberford and Garforth. The NPPF and Leeds City’s own core strategy state that one purpose of Greenbelt is to stop communities from merging. The proposed arbitrary extents of MX2-39 in our view, are not defensible planning barriers and as such provide a vehicle for encroachment, coalesce and merging in the future. Land to the east of Wetherby currently locally designated as 'rural land' is not an equivalent or appropriate substitute for the prime green belt of Parlington. The greenbelt land containing MX2-39 should not be subject to a selective, isolated greenbelt review, and full and sequential review should be taken on all greenbelt in the HMCA area and the whole of the principle authority area. LCC has identified only 6% of its allocation target from brownfield land for the Outer North East Area. This is not consistent with its own register of available brownfield sites which identifies 30,000 homes as being deliverable on brownfield sites (45% of the 66,000 identified in its own core strategy). MX2-39 is unsound as any sequential test would propose brownfield, then greenfield before Green Belt.

Section 9, paragraphs 79 to 92 of the NPPF articulate the clear importance ascribed to green belt land, the requirement for them to not be used for development with only limited ‘exceptional circumstances’ to this rule. These ‘exceptional circumstances’ have not been adequately defined as part of this development proposal. The use of green belt within this proposal is attempted to be addressed by the proposal itself against the 5 purposes of the green belt, as defined in paragraph 80 of the NPPF, but I do not believe these to be correct: Green Belt serves the following five purposes: 1. to check the unrestricted sprawl of large built-up areas – this proposal will increase the ‘sprawl’ of Garforth and East Garforth into the neighbouring villages (particularly when considered against the planning applications for the Garforth area) as well as a continuation of the East Leeds conurbation from say Colton and Seacroft; 2. to prevent neighbouring towns merging into one another – this proposal will have the effect of merging Barwick in Elmet, Aberford, the proposed Parlington new townand Garforth as well as linking more closely with Colton; 3. to assist in safeguarding the countryside from encroachment – this proposal will only exacerbate the likelihood of encroachment from the aforementioned areas in Garforth and even Colton. The proposed ‘defensible buffer’ is not sufficient to prevent this and will be managed by the same land holders as the proposed development with no recourse to prevent further development; 4. to preserve the setting and special character of historic towns – as discussed above the limited impact on the historic neighbouring villages is predicated on flawed assessments of traffic flows using modelling techniques that do not reflect reality and also based upon a single entry/exit point which the highways agency has assessed as being inadequate; 5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land – the use of this green belt land runs contrary to this principle as there are alternative sites such as the brownfield sites at Thorpe Arch that could take a significant proportion of house building without recourse to destroying existing green belt land; If any greenbelt land is to be considered for allocation, it should be at an appropriate percentage and on an infill basis adjoined to existing settlements and NOT a country estate containing grade II* and II listed buildings of national heritage value; All land in the ONE HMCA area should be sequentially tested in order to establish the most suitable land for development.LCC has identified only 6% of its allocation target from brownfield land for the Outer North East Area. This is not consistent with its own register of available brownfield sites which identifies 30,0000 homes as being deliverable on brownfield sites (45% of the 66,000 identified in its own core strategy); The inclusion of this site is inconsistent with National Planning Policy Framework: • PRIORITISATION OF GREENEBLT OVER BROWN FIELD: NPPF states that brown field sites are to be prioritised over the development of green field and greenbelt. The July 2016 Plans Panel meeting had the option of taking forward a brown-field site at Thorpe Arch but rejected this in favour of this greenbelt site. • LOSS OF COMMUNITY IDENTITY: NPPF states that merging of communities is to be prevented, yet development of this greenbelt site will threaten the individual identities currently held between the areas in which they are located. This development of 5,000 houses will only be separated from Garforth by the motorway junction, particularly once the planned development in East Garforth near junction 47 takes place. Although the developers call this development a “village” and the council call it a “garden city” this is clearly an extension of Garforth and represents urban sprawl. The size of this development dwarfs the two villages of Barwick-in-Elmet and Aberford and by extending to within 500m of each village threatens the separate community identity of both villages. The urban sprawl represented by this development will knit the areas of Garforth, Aberford and Barwick together resulting in a loss of individual community identity. There are no defendable features that would prevent the engulfing of Barwick and Aberford by this development; • INADEQUATE ENVIRONMENTAL CONSTRAINT: NPPF now states that the target level of housing development within the plans should be capped in line with the capacity of brown field sites to accommodate it, to protect and enhance greenbelt. The current plans significantly exceed this capacity; resulting in the permanent destruction of greenbelt; • NON-EXCEPTIONAL CIRCUMSTANCE: NPPF states that greenbelt is to be protected and requires exceptional circumstances to be built on. There is nothing exceptional about the council's plans to build on unspoilt land to meet their current housing target. The council's adoption of the self-imposed Core Housing Strategy cannot be considered to be an exceptional set of circumstances, but is merely part of their scheduled housing building policy plan.

The plan is unsound and contravenes the National Planning Policy Framework.

Issue: Conservation and heritage Neither the revised SAP for Outer North East (ONE) nor the proposed MX2-39 plan follows the core principles of the NPPF stated below: • take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it; • conserve heritage assets in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of this and future generations; Aberford and Barwick in Elmet are village communities with long histories and so have conservation status. The boundaries of site MX2-39 are less than half a mile from either village. This threatens to engulf the villages leading to further encroachment and urban sprawl. These historic villages will lose their distinct identities. MX2-39 lies within the Parlington estate. Parlington is also a site of historic significance. It predates the Norman conquest as there is reference to it in the Domesday book. It has belonged to only two owners since the mid -1500s; the Gascoigne family and the present land owners, M&G Investments who acquired the estate in 1964. It was thus in single ownership for over four centuries and even now remains predominantly unchanged. The development of MX2-39 would result in the loss of this unique designed landscape. There are also a significant number of grade II and grade II* listed buildings and structures both in and close to the proposed boundary of the development. Construction of a new town would destroy the setting and landscape in which these listed structures lie. The NPPF paragraph 133 states in part ‘Where a proposed development will lead to substantial harm to or total loss of significance of a designated heritage asset, local planning authorities should refuse consent,…’ There is archaeological evidence of human activity on the Magnesian Limestone ridge in Parlington throughout the last two millennia such as deserted medieval villages, Iron Age enclosures, Romano-British settlement. Finds such as these are rare in Northern England. The development of MX2-39 would destroy archaeological remains of regional and possibly national importance. From all the evidence described above allocating site MX2-39 for development is wholly unacceptable. The plan is unsound. Issue: Ecology/Landscape/Trees The plan to develop site MX2-39 is unsound. Site MX2-39 is an outstanding example of an intact country estate unchanged for centuries. It has a rich and diverse archaeological heritage and is of important historic interest in East Leeds. It is a site of high quality Green belt and includes areas of ancient woodland, SEGI and Leeds Wildlife Habitat Network. Ancient woodland is an irreplaceable habitat which comprises only 2% of UK woodland and is rigorously protected. Construction work, the presence of permanent structures and large scale human interference will have a significant, detrimental impact on the ancient woodland and the surrounding and supportive ecosystems. The MX2-39 site should be considered as a special conservation area requiring special consideration and thus entirely inappropriate for the proposed scale of development. The National Policy Planning Framework (NPPF) 2012 paragraph 1181 states 'planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss'. The NPPF 2012 sets out 12 core planning principles; principle 7 states that plans should 'contribute to conserving and enhancing the natural environment and reducing pollution. Allocations of land for development should prefer land of lesser environmental value, ...'.MX2-39 has substantial, significant and unique environmental value. Plant species which indicate ancient woodland such as bluebells, wood anemone and wild primrose are found extensively throughout MX2-39. Regionally rare and uncommon plant species are found in the ancient woodland and SEGIs including green flowered helleborine, wood barley, false oxlip, columbine and goldilocks buttercup. There is a diverse flora which supports a good range of birds and invertebrates, particularly Lepidoptera, including the regionally uncommon speckled wood butterfly. Standing Advice for Ancient Woodland applies to all planning authorities and states that 'An ancient woodland ecosystem cannot be moved' and 'Whilst the translocation of ancient woodland soil to a new site is sometimes proposed as a compensation measure for the loss of ancient woodland, it is not possible to replicate the same conditions at another site. In that circumstance it will no longer be an ancient woodland.' The proposed development is less than 50m from a Site of Special Scientific Interest at Hook Moor. This SSSI supports a protected plant species, Orobanche reticulata' which is largely restricted to the Magnesian limestone belt and has 'near threatened' status. Development at site MX2-39 will be on the Magnesian limestone belt and so may well inhibit the survival of this threatened species. The promoters of site MX2-39 propose to manage the balancing of surface water run off through the use of a former ornamental lake in the SW corner of the site. This lake lies within the ancient woodland and one of the Sites of Ecological and Geological Interest (SEGI). Thus not only is this plan unsound it is also clearly poorly prepared.

Legal compliance

Consider the plan legally compliant? No

Legal compliance issues addressed:

Local Development. Scheme Statement of community involvement Duty to co-operate Consultation of statutory bodies

Planning and Compulsory Purchase Act Sustainability appraisal Town and Country Planning Regs

Comments on legal compliance: n/a

Future updates

Take part in public examination? Be informed of submission to examination? Be informed of adoption of the plan? Submitter details Agent details Ref PDP10155 Ref Title Title Forename Karen Forename Surname Baxter Surname Address 1 19, Highfield Road Address 1 Address 2 Aberford Address 2 Address 3 Address 3 Town LEEDS Town PostCode LS25 3AY PostCode Online response to LCC SAP MX2-39

Karen Baxter

Ecology, Landscape, Trees

The plan to develop site MX2-39 is unsound. Site MX2-39 is an outstanding example of an intact country estate unchanged for centuries. It has a rich and diverse archaeological heritage and is of important historic interest in East Leeds. It is a site of high quality Green belt and includes areas of ancient woodland, SEGI and Leeds Wildlife Habitat Network. Ancient woodland is an irreplaceable habitat which comprises only 2% of UK woodland and is rigorously protected. Construction work, the presence of permanent structures and large scale human interference will have a significant, detrimental impact on the ancient woodland and the surrounding and supportive ecosystems. The MX2-39 site should be considered as a special conservation area requiring special consideration and thus entirely inappropriate for the proposed scale of development. The National Policy Planning Framework (NPPF) 2012 paragraph 1181 states 'planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss'. The NPPF 2012 sets out 12 core planning principles; principle 7 states that plans should 'contribute to conserving and enhancing the natural environment and reducing pollution. Allocations of land for development should prefer land of lesser environmental value, ...'.MX2-39 has substantial, significant and unique environmental value. Plant species which indicate ancient woodland such as bluebells, wood anemone and wild primrose are found extensively throughout MX2-39. Regionally rare and uncommon plant species are found in the ancient woodland and SEGIs including green flowered helleborine, wood barley, false oxlip, columbine and goldilocks buttercup. There is a diverse flora which supports a good range of birds and invertebrates, particularly Lepidoptera, including the regionally uncommon speckled wood butterfly. Standing Advice for Ancient Woodland applies to all planning authorities and states that 'An ancient woodland ecosystem cannot be moved' and 'Whilst the translocation of ancient woodland soil to a new site is sometimes proposed as a compensation measure for the loss of ancient woodland, it is not possible to replicate the same conditions at another site. In that circumstance it will no longer be an ancient woodland.' The proposed development is less than 50m from a Site of Special Scientific Interest at Hook Moor. This SSSI supports a protected plant species, Orobanche reticulata' which is largely restricted to the Magnesian limestone belt and has 'near threatened' status. Development at site MX2-39 will be on the Magnesian limestone belt and so may well inhibit the survival of this threatened species. The promoters of site MX2-39 propose to manage the balancing of surface water run off through the use of a former ornamental lake in the SW corner of the site. This lake lies within the ancient woodland and one of the Sites of Ecological and Geological Interest (SEGI). Thus not only is this plan unsound it is also clearly poorly prepared.

Conservation/Heritage

Neither the revised SAP for Outer North East (ONE) nor the proposed MX2-39 plan follows the core principles of the NPPF stated below:

• take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it;

• conserve heritage assets in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of this and future generations;

Aberford and Barwick in Elmet are village communities with long histories and so have conservation status. The boundaries of site MX2-39 are less than half a mile from either village. This threatens to engulf the villages leading to further encroachment and urban sprawl. These historic villages will lose their distinct identities.

MX2-39 lies within the Parlington estate. Parlington is also a site of historic significance. It predates the Norman conquest as there is reference to it in the Domesday book. It has belonged to only two owners since the mid -1500s; the Gascoigne family and the present land owners, M&G Investments who acquired the estate in 1964. It was thus in single ownership for over four centuries and even now remains predominantly unchanged. The development of MX2-39 would result in the loss of this unique designed landscape. There are also a significant number of grade II and grade II* listed buildings and structures both in and close to the proposed boundary of the development. Construction of a new town would destroy the setting and landscape in which these listed structures lie. The NPPF paragraph 133 states in part ‘Where a proposed development will lead to substantial harm to or total loss of significance of a designated heritage asset, local planning authorities should refuse consent,…’

There is archaeological evidence of human activity on the Magnesian Limestone ridge in Parlington throughout the last two millennia such as deserted medieval villages, Iron Age enclosures, Romano- British settlement. Finds such as these are rare in Northern England. The development of MX2-39 would destroy archaeological remains of regional and possibly national importance.

From all the evidence described above allocating site MX2-39 for development is wholly unacceptable. The plan is unsound.

Highways/Transport

The promoters of MX2-39 anticipate that 97% of the trips made by vehicle from the new town would leave via a single access point towards junction 47 of the A1/M1 link road and that presumably the return trips would be made in the same way. Currently at peak travel times junction 47 is dangerously inadequate to manage the volume of traffic flow. Vehicles exiting here from the direction of Leeds (67% of the predicted trips) routinely have to queue on both the hard shoulder and lane 1 of the motorway. A minimum planned build of 1850 homes would, at a conservative estimate, generate 2775 trips each morning and evening (assume an average of 1.5 journeys per household). This would increase the traffic volume at junction 47 by 1859 trips which is unsustainable. Traffic heading south east on the A656 would increase by 222 trips. This road has a junction with Church Lane Micklefield where sight lines are very restricted and a junction with Peckfield Lane industrial site which is heavily frequented at peak times by HGVs. All other roads around the proposed development are classified as B roads or are unclassified. On the B1217, Aberford Road/ Collier Lane there are two locations where traffic accidents regularly occur; Hook Moor crossroads and close to Wakefield Lodge. Increased traffic use would further increase the risk of serious accidents. The promoters of MX2-39 suggest that 2% of traffic might leave the site via Parlington Lane on to Long Lane/Barwick Road and towards Garforth. Long Lane/Barwick Road is an unclassified country road. At two points between the proposed egress and Garforth it is single lane (crossing Cock Beck and passing under the Leeds-York railway line. At Town End Garforth this road joins the A642. This is a busy and heavily used road particularly at peak times and could not meet the increased traffic demands effectively. Clearly Parlington’s location does NOT provide excellent strategic road access.

Public transport

Site MX2-39 is located in the Outer North East HMCA as identified by Leeds City Council. There are no rail stations within the Outer North East area. The nearest rail station at Garforth does not have the capacity to cope effectively with current levels of use at peak times. There is insufficient parking for rail users. Trains are regularly over crowded. Increasing the number of commuters using rail services is unsustainable.

There is one bus service per day which passes the proposed site entrance. Accessing other bus services would require walking at least a mile. This would not be feasible for the elderly or disabled or parents with young children. Thus residents of the new town would be dependent on car travel and would exacerbate the road traffic problems identified above.

Developing this site would require very significant investment in road and rail infrastructure and major improvements in public transport services. None of these are within the remit of the proposers of the development. The plan is unsound.

Schools

Secondary school provision in the locality is already oversubscribed. Local authorities are no longer able to open new schools. There are no plans for how secondary age pupils living in the new development will receive an education. The NPPF states that infrastructure must be in place first. New primary school places would also be required. This is alluded to only in terms of a contribution within the proposal. The plan is poorly prepared and unsound.

Other

Flood Risks Water from the Parlington Estate drains into the Cock Beck predominantly with lesser volumes draining in to the Crow Beck. Both flow through Aberford; their confluence is close to the centre of the village. Aberford has been flooded regularly in recent years. Increasing the volume of water discharging into these rivers would increase the risk of flooding not only at Aberford but also further downstream at Tadcaster where the Cock Beck meets the river Wharfe. Tadcaster has been severely affected by flooding as recently as December 2015. The submission relating to site MX2-39 proposes the use of a ‘former “ornamental” lake’ to balance surface water run off. The lake lies within Parlington Hollins an area designated as part of the Leeds Wildlife Habitat network, a site of ecological and geological importance and an ancient woodland, thereby being a UK priority habitat. The increased risk of flooding both locally and further afield and the inadequate plans for mitigating this means this site should not be allocated.

Loss of arable land

Contrary to the statement in the submission by M&G UK property fund that the agricultural land is of little value Natural England’s map ‘Yorkshire & The Humber Region 1:250 000 Series Agricultural Land Classification’ indicates that land in this area is of very good quality. National Planning Policy guidance paragraph 112 says “…local planning authorities should seek to use areas of poorer quality land in preference to that of higher quality.” Building on site MX2-39 would directly contradict this guidance.

In my view the plan is UNSOUND.

The plan is not positively prepared.

Leeds City Council (LCC) did not offer a fully announced and widely advertised consultation period. The landowners and promoters of the site M&G held information and drop in sessions separately from those held by LCC.

Information from M&G advertising LCC’s sessions were factually incorrect and gave the date as one month later than the actual date. Neither party attempted to correct this or ensure that the public were fully and correctly informed.

It does not adhere to Leeds’ adopted Core Strategy.

• It fails to meet Spatial policy 6 which specifies o sustainable locations which meet standards of public transport accessibility – there is no bus service on the main access road the B1217 and limited services via other routes which are at least 1 mile away. o Preference for brownfield and regeneration sites. MX2-39 is entirely in the Green Belt o The least impact on green belt purposes. MX2-39 is entirely in the Green Belt and is of particular ecological and environmental importance as it contains ancient woodland and SEGIs. o The least negative and most positive impacts on green infrastructure, green corridors, green space and nature conservation. MX2-39 is entirely in the Green Belt and is of particular ecological and environmental importance as it contains ancient woodland and SEGIs. o Generally avoiding or mitigating areas of flood risk. The promoters propose to mitigate flood risk by using an area within the ancient woodland. • It fails to meet Spatial policy 7 which states that o housing numbers in the settlement hierarchy ‘ other rural areas’ should number no more than 100 infill and 600 extension. MX2-39 plans 1,850 homes in the first phase and potential further development after that. • It fails to meet Spatial policy 10 as a review of the Green Belt has not been carried out and MX2-39 contravenes all 5 purposes of the Green Belt as laid out in the NPPF p80

There has been no survey of local housing need therefore MX2-39 cannot seek to meet local needs for housing (CPRE) as the needs are not known.

MX2-39 contains ancient woodland which cannot be destroyed, moved or changed. It must not be developed.

The surface water from MX2-39 will discharge into the Cock Beck which flows via Aberford to the river Wharfe at Tadcaster. Both Aberford and especially Tadcaster are subject to regular flooding.

Existing transport networks are already stretched beyond capacity at peak times. The required infrastructure does not exist and the proposed transport plan is woefully inadequate.

The plan is not justified.

Site MX2-39 is the only site under consideration. It has not been assessed against other available sites. The plan is unsound and unjustified.

There is no rationale for the decision to allocate 75% of all new housing in Outer North East (ONE) HMCA to this single site.

Other sites within the ONE HMCA with much better SA scores have not been re-considered. There has been no explanation for why this is so. Site MX2-39 does not meet many of the SA criteria.

There are many sites in the ONE HMCA which have been discounted for reasons which apply equally well to site MX2-39.

The plan is not effective.

There is no evidence that any other authorities, bodies or organisations such as Network Rail, Arriva, Yorkshire Water, gas, electricity and other utilities, education providers, health authorities, fire and rescue services have been consulted.

There is no evidence that any organisations with responsibility for ensuring the investigation, understanding and preservation of the archaeology, history, heritage and natural environment of this unique site have been consulted.

Without consulting these agencies any concerns have not been identified and so plans to mitigate any problems cannot be made and considered. The plan for site MX2-39 cannot be seen as effective in delivering the allocated housing, associated infrastructure and services or in ensuring the preservation of the heritage of the site.

The plan is not consistent with national planning policy

The plan to develop site MX2-39 is not consistent with NPPF in many policy areas,e.g.

• In section 9, points 79, 80, 83, 87, 88 and, in particular, 89 ‘A local planning authority should regard the construction of new buildings as inappropriate in Green Belt.’ • In section 11, points 110, 111 and 112, ‘Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality.’ 117, 118 ..’ proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. ‘ • In section 12, points 126, 128, 129 ‘Local planning authorities should identify and assess the particular significance of any heritage asset that may be affected by a proposal (including by development affecting the setting of a heritage asset)..’, 131

Is the plan legally compliant? NO

The plan:

• Has not been prepared in accordance with the Local Development Scheme • Is not compliant with the Statement of Community Involvement (SCI) NPPF and Localism Act • Has not been subject to sustainability appraisal • Does not conform to the policies in the Core Strategy • Does not conform to the NPPF

The plan has not met the principles of LCC’s community involvement:

Early contact

• Residents of villages affected by MX2-39 only became aware of the revised Site Allocations Issues & Options plan in July 2016 • Consultation was only announced in mid-September 2 weeks prior to the beginning of the consultation period • Residents were not informed of the commencement of the consultation period; the general public were not made aware. • M&G, not LCC,(LCC did not circulate information) circulated a leaflet advising about information sessions. Some of the information was incorrect, giving the date of a session as November 4th a mere 3 days before the close of the consultation period. • A letter to residents in local villages, again not from LCC but from ward councillors, was delivered on Oct 15th and 16th; three weeks before the end of the ‘six week’ consultation.

Access to information • Only one set (of many documents) is available in each local library • Information online is not available to all residents • LCC delivered only two information sessions; one in Barwick and one in Wetherby. Residents relying on public transport would find it difficult to attend these sessions. The date of the session in Wetherby was given as Nov 4th in M&G’s publicity material. The only information session delivered in Aberford was by M&G.

Reducing barriers

• LCC SCI states that ‘opportunities will be provided to consult those parts of the community which do not normally get involved in planning issues’ but fail to consult the local parish councils on the SAP

Appropriate methods

• The parish councils have not been consulted • The only information session held in Aberford was by M&G Real Estates • Providing information online is not an appropriate way to ensure all residents are informed.

Despite all the above issues a request for a two week extension to the consultation period was denied.

Green Belt

The Parlington Estate is a key component of the Leeds Green Belt, serving an important function in ensuring the city and its satellite communities do not merge with consequent loss of greenfield land. It is a particularly important part of the Green Belt due to it containing Grade A agricultural farm land and several Grade II and II* listed buildings. It is a designed landscape unchanged over centuries. The proposed site contains Ancient Woodland and any change of status would damage this, and a designated site of Special Environmental and Geological Interest (SEGI) and is an integral part of the Magnesian limestone Green Infrastructure corridor as defined by Natural England and incorporated within Leeds City Councils’ Adopted Core Strategy; Building a new town at MX2-39 a few hundred metres from Barwick and Aberford is a gateway for future encroachment and the merging of Barwick, Aberford and Garforth. The NPPF and Leeds City’s own core strategy state that one purpose of Greenbelt is to stop communities from merging. The proposed arbitrary extents of MX2-39 in our view, are not defensible planning barriers and as such provide a vehicle for encroachment, coalesce and merging in the future. Land to the east of Wetherby currently locally designated as 'rural land' is not an equivalent or appropriate substitute for the prime green belt of Parlington. The greenbelt land containing MX2-39 should not be subject to a selective, isolated greenbelt review, and full and sequential review should be taken on all greenbelt in the HMCA area and the whole of the principle authority area. LCC has identified only 6% of its allocation target from brownfield land for the Outer North East Area. This is not consistent with its own register of available brownfield sites which identifies 30,000 homes as being deliverable on brownfield sites (45% of the 66,000 identified in its own core strategy). MX2-39 is unsound as any sequential test would propose brownfield, then greenfield before Green Belt.

The plan is unsound and contravenes the National Planning Policy Framework.