Response to the Harrogate Borough Council Development Plan From North Rigton Parish Council Site references: H45, H74, which already have planning permissions. H49, H46, H70, H36, H65, H56, H51, proposed development sites in the HBC draft local plan This submission is made by North Rigton Parish Council which represents 460 residents of the parish, located 2.5 miles south west Harrogate. North Rigton Parish Council does appreciate the need to plan for further housing in the borough of Harrogate, but the latest proposals provide figures which are unproven, unsafe and therefore unsound. HBC has failed to investigate other alternatives in depth but has opted either for more convenient development on land it “inherited” or via landowners wanting to profit from the sale of low value agricultural land for housing. NOT POSITIVELY PREPARED - Housing & Infrastructure • There is little additional infrastructure provision to the West of Harrogate where it is proposed that in excess of 6,000 houses are to be built. The bus and rail routes are to the East of the town centre, supermarkets are also to the East. The two secondary schools in the West are full and access to the other secondary schools in the East will be via the town, and school buses are unlikely to be provided for this travel necessitating in parents driving through the town to gain access. The lack of a suitable road network doesn’t seem to have been considered. • Traffic from the sites near Otley Road would regularly depart from that area towards Leeds and Bradford and inhabitants from around those cities will continue to make the reverse journey to work in Harrogate’s tourist industry; hotels, conference and exhibition trades. • On HBC’s Sustainability Appraisal there is little regard for traffic currently and projected to run through the areas of Burn Bridge or North Rigton. North Rigton regularly DOES NOT FEATURE ON HBC MAPS. This makes a mockery of the whole appraisal as it is deemed not to affect these places when residents of these villages know it does. The appraisal only looks at the proposed sites in isolation as if there were no other external influences with traffic flow or gridlock. A separate traffic model and risk assessment for the whole area is an absolute necessity with terms of reference defined by residents rather than planners who have assiduously ignored the potential overall effect. North Yorkshire County Council in conjunction with HBC applied for a government grant for road upgrades associated with the draft Local Plan for the West of Harrogate. The monies were allocated in the Autumn of 2017. The Chairman of NY Highways committee, Don McKenzie, proudly and publicly announced this allocation of funds, specifically for the upgrades to traffic lights at the junctions, and a cycle lane on Otley Road, which was welcomed by residents. However, at no time did he indicate that NYCC would be seeking to upgrade two village routes (one through Beckwithshaw and North Rigton, the other through Burn Bridge), identified as “rat runs” There has been no public consultation on this suggestion, in fact the only reference was in a paper entitled “West Harrogate Scheme” with the proposal being in an annex to the document. • There seems little in the draft Local Plan and the NYCC West Harrogate Package, to address the capability of Harrogate and the surrounding areas to cope with the expansion envisaged. If just the Harrogate houses are built, that's a 20% increase in the size of the town. That won't just cripple Harrogate, the extra traffic will destroy all the towns and villages you have to drive through to get anywhere - Burn Bridge, Pannal, North Rigton and more. Harrogate is so poorly connected. In every direction the roads are just not equipped to cope with the existing traffic let alone 20% more. • Skipton Road - once named Britain's most dangerous road and often closed at Blubberhouses. • Harewood Bridge A61 to Leeds - often closed and where buses and HGVs are unable to pass. • Harewood Bank A61 to Leeds- accident blackspot • The approach to Spofforth on the Wetherby Road, • The narrow twisty ‘rat runs’ through Kirk Deighton, Burn Bridge, Pannal, North Rigton and Haggs Road to Spofforth. • The train service is also overloaded and is unlikely to be improved without major financial funding. None of the proposed developments in western Harrogate are in reach of the rail services without a car journey. • Specifically, from the point of view of North Rigton Parish Council, the minor road between Beckwithshaw and North Rigton has a constricting bridge necessitating “give way to oncoming traffic” (not formally signed as such) In addition, there are high exposed stretches and steep gradients, there is a steep effectively single-carriageway on the approaches and through the main street of the village, and areas with no pavement for pedestrians. This road and similar minor roads to the west of Harrogate are also used by horse riders. • These roads are already hazardous without the addition of potentially hundreds or thousands more vehicles. • The Plan has not been positively prepared and there is no reference to infrastructure other than to an “unavailable” infrastructure plan • It is not justified as it is not based on factual evidence but upon aspirational thinking and opportunistic land availability that isn’t supportable. • National Planning and Policy guidelines currently indicate the need for 395 homes each year, not the 669 suggested by Harrogate Borough Council. • The requirement for 669 houses per annum does not account for the shortfall already accumulated from the start of the plan period so the actual number has become 765 houses per annum to meet the total target during the plan period (HBC quote 765 in para 10.30 of the plan but in para 10.32 the number is 723 – such discrepancies can make a large difference when planning over such a long period). • Harrogate produced one document issued in June 2016 stating that the council needed to build 11,500 houses in the next 20 years. A year later they wrote another document stating 15,000. What happened in that year to warrant a 30% increase? (The only significant event in that year was the Brexit vote. The second document does mention Brexit, but only dedicates one small paragraph to it - in summary "Brexit changes nothing") • The previous HBC plan was dismissed by the Planning Inspector in 2014 because of the lack of infrastructure in the plan. Nothing has changed in the area to the West of Harrogate. There are no new roads, no rail links and no plans for new bus links. The only plan on offer is an upgrade of traffic light junctions to aid the flow of traffic, a new roundabout on the A61, and a cycle lane from these developments to the town centre. Cars and other vehicles will continue to be the major form of transport to and from the housing developments and business areas planned, and the likelihood of those people living and working locally is not in the control of HBC despite its allocation of additional business land in the area. All of the supermarkets, health care and other retail provision are on the eastern side of Harrogate. NOT JUSTIFIED: • Housing (and commercial) developments to the west of Harrogate (and specifically those listed above) critically lack the infrastructure to support them and will inevitably result in a significant increase in traffic travelling through North Rigton on rural village roads. The plan for south west Harrogate is inappropriate when sites, some brownfield, to the immediate east and west and north of the A1 provide alternative development opportunities with existing infrastructure, and are therefore a better fit with HBC objectives. • A Strategic Environmental Assessment (SEA) should have been undertaken that examines the cumulative impact of multiple sites in a single settlement. HBC has only carried out single site sustainability appraisals for Primary Service Villages • Whilst HBC appears to have cooperated with Leeds City Region it has ignored the fact that Leeds City Region Strategic Economic Plan 2016-36 doesn’t identify Harrogate for housing growth. In fact, Leeds City reduced its housing need by approximately 30%, so why does Harrogate persist with its unrealistically high target? NOT EFFECTIVE: With particular reference to the developments to the West of Harrogate which constitute a small-town equivalent. Many of its aspects are undeliverable and it does not adhere to the National Planning Policy Framework as set out by the Government. • HBC Housing Strategy 2015-20 doesn’t address the real issue of affordability which can only be addressed by building housing that remains permanently outside the open market. – Harrogate Borough Council aims to deliver 40% affordable houses in its plan. This target may be desirable but is not achievable with the average house price in Harrogate being 35% higher than the North Yorkshire average. The Council qualifies its aims with the statement: “subject to viability” • There will not be sufficient resources available to deliver the level of construction proposed during the plan period in terms of funding, materials and labour (especially after Brexit) • The lack of infrastructure, and of a cogent, fully costed Infrastructure Delivery Plan, means that the proposed development may not be able to be completed. The NPPF (para 177) required there to be a reasonable prospect that planned infrastructure is deliverable in a timely fashion therefore infrastructure policies should be developed at the same time as the Local Plan. NOT CONSITENT WITH NATIONAL POLICY: • It would appear that none of the objections made by residents in the 2016 consultation have been taken into account. Quote: “While the council is required to develop a Local Plan that reflects the views and aspirations of local communities across the district (both residential and business) …” The 2017 November Consultation Statement shows that only a handful of amendments have been made to the plan out of the thousands of responses received.