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PNW00352 Outer North East MX2-39

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PNW00352 Outer North East MX2-39 Ref: PNW00352 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: 1) drastic reduction in the number of houses built. 2) to adhere to the agreed guidelines of not building on green belt land. 3) change of location to one of significantly lower environmental and heritage value and lower flood risk to surronding villages. Issues Issue: Other - Flood Risk I believe that it is important to learn from some of the contributing factors in recent local flooding events including most notably the damaging impact of the floods In winter 2015 upon the town of Hebden Bridge. One of the key components in this disaster was the removal of upstream woodland, leading to a significant reduction in the levels of water being naturally absorbed subsequently causing the water to run straight down into the town. This was in stark contrast to the town of Pickering which having suffered been flooded four times between 1999 and 2007, the last disaster costing £7 million of damage (http://www.independent.co.uk/news/uk/home-news/uk-flooding-how-a-yorkshire-flood-blackspot-worked-with-nature-to-stay-dry-a6794286.html). One of the major implementations was the planting of 29 hectares of woodland as part of the natural defences which helped slowed the flow of water and prevented flooding. Since its implementation Pickering has not suffered from flooding. These events are highly suggestive that natural flood defences, including the woodland, arable land and flood plains found in Parlington estate are the most effective. The area of the Parlington Estate is vital as part of the local ecology and flood protection creating natural protection and regulation of water run off into the local Cock Beck and River Crow thereby protecting the local villages of Aberford and Stutton from flood risk. Flooding has already occurred in recent years in 2000, 2008 and 2014, and will increase in likelihood as effects of climate change develop. The attached photograph indicates some of the flooding on the Estate in the winter of 2015/16 (despite it being designated in Flood zone 1). By building over this site will introduce a huge volume of hard standing, including roadways and housing which will ensure that the water run off will significantly affect the way in which water is deflecting to watercourses flowing into the local water systems. This loss land that was utilised by the Parlington Estate as an area for flood mitigation that will be lost as part of this development. This will have a dramatic impact upon the water levels in this estate and therefore subsequently altering the water levels in the vulnerable surrounding villages and villages further downstream. The central area of Aberford, for example, around the Cock Beck is already classed as flood Risk 3. By replacing this natural defence with such a significant increase in the levels of hard standing I believe that these plans will not meet the increasing challenge of climate change this risk of flooding in the local area will continue to rise. Within the plans there is no process put in place to mitigate against the increasing flood risk associated with the challenge of climate change, throughout the lifetime of the project. The NFFP states that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall. Therefore I believe that these plans do not manage this not only on-going but increasing risk sufficiently and are unsustainable long term and I believe the council needs to consider more sustainable location with associated with reduced flood risk. It is also worth noting that both the River Crow and Cock Beck are tributaries to the River Wharfe with their confluence occurring at Tadcaster, scene of severe flooding and the destruction of the historic road bridge in the winter of 2015/16. Whilst the area itself is within flood zone 1 and therefore designated as a low probability of flooding it is the protection provided and the additional water run off that will have a significant impact on the surrounding area. I believe that this is clearly in contravention of the 9th planning principle. The NPPF states that it must be “demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk, informed by a Strategic Flood Risk Assessment where one has been prepared.” I do not believe that the benefits of so dramatically increasing number of houses into the local community outweigh such an obvious risk of flooding. Altering the water tables in this fashion will have an irreversible damaging impact upon this fragile landscape. This is acknowledged in the proposal (paragraph 5.6.15) which states that, “Rainwater that does not infiltrate would need to be discharged via attenuation facilities to Cock Beck, which runs along the western and northern boundary, with flow restricted to greenfield runoff values. This means that balancing, detention or retention ponds should direct their outlets to the Cock Beck”. It is also recognised within the proposal that , “The proposed development will introduce some impermeable areas, reducing the greenfield areas that currently permit rainwater to infiltrate into the ground. This will increase rainfall runoff from the site.” As noted above this will have a considerable impact both on the flood risk to the villages of Aberford and Sutton as well as into the river Wharfe at Tadcaster. There are insufficient measures indicated in the proposal that would mitigate this increased risk for areas that are already susceptible to flooding – such as those areas identified as zone 2 and 3 flood zones in the centre of Aberford as determined by the environment agency. Paragraphs 99 to 104 of the NPPF are clear in their consideration of flood risks and the building on areas that are of use in the mitigation of flood risks. I do not believe that either the sequential or exception tests have been adequately applied in relation to the ‘downstream’ impacts as other brown field sites which would not have these related issues due to the topography of the land and its current use. Issue: Highways and transport The NPPF makes reference in paragraph 162 to local planning authorities working with other authorities and providers to, “assess the quality and capacity of infrastructure for transport”. There is no evidence that this has occurred. In relation to transport: The current motorway junction at Hook Moor junction 47 is not able to take additional capacity at peak times. At rush hour this can be found to be ‘backed up’ from the junction all the way down the hard shoulder and onto the motorway. As part of the assessment process I would ask that you check the number of times that the overhead signage approaching the motorway junction has been used to state “Queue on Slip Road” (this data will exist) as it is a regular occurrence. The proposal to build up to 5,000 new homes at the Parlington development will create a significant increase in the volume of traffic utilising this junction. Altering this slip road is beyond the scope of this proposal, again making the project unsound. 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. Using a conservative estimate based on the department for transport statistics provided by their national travel survey indicates that there is an average of 1.13 vehicles per household in the Yorkshire and Humber region. This would result in an additional 5,650 vehicles in use as part of the proposed development (the likely number is much higher).
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