Ref: PNW00352 HMCA\Topic: Outer North East

Subject: Site in the plan

Site: MX2-39 - Estate,

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 . 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--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 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 (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 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 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 . 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). Using the proposal’s own modelling (flawed as it is) this assumes that there would be a single entry / exit point to the development which from which 97% of the traffic flow (up to 5,480) vehicles could make use of this junction on a daily basis. This is not sustainable based upon the current highways infrastructure. In addition, the south west corner of the proposed development is designated for employment use, thereby increasing the likelihood of commercial vehicles making use of the highway thereby causing further disruption and associated pollutants. The current proposal indicates that the road (B1217) from the junction may require upgrading to dual carriageway. This is unsustainable given the existing accident blackspot . Last year according to the Parish Council there were 17 accidents along the B1217. In the same time frame fatal accidents on minor roads across the country have risen by 2 per cent over the same timeframe. Across the entirety of the , where there is over 9,000 B roads there were only 896 fatal accidents on similar classified B roads.

There would be adverse implications of expanding the carriageway given the current site constraints and the existence of the SSSI at Hook Moor on the south side of the carriageway. In order to mitigate some of the above there are other potential access points that are indicated in figure 5.3 of the development proposal. Any development of these however would call into question the level of impact on the local historic villages of Aberford and Barwick in , a key criteria in the maintenance of green belt land under paragraph 80 of the NPPF thereby calling into question the validity of the proposal. As it stands at the moment this proposal would destroy approximately 19 football pitches of irreplaceable stunning green belt land simply for the car park space alone. This proposal will obviously lead to a significant increase in disturbance to the wildlife from the increase volume of traffic.

Public Transport The current rail provision at Garforth and East Garforth is under significant pressure with current volumes. The car parking capacity of Garforth station is full at any point on a working day prior to 7:45am with trains into Leeds being overly busy (there is only room to stand). This is recognised and reported at the station. The proposal references the electrification of the Trans Pennine route to provide additional capacity. This has previously been paused and was only resumed as a proposal with a significant delay with no guarantees as to when or whether it will take place. Site MX2-39 is located in the Outer North East HMCA as identified by Leeds 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 The NPPF makes reference in paragraph 72 to the importance of the provision of schooling to the proposed development. It is not sustainable for this to be supported by the current school provisions in the neighbouring villages of Aberford and Barwick in Elmet or East Garforth primary (in the case of primary school places) or the secondary school provisions of John Smeaton and Garforth Community College. This would require significant planning to construct new school places. Again this is alluded to only in terms of a contribution within the proposal and insufficient plans have been provided by Leeds City Council as to where the additional requirements for school places would be provided. There are site constraints in the expansion of the local schools and only a contribution towards entries, rather than infrastructure costs, outlined within the proposals. Additionally, the NPPF requirements to promote the retention and development of local services would come under pressure in relation to the local school places. There has been no consideration of the impact on the local schools in terms of entrants or the viability of their schooling provision outlined either in the proposal document or the broader plan from Leeds City Council.

Issue: Local services The NPPF makes reference to a number of requirements in relation to local facilities / services namely in paragraph 28, “promote the retention and development of local services and community facilities in villages, such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship.” and paragraph 70 which states that, “ensure an integrated approach to considering the location of housing, economic uses and community facilities and services.” There does not appear to be any integrated approach to this with the current development proposal making loose reference to ‘contributions’ towards community facilities such as health and schooling. These are not within the control of those making the proposal and there has not been adequate consideration from Leeds City Council as to how these requirements would be met. The infrastructure in the local communities would not be sufficient to support the scale of development proposed. For example the healthcare facilities in Garforth , Aberford and Barwick in Elmet would not be sufficient to satisfy the additional demand created by this proposed development.

These proposals will significantly increase the population density of the local area. According to the government consensus http://www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/populationestimates/bulletins/populationandhouseholdestimatesfortheunited kingdom/2011-03-21 this states that there is on average 2.3 individuals per household. By building 5,000 houses, Parlington will become three times more densely populated area than for example the centre of Hull and Leeds, areas that like most major struggles with in the inner-city challenges associated with being densely populated namely deprivation, crime, and vandalism. There is no evidence within the plans of how this will be managed long term, and how the impact of this incredibly dense population can possibly be sustainable.

The current plan and the associated local planning from Leeds City Council does not adequately address the needs of the local population. The council have also failed to offer and communicate any valid reason for why there is a need to build the proposed 5,000 house on one site. On discussion with several councillors they have verbally suggested that this is because they are concerned about impact of several smaller build would have on the rural nature of villages in North East Leeds. It was claimed that by building on one site the rural nature of villages would be protected elsewhere. However this proposal of creating an urban landscape across current irreplaceable land also prevents essential growth in surrounding villages. I believe that all of the villages in the North East sector of Leeds would benefit from multiple smaller builds which would enable the villages the opportunity of accessing and improving their local amenities whilst maintaining their rural characteristics. Many of the local communities have suffered from a steady decrease in amenities over the years due in part to the lack of appropriate growth and increasing reliance on cars, and the urbanisation outlined in the Parlington proposal would further prevent any appropriate growth in any of the surrounding local villages. Any small build projects would need to be soundly planned, this proposal is unsound, built in the appropriate place that benefits the community and doesn’t destroy it, neither is achieved through this proposal. Issue: Greenbelt According to the National Framework Policy once Green Belts have been defined, local planning authorities should plan positively to enhance the beneficial use of the Green Belt, to retain and enhance landscapes.

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. I do not believe that these ‘exceptional circumstances’ have 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 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 Colton and Seacroft. One of the concerns is that by reducing the overall level of Green Belt land across Leeds will have potential significant impact upon the physical and mental health of all of the citizens of Leeds, most particularly individuals living in Garforth, Barwick-in-Elmet and Aberford. This proposal will significantly reduce the opportunity of these communities to access this Green Belt land and the associated restorative effects of greenspaces for both mental and physical health. The National Planning policy framework defines Sustainable as ensuring better lives for ourselves don’t mean worse lives for future generations. I do not believe that this proposal demonstrates this. Sustainable development is required to also consider our wellbeing to which the natural environment plays such a crucial role.

2. To prevent neighbouring towns merging into one another – this proposal will have the effect of merging Barwick in Elmet, Aberford, the proposed Parlington village and 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 Garfroth and 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 have 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 that could take a significant proportion of housebuild without recourse to destroy existing green belt land. I do not believe that the council have demonstrated why normal planning and development management policies including building on brownfield sites and derelict buildings has been sufficiently considered.

The NPPF is also quite clear in relation to the redesignation of green belt or assignment of new green belt land. Paragraph 82 states that, “The general extent of Green Belts across the country is already established. New Green Belts should only be established in exceptional circumstances,” and in paragraph 89 that, “A local planning authority should regard the construction of new buildings as inappropriate in Green Belt.” This proposal will irreplaceably alter the landscape character of the area. Furthermore land of such exceptional value cannot simply be relocated without a significant down grading in the quality of green belt land for several hundred years. I do not believe that these ‘exceptional circumstances’ have been established when other brown field sites such as those at Thorpe Arch have been overlooked in preference of using green belt land. I believe that the size and scale of such a development dis-empowers local population I believe that we have a duty of care to protect this landscape for future generations.

This proposal does not take into account of the different roles and character of different areas, it does not promote the vitality of our main urban areas, protecting the Green Belts nor does it recognise the intrinsic character and beauty of the countryside and supporting thriving rural communities within it as per principles 5 and 10 of the NPPF.

The last survey undertaken across the Parlington estate, described part of Parlington Hollins as a wet woodland. Wet woodlands are one of the rarest woodland habitats in Britain. The precise extent of wet woodland remains unknown, but estimates ranges from just 25,000 and 35,000 ha (http://www.swog.org.uk/wp-content/uploads/2008/12/creating-wet-woodlands-1.pdf). Fragments of ancient wet woodland are particularly rare which is what Parlington Hollins is. Wet woodland experience waterlogged conditions for at least part of the year, so are sensitive to changes in climatic conditions (publications.naturalengland.org.uk/file/4974561491681280) They are woodlands which are frequently or seasonally wet either through the action of flooding from streams or rivers. The fragile ecosystems that ancient wet woodlands support are of national and international importance supporting a number of priority species including the Otter, Lesser spotted woodpeckers, Woodcock and Willow tit, all of which have been seen in the Parlington Hollins woods. Ancient wet woodlands provide a great many additional microhabitats for other species. The sheer age of the habitat itself and the absence of major physical disturbance also gives rise to a continuum of conditions which favour a variety of rarer species. In particular, this would include species which are either slow to establish and, or which require very particular conditions in order to survive. This means that ancient woodlands have potentially far greater biodiversity than more recently established woodlands.

Across the UK the number one reason why this fragile habitat has declined is urban development and subsequent alterations in water tables and air pollution which is associated with proposed building projects and particularly adversely affects mosses, liverworts and lichens. Maintaining wet woodland has been shown to directly lead to an improvement to water quality, and reduced public water treatment costs. There is also an important role for planting woodland along urban river corridors to reduce thermal stress to fish and freshwater life (http://www.forestry.gov.uk/pdf/SynthesisUKAssessmentfinal.pdf/$FILE/SynthesisUKAssessmentfinal.pdf) The UK Government has set itself challenging and legally binding targets leading to an emissions reduction of 80% of 1990 green house gas emissions by 2050. A contribution to the targeted reductions in atmospheric GHG concentrations can be achieved by increasing the rates at which the gases are removed from the atmosphere through biological uptake and carbon storage achieved with the protection of habitats like wet woodlands (http://www.forestry.gov.uk/pdf/SynthesisUKAssessmentfinal.pdf/$FILE/SynthesisUKAssessmentfinal.pdf). The Stern Review commissioned by the UK Government in 2006 similarly concluded that curbing deforestation was a highly cost-effective way of reducing greenhouse gas (GHG) emissions and that action to preserve woodland areas was urgently needed.

Woodlands provide a net sink for the reduction of CO2, i.e. they remove CO2 from the atmosphere. For example in Scotland show average annual removal from the atmosphere of around 24 tonnes of CO2 per hectare per year. Comparable measurements made in an oak forest in southern indicate that it removes 15 tonnes of CO2. It is believed that one of the main differences between these two values is associated with the population density of the areas. By dramatically increasing the population density as outlined in this proposal the effectiveness of the any remaining woodland to help absorb CO2 would diminish. In Scotland, where woodland cover is higher than in the rest of the UK and the population density is smaller, the removal of CO2 by woodlands currently accounts for around 12% of green house gas emissions. However, the situation is very different in England, where the woodland carbon sink equates to less than 1% of total GHG emissions (http://www.forestry.gov.uk/pdf/SynthesisUKAssessmentfinal.pdf/$FILE/SynthesisUKAssessmentfinal.pdf) In its White Paper, the UK Low Carbon Transition Plan (2009), the Government identified woodland protection and creation as a cost-effective way of fighting climate change and recognised the urgency of action to supporting tree-planting and protection initiatives. Climate change projections (UKCP 2009) use model simulations to provide probabilistic estimates of future climate. These indicate that the UK climate will continue to warm substantially through this century; that there will be changes in rainfall patterns and its seasonal distribution; and that considerable regional variations can be expected. Therefore there is a need to build communities that can mitigate the impacts of these projected changes and to tailor adaptation measures to local conditions. Protection of existing ancient wet woodland like the Parlington estate are essential for helping protect communities further downstream.

Issue: Conservation and heritage The local villages of Barwick in Elmet and Aberford, as well as the Parlington Estate itself, are of crucial local heritage. The Estate itself consists of 6 grade II listed buildings including the historic Triumphal Arch which is unique in its proclamation of support for American Independence. The plan does not provide any sufficient information as to how these would be preserved making no mention of the way in which they would be impacted by both the construction and the ongoing impacts of 5,000 households in the local vicinity. In addition, the park at Parlington has been utilised historically for a number of purposes including being used by the army during the First and Second World Wars. There are signifcant structures, built during the Second World War, that were constructed by the soldiers of No.3 Vehicle Repair Depot, part of Royal Army Ordnance Corps. The local area, including the region around and within the Parlington Estate have been of historical and archaeological significance. Significant archaeological finds have been made in the local area including an anglo saxon, from the ninth century, ring that is currently housed in the inscribed with the name of Æthelswith the sister of King . In more recent times the ‘ hoard’ comprising of numerous anglo saxon gold artefacts and described as, “a jewel in the crown of the museum's collection” was found in Aberford only a matter of a few hundred metres from the boundary of the proposed development. With these and historic events such as the battles of Towton and Bramham Moor in the vicinity it would be appropriate for a full archaeological evaluation to be performed of any proposed site prior to any development proposal approval. The historic village of Barwick in Elmet is situated at the heart of the historic kingdom of Elmete and boasts not only the second tallest Maypole in Britain but an iron age fort and subsequent motte and bailey site of Norman construction. Aberford has significant cultural heritage including the Aberford Almshouses built in 1843 by the accomplished architect George Fowler Jones at the request of the Gascoigne sisters. Both villages also contain historically significant local architecture that is subject to heritage protection. 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. Overall the UK has less than 8.7% of its territory is woodland. This makes the United Kingdom one of the least wooded areas in Europe. Across Europe, woodland accounts for 44% of all the territory. 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.

As previously stated the Parlington Estate is home to a diverse array of local flora and fauna contributing hugely to the biodiversity of the area. The most recent (1998) ecological survey indicating the presence of many species crucial to the local ecosystem including (but not limited to): • Badger • Otter • Grass Snake • 3 Different Bat Species. • Over 53 different species of bird. An ecological survey has not been carried out since that time and did not form part of the proposal submission. It is highly likely given the changes that have been made to the local area and the reintroduction of native species in the last 18 years since the survey much will have changed in the area. Previously the area was a stronghold for water voles. It is possible that they are still present, but if not it is indicative that with appropriate management this could once again be a site of even greater environmental importance than it is now. This development would end this opportunity. Furthermore the greater crested newt is acknowledged (within the proposal documentation) to having breeding populations in the ponds at Hawk’s Nest Wood, less than 50m away from the proposed development site and at Becca Hall also within the village of Aberford – the Parlington Estate is located geographically centrally between these two sites making their presence more likely. The Natural England Standing Advice on ancient woodland describes how activity close to such precious habitat can have an detrimental impact upon the ecology of an area, its biodiversity and its fragile inter-related eco-systems despite any attempts measure to prevent this from happening. The neighbouring Hook Moor is a Site of Special Scientific Interest (SSSI) due to the presence of “Orobanche Reticulate” which is a protected species and is found only in Yorkshire within Britain, is nationally scarce and, because of its localised distribution, is additionally classified as ‘near threatened’. It is largely restricted to the narrow band of magnesian limestone within Yorkshire and is subject to legal protection under Schedule 8 of the Wildlife and Countryside Act 1981 (as amended). Given that the proposed development is less than 50m from the perimeter of Hook Moor and has a magnesian limestone ridge as part of its topography there is a high chance that the Orabanche Reticulate could be found to be a native species within the development area. The species of birds that have been regularly spotted in and around Parlington includes the song thrush. (which has suffered a nationally reduction in numbers of more than 50% since 1970), greenfinch (which has suffered a national reduction in numbers by approximately 39% since 1970), marsh tit (which has nationally reduced in numbers by more than 70% since 1970) lapwing (which has nationally reduced in numbers by approximately 37% since 1970) and the tree sparrow (which has nationally reduced in numbers by approximately 90% since 1970) https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/471745/UK_Wild_birds_1970-2014__2_.pdf)

In the UK, bats and their roosts are protected by law whether occupied or not. It is illegal to damage, destroy or disturb any bats or roosts without having taken the necessary precautions. A roost is defined as any place that a wild bat uses for shelter or protection and the roost is protected whether bats are present in it or not. This proposal places all three species of bats regularly seen in the Parlington estate and their roosts at significant risk of harm. We are only just beginning to understand the enormous benefit of Green Belt land and therefore the need to protect it, especially ancient woodland. Once this irreplaceable land has been destroyed it will be lost forever and cannot simply be moved without a huge environmental cost being paid. As previously outlined in https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences, there is some specific guidance regarding the protection of ancient woodland. I believe that this proposal completes contradicts these guidelines. This document state that plans should not • polluting the ground • changing the woodland’s water table or drainage • damaging archaeological features or heritage assets • damaging or killing veteran trees or parts of them • damaging roots and soil, as well as the understorey (all the vegetation under the taller trees) It clearly states that development adjacent to ancient woodland can have the following effects and the species they support: • compacting the soil around tree roots • breaking up or destroying connections between woodland and other habitats • reducing the amount of semi-¬natural habitats (like parks) next to ancient woodland • changing the water table or drainage • increasing the amount of pollution, including dust • increasing disturbance to wildlife from additional traffic and visitors • increasing light pollution • increasing damaging activities like fly¬tipping and the impact of domestic pets • changing the landscape character of the area Planning authorities and developers should start by looking for ways to avoid the development affecting ancient woodland or veteran trees. I believe that the only realistic way of achieving this is by moving the scheme to an area of lower environmental value, for example non-green belt. Many of the threats outlined above come from drainage issues, infilling due to urbanisation like this project, poor water quality, caused by nutrient enrichment or pollution, due to population density (https://www.glasgow.gov.uk/CHttpHandler.ashx?id=31952&p=0) This proposal will significantly increase the recreational use of the woodland, which has been shown to directly lead to a decline in the biodiversity value of any woodland. The build will significantly increase the level of pollution, including dust, noise and light, into the woodland and surrounding green belt area. These plans will lead to a directly to the existing woodland and green belt land fragmenting further as the existing connections are further destroyed further disconnecting and isolating the wide variety of species that are supported by the Parlington estate.

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 PDP03995 Ref Title mr Title Forename doug Forename Surname bodey Surname Address 1 Swan Mill House Address 1 Address 2 Aberford Address 2 Address 3 Address 3 Town Leeds Town PostCode LS25 3Bh PostCode