Hull Local Plan: Preferred Options
DRAFT JUNE 2015 Hull Local Plan: Preferred Options
1 Introduction 6 What is this? 6 What is this consultation? 6 How to respond 6 Part 1: this Draft Policies Document 7 Part 2: Policies Map 7 Part 3: Inset Maps - Draft Site Allocations 8 Part 4: Inset Maps - Draft Area Designations 8 Call for sites 8 Sustainability Appraisal 8 Evidence base 8 Presumption in favour of sustainable development 9 Duty to cooperate 9 Area Action Plans 10 Waste and Minerals 10 Marine Planning 10 Next steps 11 2 Context 12 Hull today 12 City Plan 18 Hull and East Riding Joint Planning Statement 19 Humber LEP – Strategic Economic Plan 21 3 Hull: The Energy Port City 23 Where we want to be: Spatial Vision for Hull in 2030 23 How do we get to where we want to be: Strategic Priorities 23 Infrastructure & Delivery 26 Enabling Delivery 27 Viability of Development 27 Community Infrastructure Levy 28 Evidence base sources 30 Key Diagram 30 4 Climate Change 32 Introduction 32 Adapting to climate change – making the city safe and 32 resilient Mitigating climate change – moving to a low carbon future 34 5 Economic Growth 38 Introduction 38 Predicting future employment land requirements 39 Main employment areas and identified sites 41 Future use of land within designated Employment Areas 48 University of Hull 52 Supporting evidence 53
DRAFT JUNE 2015 Hull Local Plan: Preferred Options
6 Housing 54 Introduction 54 Housing demand 54 Housing land supply 56 Type and mix of housing 67 Housing on brownfield land 69 Affordable housing 70 Specialist housing 71 Houses in multiple occupation 72 Traveller provision 75 Designing for Housing 76 Density 77 Housing space standards 78 Residential gardens 81 Residential extensions and alterations 82 Inclusive housing design 83 Supporting Evidence 86 7 City Centre 89 Introduction 89 Defining the City Centre 89 Shops and Services 92 Leisure and Tourism 104 Office-based businesses 107 City Centre Living 109 City Centre development sites 110 Supporting Evidence 115 8 Shops, Services and Community Facilities 116 Establishing a centre hierarchy 116 Defining the extent of centres 121 Ensuring the vitality and viability of centres 123 Applying the sequential and impact tests 128 Promoting healthy communities 134 Delivering Community Facilities 138 Supporting evidence 142 Table 8.1: Schedule of centres 144 9 Design and Heritage 150 Design 150 Local Distinctiveness 152 Heritage 154 Energy efficient design 159 Shop Fronts 162 Advertisements 163 Designing Employment Development 165 Supporting Evidence 166
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10 Transport 168 Introduction 168 Sustainable transport 168 Location and layout of development 171 Transport assessments 173 Classified Road Network 174 New roads and road improvements 177 New parking sites 182 City Centre Car Parking 186 Car parking standards 189 Bus transport 193 Rail transport 195 Water transport 199 Walking and Cycling 201 Supporting Evidence 205 Table 10.1: Transport Assessments 207 Table 10.2: Parking Standards 214 11 Water Management 235 Flood Defences 238 Surface Water Storage and Drainage 240 Sustainable Drainage 241 Flood Risk Zones 244 Flood Risk Assessment, Sequential Test and Exception 247 Test Flood Risk Assessments Areas of Search 249 Water Quality 250 Water Supply 252 Waste Water 253 Supporting Evidence 255 12 Open Space 256 Introduction 256 Designating and allocating open space sites 257 Open space standards 261 Protecting open space 265 New public open space requirements 268 Supporting evidence 271 13 Natural Environment 273 Introduction 273 Planning positively for green infrastructure 273 Planning positively for biodiversity and wildlife 279 Tree Protection and Replacement 285 Supporting evidence 287
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14 Environmental Quality 289 Introduction 289 Atmospheric Pollution 289 Land affected by contamination 292 Noise Pollution 293 Light Pollution 295 Hazardous Substances 295 Supporting Evidence 298 15 Energy and Utilities 299 Renewable and low carbon energy 299 Wind turbines 305 Utility Equipment 307 Supporting evidence 309 Appendices A Saved Local Plan (2000) policies to be deleted 311 General Policies 311 Managing the Environment 312 Urban Regeneration 313 Natural Environment 313 Built Environment 315 Movement 319 Housing 322 Employment 323 Shopping 324 Community Facilities 326 Tourism 328 City Centre 329 Docklands 331
DRAFT JUNE 2015 Hull Local Plan: Preferred Options
1. Introduction What is this?
1.1 This is the second public consultation of the new Hull Local Plan. The Local Plan is an important document that will be used to determine planning applications in the city. Once adopted, the Local Plan will be used to guide new development in the city for the next 15 years, up to 2030.
1.2 Hull already has a Local Plan. However, it was published in May 2000 and parts of it are becoming out of date. In March 2012 the Government replaced all national planning policy with the National Planning Policy Framework (NPPF). The NPPF and the supporting National Planning Practice Guidance (NPPG) will be used to guide the content of the Local Plan. Paragraph 154 of the NPPF states that Local Plans should be…
…aspirational but realistic. They should address the spatial implications of economic, social and environmental change. Local Plans should set out the opportunities for development and clear policies on what will or will not be permitted and where.
1.3 In order to retain control of its planning decisions, it is important that Hull has an up-to-date Local Plan. Our intention is for the new Local Plan to entirely supersede the old Local Plan.
1.4 If you have an interest in Hull, whether as a business-person, builder, resident, or visitor, then we would like to hear from you. What is this consultation?
1.5 This is a Preferred Options consultation. It sets out the draft planning policies and site allocations that the Council believes are appropriate. It also sets out the other potential options that the Council considered and the reasons why they were not chosen. We are seeking the views of those who live, work, or have an interest in the city, to tell us whether they agree with the options we have chosen.
1.6 The Council ran an Issues and Options consultation in May and June 2014. We have considered all the responses that were made to that consultation, and they have helped inform production of this document. How to respond
1.7 You can comment on any part of the Preferred Options Consultation Document. It comprises of five parts which should be considered together:
Part 1: this, the Draft Policies Document; Part 2: the draft Policies Map;
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Part 3: draft Inset Maps - site allocations; Part 4: draft Inset Maps - area designations; and Part 5: the Response Form
1.8 You can also comment on the Sustainability Appraisal and Evidence Base documents which support the Local Plan.
1.9 The consultation will run for X weeks. The deadline for receiving your responses is XXX.
1.10 You can respond online at: www.hullcc.gov.uk/planning or you can complete the Part 5 paper response form and post it back to us using the following Freepost address:
FREEPOST RSJC-KKBE-ABXZ Planning Policy Hull City Council PO BOX 15 HULL HU1 2AB
1.11 Alternatively email responses to: [email protected] Part 1: this Draft Policies Document
1.12 After this introduction, Chapter 2 sets the context for the plan. Chapter 3 then introduces the overall strategy for the plan. It suggests a vision, a set of strategic priorities and a key diagram.
1.13 The chapters are then based around key themes. Although each theme is dealt with separately, the document needs to be read as a whole in order to understand fully the spatial issues facing the city.
1.14 Each chapter theme follows a similar format. A number of issues are identified and discussed and then options that address the issues are listed. The options try to summarise the range of realistic options that we think are available. The Council then selects its preferred option from the list and presents a draft policy that it thinks is appropriate. In this consultation you can tell us if you agree with the Council’s choice of option, or whether you think another option should be chosen (either from the list or a different option that has not been considered in this document). Part 2: Policies Map
1.15 An important part of the new Local Plan will be the Policies Map (also known as a Proposals Map). This will show the spatial extent of the Local Plan policies. Part 2 of this consultation is a large citywide Policies Map which shows draft site allocations and area designations.
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1.16 The purpose of allocating sites is to promote development in particular places. The Policy Map can also identify areas where it is deemed necessary to limit freedom to change the uses of buildings, and also identify land where development would be inappropriate. Part 3: Inset Maps - Draft Site Allocations
1.17 Part 3 shows the individual site allocations in more detail. We have produced a separate Site Selection Methodology evidence base document which explains how we have selected the site allocations. You are welcome to comment on the Site Selection Methodology as well as the individual sites. Part 4: Inset Maps - Draft Area Designations
1.18 Part 4 shows designated areas, such as Local Centres, in more detail. Call for sites
1.19 The Policies Map shows all the potential new housing, employment, shopping and open space sites as identified by supporting evidence base documents to the Local Plan. If you are aware of any other sites that you consider have potential for new uses over the next 15 years, please let us know by providing basic site details (location / size / potential use) on the response form and head it “call for sites”. We will contact you after the consultation closes for more information about the site and will consider it in the preparation of the Publication version of the Local Plan. Sustainability Appraisal
1.20 A Sustainability Appraisal accompanies this document. This is a legal requirement and it considers the impacts of our proposals, individually and together, in the short, medium and long term. Through this, we also consider the impact of our plans and policies on different groups of people. We are also assessing the impact of our plans and policies on people’s health. Your comments on this are also welcomed. Evidence base
1.21 We have an up-to-date and robust evidence base that tells us about the need for different land uses in the city. These documents have enabled us to produce the content of this document. The main evidence base documents are given at the end of each chapter.
1.22 We are consulting on our most recent evidence base documents at the same time as this Preferred Options consultation. The documents are available to view online at: www.hullcc.gov.uk/planning
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Presumption in favour of sustainable development
1.23 The National Planning Policy Framework (NPPF) introduced the presumption in favour of sustainable development as a key principle in the planning system. For plan-making it means that:
We should positively seek opportunities to meet the development needs of the area; and Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change.
1.24 The two exceptions to this are where:
any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the NPPF taken as a whole; or specific policies in the NPPF indicate development should be restricted.
1.25 It is our intention that the Local Plan will meet the requirements of the NPPF, including the presumption in favour of sustainable development. Documents in our evidence base have been prepared in order to inform us what the needs of Hull are. Where possible we will plan to meet those needs. Duty to cooperate
1.26 We have a legal duty to cooperate when planning for strategic issues that affect a wider area than Hull. Examples of where this is particularly important include:
planning for housing, as the housing market extends beyond the administrative boundary, particularly with the East Riding of Yorkshire Council (ERYC) and the Homes and Communities Agency; flood risk, with ERYC, the Environment Agency and Defra; transport, where we work closely with the Highways Agency and ERYC; economic and employment issues, working with the Humber Local Enterprise Partnership, ERYC, and North and North East Lincolnshire Councils; nature and biodiversity issues, working with the Local Nature Partnerships and Natural England; employment development – as the Hull Functional Economic Area crosses into the East Riding; Conservation and heritage issues - working with Historic England; and Infrastructure issues - working with local water, gas and electricity suppliers.
1.27 The next chapter describes the Humber Strategic Economic Plan and the Hull and East Riding Joint Planning Statement.
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Area Action Plans
1.28 Area action plans (AAPs) are like local plans, but focus in detail on a specific area. Hull has two adopted AAPs. These are for Newington & St Andrews (February 2010) and Holderness Road Corridor (March 2011). Their focus is the regeneration of those areas. They were drawn up during a period when there was considerable funding from the Government for housing market renewal. This is no longer the case, but Hull City Council is still committed to regenerating these areas. There is therefore a need to review these plans. We are proposing to do this through the Local Plan. There are three options available to us as to how we take forward the two area action plans in the context of the citywide Local Plan.
Option A: Keep the Area Action Plans in their entirety and embed them in the new Local Plan.
Option B: Retain some Area Action Plan policies and replace site specific policies.
Option C: Wholly replace the Area Action Plans by the new Local Plan.
1.29 Our preferred option is Option B. This is because the site specific policies are outdated but certain other policies remain relevant.
1.30 In addition, Hull City Council is currently preparing a separate AAP for Kingswood. This area of the city is going through a significant expansion and this change needs to be positively shaped. The Kingswood AAP and the Local Plan will form parts of the development plan for Hull. Our Part 2 Policies Map replicates what will be shown on the Publication version of the Kingswood AAP. The publication version of the Kingswood AAP is due to be consulted on in June 2015, and then submitted to the Secretary of State in the autumn. Waste and Minerals
1.31 We must also plan for Waste and Minerals. We are carrying this work out separately, and are preparing both plans jointly with the East Riding of Yorkshire Council. You can find more information on our website www.hullcc.gov.uk/planning Marine Planning
1.32 The Marine Management Organisation has responsibility for preparing marine plans for the English inshore and offshore waters. This includes the Humber Estuary and part of the River Hull. More information can be found on the Marine Management Organisation’s website www.marinemanagement.org.uk
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Next steps
1.33 The rules for producing a Local Plan are set out in legislation. This consultation falls under Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012. It requires us to invite people and organisations to tell us what the Local Plan should contain. We are then required to consider the representations made in response to this invitation.
1.34 When this consultation is over we will prepare a Publication document. This will be a version of the Local Plan that we consider to be ‘sound’ – that is to say, it is positively prepared, justified, effective, and consistent with national policy. There will be a 6-week public consultation.
1.35 We will then submit the document, along with a summary of all the representations made during the consultation stages, to the Planning Inspectorate. A public examination will take place. If the inspector finds the new Hull Local Plan to be sound or can make modifications to the plan to make it sound, the Council will be allowed to adopt it. Once adopted, the new Hull Local Plan will be used to determine planning applications in the city.
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2. Context 2.1 This chapter outlines the overall context for the Local Plan. It starts by providing a portrait of Hull today (where we are now), it then outlines the City Plan which the Council is using to promote regeneration work over the next 10 years, as well as describes the Hull and East Riding Joint Planning Statement and the Humber LEP Strategic Economic Plan. Hull today
2.2 Kingston upon Hull (Hull) is a city on the east coast of England, sitting on the north bank of the Humber estuary. The city is roughly semi-circular with a radius from edge to centre of approximately 4 miles. The city is compact and highly urbanised: with an area of just 71 sq km and a population of 257,500 (latest ONS estimate), it is the most densely populated local authority area in the Yorkshire and Humber region. The River Hull runs through the middle from north to south, dividing the city into two halves. Industries in Hull have traditionally located around the rivers Hull and Humber, forming an inverted T-shape. These areas are still largely industrialised so in many places the riverbanks are not accessible. However, some waterside areas have been successfully regenerated, such as the Marina and Victoria Dock. Other areas, such as Tower Street on the east bank of the River Hull, are planned for regeneration.
2.3 The continuous urban area of the city extends outside of the administrative boundary, particularly to the Haltemprice settlements to the west. Hull therefore has a close relationship with its immediate neighbour, the East Riding of Yorkshire. The Hull travel-to-work area, which covers the southern half of the East Riding, has one of the highest levels of commuter self-containment in the country. The main reason for this is Hull’s relative isolation: its nearest city neighbour, York, is 40 miles away, and Leeds, the main economic centre of the region, is 60 miles away.
2.4 The Humber Ports complex brings important linkages between Hull and the south bank of the Humber. The relationship between Humber authorities has been recognised by the establishment of the Humber Local Economic Partnership (LEP). Many key public services, such as the police and fire brigade, operate across the whole Humber area. As well as jobs, Hull provides many services – shops, education, healthcare, theatres, cinemas, and sports facilities – for the city and the wider Humber region.
2.5 At the heart of the city is the city centre. A large amount of regeneration has taken place here in the last twenty years. For example, the new transport interchange couples the historic Paragon railway terminal to a modern bus station. This helps promote public transport to residents and provides a good first impression to visitors arriving in the city.
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Hull Local Plan: Preferred Options
2.6 Immediately adjacent to the Interchange is the St Stephen’s Shopping Centre which has been extremely popular with retailers and shoppers since opening in 2007. Built next to St Stephen’s at around the same time are the Albermarle Music Centre and the famous Hull Truck Theatre – these are also popular and are a strong reflection on the value the city places on arts and culture.
2.7 Tourism is important to the city, and the award winning Deep submarium, which sits on the mouth of the River Hull overlooking the Humber Estuary, is emblematic of this. Sport, particularly football and rugby league, are also important to the city, and the KC Stadium was constructed as a home for two of the city’s top-flight teams. These new developments complement the city’s older venues which remain popular, including the Ferens Art Gallery, Hull New Theatre, City Hall, the Maritime Museum, and the Streetlife Museum. The city is proud to be the birthplace of William Wilberforce, and Wilberforce House is an important reminder of the slave trade past and present. The city centre hosts a number of popular festivals every year, including the Freedom Festival, which celebrates the legacy of Wilberforce. With this in mind, it is perhaps not surprising that the city was successful in its bid to host UK City of Culture 2017. It is hoped that this status will propel its role as a visitor attraction.
“A city coming out of the shadows and re-establishing its reputation as a gateway that welcomes the world as it embraces some of the biggest issues we face today.”
Hull’s Vision for UK City of Culture 2017
2.8 For centuries the city has been an important port with strong links to Europe. Today it is the UK’s leading softwood port, and one million passengers travel through the ferry terminal each year. Recently, Siemens has begun building Green Port Hull, an offshore wind turbine manufacturing plant based at Alexandra Dock. This development has the potential to transform Hull’s economic future. The Government recognises the importance of this and has granted Enterprise Zone status in and around the port to encourage complementary businesses and supply chain companies to locate there.
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Figure 2.1 Historic and projected future population (source: Nomisweb.co.uk)
2.9 In addition to the port, the city has many successful industries, including companies that have started locally but have grown to have global significance – these include Reckitt Benkiser, Smith & Nephew, and Croda. The vast majority of the UK’s static caravans are manufactured in Hull and surrounding area. Other industrial sectors that Hull is particularly notable for include logistics, healthcare and bioscience, advanced engineering, and food manufacturing and processing. The University of Hull leads research into many fields that are important to local industries, including wound-care, renewable energy, and logistics. Two new buildings offering prestige office space form the Humber Quays development, which is situated next to the Marina. On the other side of the Marina, work has begun on the construction of C4DI (Centre for Digital Innovation), which will be a hub to support high-tech start-up companies.
2.10 The success of the City of Culture 2017 bid will mean that a number of renovation schemes will go ahead. This work will include investment to transform the public realm, transformation in the city centre, refitting of Ferens Art Gallery and Hull New Theatre, and potentially the construction of a Conference Centre at Quay West. It should be noted some of these schemes, such as the Conference Centre, will be finished after 2017, but are necessary to secure the long-term legacy of the year.
Table 2.1 Employment and education statistics(1)
Hull East Riding Great Britain
Residents aged 16-64 claiming 5.0% 1.8% 2.0% Jobseeker’s Allowance
1 Source: www.nomisweb.co.uk and www.ons.gov.uk/ons/dcp171778_364960.pdf
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Hull East Riding Great Britain
Residents aged 16-64 with no 13.8% 7.3% 9.4% qualifications
Full-time workers gross weekly £432 £525 £521 pay
Table 2.2 Life expectancy(2)
Hull average Worst ward Best ward England
Men 76.6 70.3 82.8 79.4
Women 80.7 76.9 86.5 83.1
2.11 Despite these success stories, the city has a high proportion of jobseeker allowance claimants and is statistically the tenth most deprived local authority area. Residents typically suffer from poorer health outcomes and lower levels of educational attainment than the national averages. To remedy these issues, new health centres have been built across the city and all secondary schools have either been rebuilt or substantially remodelled. Primary schools and further education colleges have also seen improvements. In particular, Hull College has created a Centre for Digital and Green Energy with the intention of providing the necessary skills for the future. Recently it has been announced that the National College for Wind Energy will locate to the Humber region, with sites in Hull being investigated.
Figure 2.2 Population structure (source: ONS Census 2011)
2 Source: www.hullpublichealth.org
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2.12 Hull has a high proportion of small, terraced housing and house prices tend to be low. Although these can be affordable to first-time buyers, people tend to move out of the city when they want a larger, detached house. The result is that Hull has proportionately a large number of younger residents and a lower proportion of older people – the opposite of the East Riding. Significant regeneration work has taken place in recent years to help re-balance the housing stock. To guide this work, Area Action Plans have been prepared for two parts of the city, namely Newington & St Andrews and the Holderness Road Corridor. Despite considerable changes in Government funding, schemes are still progressing in these intervention areas. Other areas, such as Orchard Park and North Bransholme, are now beginning to see regeneration activity. Outside of these areas, the city has a number of desirable residential locations which attract higher house prices. The Avenues and Garden Village are two distinctive areas built in the late nineteenth / early twentieth century. More recently, Victoria Dock and Kingswood have provided a large number of modern homes with attractive surroundings. There is still a lot of land which is planned for housing left at Kingswood and it is anticipated with current build rates that construction will still be taking place in 2030 and beyond. Elsewhere in the city, due to the constrained boundary, land is in short supply, so consideration needs to be given to using it efficiently.
Table 2.3 Housing statistics(3)
Hull East Riding England
Council tax band A dwellings 69% 26% 25%
Local authority owned 22% 8% 8% dwellings
Terraced houses 49% 20% 25%
Average house price (2013) £103,000 £165,000 £247,000
2.13 The city is largely flat and low lying. In recent years a large number of properties in the city have been flooded due to heavy rainfall and from a tidal surge. Unfortunately over 90% of the city is located in areas of high flood risk. However, the city has an extensive green network, based around the rivers, drains, and former railway lines, and includes the internationally important Humber Estuary, and the regionally important River Hull and Holderness Drain corridors. The green network joins together the majority of the city’s open spaces to the wider countryside, providing routes for wildlife, walkers and cyclists. In addition, the city has a good distribution of parks which provide attractive places for recreation and relaxation.
3 Sources: neighbourhood.statistics.gov.uk and www.gov.uk/government/statistical-data-sets/live-tables-on-housing-market-and-house-prices
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2.14 The city is well connected by the road and rail networks. The A63 going west connects to the M62 and the rest of the motorway network. The Humber Bridge, just to the west of the city, forms an important road link across the estuary to Lincolnshire. Trains run regular passenger services south to London, Doncaster and Sheffield, west to Leeds and Manchester, and north to Beverley, Bridlington and Scarborough. A high level freight line runs through the city from the west through to the port. For international travel, there are daily overnight ferries to Europe, and Humberside Airport (in North Lincolnshire) offers several flights a day to Amsterdam.
Table 2.4 Destinations from Hull
Journey time by train Distance by road
Beverley 15 minutes 10 miles
York 1 hour 40 miles
Leeds 1 hour 60 miles
Manchester 2 hours 100 miles
Birmingham 2 hours 30 min 140 miles
London 2 hours 40 min 200 miles
City Plan
2.15 Hull City Council and other partners in the city are producing a City Plan – this is a 10-year plan to tackle the issues and seize the opportunities outlined above. The City Plan aims to create 7,500 jobs for local people, deliver a £1 billion investment in the city, reduce the bills of every household, cut the city’s carbon footprint by one million tonnes, and reduce the welfare bill.
2.16 Unlike the Local Plan, the City Plan is not a statutory development plan. Instead, it is essentially a collection of projects based around five priorities (see below). Although the Council plays its part, City Plan leadership comes from all parts of the city. The work to develop the City Plan has so far involved a range of organisations from the public, private, voluntary and community sectors.
2.17 The five City Plan priorities are:
1. Harness all Hull’s assets to become the leading UK Energy City. Hull’s location and its skilled workforce will see it become the UK hub for renewable energy industries and investment. Local businesses, agencies and communities will be trailblazers for producing and saving energy – creating jobs, cutting the city’s carbon footprint and making Hull a sustainable city.
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2. Make Hull a world class visitor destination. Hull will be known across the UK and beyond for its unique heritage and culture – a city with fascinating, world-class places to visit and great things to do. Visitor numbers will treble and more residents will take part in Hull’s rich and varied culture, leisure and sporting activities. The designation of Hull as UK City of Culture in 2017 is an important boost in meeting this theme. A key aspect of the programme is that the city is the venue and therefore the Council has produced a Public Realm Investment Strategy which sets out ambitious plans for improving the quality of the city centre.
3. Help residents to make their money go further. Hull will be a place where people and organisations come together in imaginative ways to cut the cost of living and help families manage their finances so they’re better able to cope during tough times. This includes exploring the potential for community food growing, which would have a land use impact.
4. Prevention and early intervention and ...
5. Safeguarding the most vulnerable residents reflect social responsibilities. Hull will be a place where everyone matters, everyone has the opportunity to be the best they can be and where vulnerable residents are supported to be as independent as possible and allowed to retain as much control over their lives as possible. While opportunities for the planning system to directly support these priorities are limited, there is an important role to be played in ensuring that development in Hull supports them. There are direct projects such as extra care housing and new health facilities where planning has a clear role. Equally important however will be supporting the development of places where active lifestyles can be supported. Developing strong, healthy and vibrant communities is vital to ensuring the wellbeing of local people.
2.18 The Council’s role will be to ensure that all of its activity and work supports the delivery of the City Plan’s priorities. The Local Plan, as the statutory planning document for the city, has an important role in facilitating the City Plan’s aspirations, particularly those that affect land or buildings. The Local Plan will identify City Plan projects on its Policies Map and will include policies to support their development and will act as the delivery plan for the physical City Plan projects. Hull and East Riding Joint Planning Statement
2.19 Because of the close relationship between Hull and the East Riding of Yorkshire, a Joint Planning Statement has been drawn up and agreed by the two Councils. It sets out a number of key strategic principles that are deemed important for both authorities in the formulation of their respective
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Local Plans. It also outlines how the two authorities should work together to deliver positive outcomes for people living and working in the combined area.
2.20 Overall, the key strategic outcomes relate to:
regeneration of Hull, improving its role, performance and environmental quality, and creation of strong and sustainable communities across the East Riding; potential of the Humber Ports is realised alongside the growth of the renewable and low carbon energy sector; and integrity of the internationally important environmental and biodiversity designations around the Humber Estuary have been protected.
2.21 In particular, the first key strategic principle relates to the role of Hull. It states:
Transform Hull as a city of regional importance and as a focus for new development and investment to create a place where people choose to live, work and spend their leisure time.
2.22 The full statement is available to view as one of our Evidence Base documents.
Map 2.1 Key Principles Diagram from the Hull and East Riding Joint Planning Statement
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Humber LEP – Strategic Economic Plan
2.23 The Humber Local Enterprise Partnership (LEP) covers the four Humber local authorities, which are Hull, East Riding of Yorkshire, North Lincolnshire and North East Lincolnshire. The Humber LEP Strategic Economic Plan (SEP) is an overarching plan for growth through to 2020, setting the overall context and priorities for other more detailed plans and strategies. The Strategic Economic Plan states:
The ambition is to maximise the potential offered by the Humber Estuary, leading the Humber to become a renowned national and international centre for renewable energy and an area whose economy is resilient and competitive. We will continue to develop our strengths in key sectors, supporting our businesses to grow and helping our residents to access the opportunities they need to lead prosperous and rewarding lives.
2.24 The SEP sets out visions for the Economy, Skills and Place. The vision relating to Place is the most relevant to the Local Plan as it relates to physical infrastructure and place making. It states:
By 2020, our visitor economy will be stronger than ever, civic pride will have risen and a stronger sense of ambition and self-confidence will be evident across the LEP area. The area will be benefiting from the legacy impacts of Hull: UK City of Culture 2017, our infrastructure and housing offer will have progressed considerably and we will be adequately resourced to deal effectively with issues of flooding and coastal erosion. Strategic development sites, including Enterprise Zones, will be thriving locations for economic growth.
2.25 In addition, the Humber LEP and local authorities are committed to producing a Humber Spatial Plan, setting out the key strategic employment locations. The Plan will be used to inform future investment proposals, and will be the basis for collecting environmental data to reduce barriers for new investment.
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Map 2.2 Draft Humber Spatial Plan key diagram (March 2014)
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3. Hull: The Energy Port City 3.1 Having considered where we are now (see previous chapter), we are able to prepare an overall strategy to guide the rest of the plan. This comprises of a Spatial Vision which describes where we want to be by the end of the plan period, and a set of Strategic Priorities which we think are key to delivering the Vision. Where we want to be: Spatial Vision for Hull in 2030
3.2 Below is a proposed Spatial Vision for Hull in 2030. We want it to be an honest and clear reflection of our aspirations for the city. It should help the reader to visualise what we are trying to achieve, and therefore understand the rationale for the Strategic Priorities and other policies that follow.
Hull A thriving port city leading the way as the cultural urban heart of the Humber Energy Estuary. A city with a rich heritage and exciting entrepreneurial, digital and renewable focused future. A great city others want to be a part of.
How do we get to where we want to be: Strategic Priorities
3.3 The National Planning Policy Framework (NPPF) lists a number of key topics that the Strategic Priorities should cover. We have taken that list into account, along with the descriptions above of where we are now and where we want to be, and considered the aims of the City Plan, in order to produce Strategic Priorities to guide the new Local Plan. These are presented in the following table.
Strategic Priority Rationale
1. Encourage high Hull is the primary settlement of the Humber region. quality shops and visitor It therefore attracts visitors to its shops and cultural attractions in accessible and leisure facilities from across a wide catchment locations, particularly the area. If Hull does not provide these facilities then city centre. people may travel further afield, to the detriment of the sustainability and prosperity of the Humber region. The plan will draw more people to the city to access shops and leisure facilities.
2. Protect district and Hull has an extensive network of district and local local centres offering centres that offer a wide range of shops and services. shops and services so These provide neighbourhood hubs and help give focus to different parts of the city. They mean that
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Strategic Priority Rationale
that they are healthy and residents do not have to travel far for the majority of vibrant and provide for their day-to-day needs. It is therefore important that day-to-day needs. the Local Plan secures their long-term success by managing development appropriately.
3. Protect and enhance Hull has 461 listed buildings and 26 conservation the city’s historic assets. areas. Of particular note is the Old Town which retains medieval street patterns and many historic buildings. Hull needs to effectively market, present and enhance these assets through sympathetic development.
4. Support more Hull residents have a lower carbon footprint than the sustainable patterns of national average. Its flat and compact nature makes living, particularly to more sustainable forms of transport easier. It is reduce pollution and important that as the city becomes more prosperous carbon emissions. that residents continue to pollute less than the national average. Reducing energy demand and using energy from renewable and low carbon sources are important.
5. Provide a transport Most businesses want to locate in places that have system that meets the good transport links. In particular, the efficient needs of residents and movement of goods and people is a basic requirement businesses, and is safe, for any successful port. It is therefore important that efficient and less Hull maintains and improves its links to the wider rail, polluting. road and water networks. At the same time, congestion and related air pollution caused by local traffic needs to be reduced, and this can be done partly by encouraging people to use more sustainable modes of transport.
6. Protect and enhance Hull has an extensive network of green infrastructure the city’s natural assets. that links the city’s green spaces with the wider countryside. These provide habitats for wildlife as well as places for rest and recreation, and safe routes for walkers and cyclists. It is therefore important that sites and the integrity of the network are protected and enhanced where possible.
7. Keep residents and The climate is predicted to change over the next businesses safe, century. In particular, events such as flooding, heat particularly from events waves, and water scarcity are likely to be more predicted by climate frequent and more severe. As much of Hull is low science, such as lying and is adjacent to the rivers Hull and Humber, flooding. it is highly vulnerable if flood defences fail.
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Strategic Priority Rationale
8. Provide sufficient land Hull has a legacy of poor quality housing that often for the right type and does not meet the needs and aspirations of families quantity of homes to and other groups. Much work has been undertaken meet local needs. in the last ten years to re-balance the housing stock. It is important for the success of the city that this work continues through regeneration initiatives and new build schemes, and that a supply of housing land is always available.
9. Provide sufficient land In the past few decades Hull has suffered from high in the right places for levels of worklessness and low levels of household new businesses and to disposable income. It is important that businesses allow existing businesses have the appropriate land and infrastructure in order to expand and to provide necessary jobs and services. The planning modernise. process will be simplified to further support jobs within the energy, digital and medical sectors.
10. Make Hull more In the past Hull has suffered from a poor public image. attractive to residents, This has been the result of industrial decline which businesses and tourists. has created unemployment and poverty. However, Hull is committed to forging a new future by embracing new industries (Green Port Hull) and the arts (UK City of Culture 2017). In order to carry this off successfully, it requires a bold plan that preserves the city’s best assets and is uncompromising in the quality that is expected from new development.
11. Provide Hull has traditionally had poor health and education fit-for-purpose health and outcomes compared to the national average. As a community facilities result, the last 10 years has seen a massive overhaul (such as schools) in of health and community facilities across the city. New accessible locations. walk-in health centres have been provided to make healthcare more accessible and reduce the burden on stretched services such as A&E. All secondary schools have either been replaced or remodelled, and many primary schools have also been improved. It is anticipated that old sports facilities that have become costly to run may need replacing in the near future. It is important that this work is supported by planning in order to continue the transformation that the city is experiencing – improving the health and education of residents.
12. Provide utility Residents and businesses rely on a range of infrastructure that meets infrastructure to support them daily. This includes the predicted growth of water and sewage, electricity, gas, the city. telecommunications (including mobile coverage and superfast broadband), and potentially heat and cooling
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Strategic Priority Rationale
networks. It is vital for the success of the city that these types of infrastructure are able to expand and improve as required.
Infrastructure & Delivery
3.4 The NPPF states that local planning authorities should work with other authorities and providers to:
assess the quality and capacity of infrastructure, for transport, waste water and its treatment, energy, including heat, telecommunications, utilities, water, health, social care, education, flood risk and coastal change management, and its ability to meet forecast demand. they should also take account of the need for strategic infrastructure including nationally significant infrastructure within their areas.
3.5 A core planning principle of NPPF is that plans should support the expansion of electronic communication networks, including telecommunications and high speed broadband.
3.6 NPPG states that the Local Plan should make clear for at least the first five years, what infrastructure is required, who is going to fund it, and how it relates to the anticipated rate and phasing of development. Where there is uncertainty over the deliverability of key infrastructure then the plan should address the consequences of this, including possible contingency arrangements. The detail concerning planned infrastructure provision is set out in a separate document called an Infrastructure Delivery Plan, which can be updated regularly. NPPG states that key infrastructure requirements on which delivery of the plan depends should be contained in the plan itself.
3.7 To guide how the Local Plan incorporates infrastructure requirements, the Hull Infrastructure Study 2015 identifies the key infrastructure needs for the city. It also seeks to identify the main funding sources to facilitate delivery, and where specific gaps exist. The study differentiates between:
Strategic Infrastructure – with citywide influence and typically Government funding – in particular the A63;
Enabling Infrastructure – critical to the development of strategically important areas and sites in the city, including facilities at the Port, renewable energy generation and broadband provision;
Place Shaping Infrastructure – driven by the need to regenerate areas and particularly the quality of the public realm and green infrastructure; and
3.8 Infrastructure is considered in the plan within chapters as following:
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Community & Cultural (chapters 7 & 8) Public Realm and open space (chapters 7 & 12) Green infrastructure (chapter 13) Health (chapter 8) Emergency Services (chapter 8) Education (chapter 8) Flood risk and drainage (chapter 9) Transport (chapter 10) Sport, Leisure & Recreation (chapter 12) Utilities (chapter 15) Waste (considered in the separate Joint Waste Local Plan) Enabling Delivery
3.9 The Infrastructure Study considered how the different types of infrastructure could be funded – where commitments existed or what would be likely sources. The main gaps in funding identified by the study related to Place Shaping Infrastructure. Strategic Infrastructure is of a scale that it requires large-scale funding, largely through Government, for example the A63 improvements.
3.10 Enabling Infrastructure may come through other funding streams – for example European funds, Local Growth, and Regional Growth Fund (RGF), where specific projects are being compiled.
3.11 The Humber LEP Strategic Economic Plan sets one of its five strategic themes as “creating an infrastructure that supports growth”. In particular, it seeks to enhance access to strategic sites along growth corridors, improve rail infrastructure, and ensure port infrastructure matches investment in the renewable energy industry.
3.12 A European Structural and Investment Fund Strategy has been created to align funding streams with the LEP economic plan, and demonstrate how the LEP intends to use its allocation of funding.
3.13 Regional Growth Fund has been secured allowing a significant area of land at Paull in the East Riding to be brought forward that is critical to the development of Green Port Hull. Viability of Development
3.14 The NPPF requires plan making and decision taking to pay careful attention to viability and costs.
3.15 An assessment has been made of the likely viability of the major development types in the city. An Area Wide Economic Viability Assessment was published in November 2012. This illustrates the significant challenge
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in the city to bringing forward development. There are few areas where values are sufficiently high to readily support development without some support.
3.16 The two types of development showing positive levels of viability in the city are housing and retail. Housing is only fully viable in certain areas of the city.
3.17 Business type uses do not generally demonstrate strong viability. This has implications for simply bringing forward development. It also has implications for the use of development as leverage for other ‘benefits’ or requirements where these can simply add more to costs.
3.18 This highlights the need to secure funding to support gaps in viability. It also requires innovative approaches to the procurement of development, including through different partnerships.
3.19 It also highlights potential issues of funding infrastructure needs as part of overall development costs. Community Infrastructure Levy
3.20 The Council has made clear its intention to adopt a Community Infrastructure Levy to support particular types of infrastructure within the city. A Preliminary Draft Charging Schedule was published in August 2013 setting out a charge against housing and retail development and a full list of projects was put forward in this document.
3.21 The scope of CIL in the city is limited by the viability of development. Projects have therefore been identified which relate largely to smaller scale public realm and green infrastructure projects.
3.22 The potential to pool resources could support specific City Plan or City of Culture projects.
3.23 A Draft Charging Schedule is due to be published and submitted alongside the Local Plan in 2016.
3.24 The use of Section 106 as a pooled resource, as currently done in the city has stopped in line with regulations. CIL will supersede but provide a similar approach to pooling of resources. Section 106 is still be available to mitigate site specific issues and to help make development acceptable.
You told us
Suggest that CIL monies should be directed to public realm improvements in the City Centre. Support the definition of Infrastructure as the basis of determining future needs and particularly endorse the inclusion of Place Shaping Infrastructure.
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Infrastructure should simply be a reference to everything that commomly services residents Agree that green infrastructure should be included as an important requirement for place shaping infrastructure The plan needs to consider how it can facilitate increasing the amount of freight that is transported to and from the port by rail. Hull's Roads (in terms of condition and capacity), flood defences, recycling facilities, and waste disposal and the public sector are all elements of infrastructure that are necessary to achieving strategic priorities. Green infrastructure provides multiple benefits and should be prioritised, especially green corridors to provide connectivity between areas. Main gaps in funding are around city centre improvements, highway maintenance, open space improvements, upgrading public buildings, providing new greenspace and in general terms around Place Shaping Infrastructure. The requirements of the Yorkshire Ambulance Service should be considered within the Local Plan. The increase in response points will need to be located in areas where new housing is proposed to be developed. Should make it clear that large housing developments may have to be phased to allow for delivery of essential waste water and water infrastructure. It is likely that other types of infrastructure would also require a phased approach and so it is essential that the phasing model reflects the interests of all infrastructure providers.
Options
3.25 There are limited distinct options. The intention of the policy should be to set a broad approach to how infrastructure needs should be met across the plan as a whole.
Draft Policy 1
Infrastructure and Delivery
1. To ensure the delivery of infrastructure requirements, to ensure the strategic and sustainability objectives of the plan are met, the Council will:
a. Support the provision of appropriate new infrastructure including schemes to mitigate and adapt to climate change and any cross boundary schemes necessary to deliver the priorities of the Local Plan.
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b. Support measures to protect, enhance or improve access to existing facilities, services and amenities that contribute to business needs, quality of life of residents, and visitor requirements, including access to information and communication technologies.
c. Facilitate the timely provision of additional facilities, services and infrastructure to meet identified needs, whether arising from new developments or existing community need, including those of the emergency services and utilities, in locations that are appropriate and accessible.
2. To facilitate the delivery of identified place shaping infrastructure requirements in the city new development will be expected to contribute in accordance with the Community Infrastructure Levy Regulations, or successor regulations or guidance.
3. S106 Planning Obligations will be directly related to the nature and potential impact of development taking account of material considerations, including viability of development.
4. The timing of provision of Infrastructure and facilities will be carefully considered in order to ensure that appropriate provision is in place before development is occupied. An Infrastructure Delivery Plan will guide how infrastructure will be funded and over what timeframes it will be delivered.
Justification
3.26 The approach puts forward the main considerations for bringing forward infrastructure, including delivery, funding and phasing. Evidence base sources
3.27 Information for this chapter mainly came from the following evidence base documents:
Hull Infrastructure Study 2011 Hull Area Wide Economic Viability Assessment 2012 Key Diagram
3.28 The Key Diagram reflects the Strategic Priorities and indicates broad locations for strategic development in the city.
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Hull Local Plan: Preferred Options
4. Climate Change Introduction
4.1 Climate change is one of the most pressing issues facing humanity in the 21st Century. The Planning and Compulsory Purchase Act 2004 requires Local Plans to include “policies designed to secure that the development and use of land … contribute to the mitigation of, and adaptation to, climate change”.
4.2 The National Planning Policy Framework (NPPF) tells us:
93. Planning plays a key role in helping shape places to secure radical reductions in greenhouse gas emissions, minimising vulnerability and providing resilience to the impacts of climate change, and supporting the delivery of renewable and low carbon energy and associated infrastructure. This is central to the economic, social and environmental dimensions of sustainable development.
94. Local planning authorities should adopt proactive strategies to mitigate and adapt to climate change, taking full account of flood risk, coastal change and water supply and demand considerations.
4.3 This, NPPF tells us, should be in line with the objectives and provisions of the Climate Change Act 2008. NPPF also states that Local Plan’s should include strategic policies to deliver (amongst other things) “climate change mitigation and adaptation” (paragraph 156). Adapting to climate change – making the city safe and resilient
4.4 Hull has had direct experience of extreme weather patterns and rising sea levels in recent years. Thousands of properties were flooded from excess surface water in the summer of 2007 and hundreds of properties were flooded from a tidal surge in December 2013. Although these events may have occurred without manmade climate change, climate scientists tell us that greenhouse gases put into the atmosphere will increase the frequency and intensity of such events. Events such as flooding and extreme heat can have detrimental impacts on people's health directly during the event and afterwards in dealing with the aftermath. It is therefore important that we plan for Hull to cope with these changes in the future.
4.5 Paragraph 99 of NPPF relates to climate change adaptation. It states:
Local Plans should take account of climate change over the longer term, including factors such as flood risk, coastal change, water supply and changes to biodiversity and landscape. New development should be planned to avoid increased vulnerability to the range of impacts
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arising from climate change. When new development is brought forward in areas which are vulnerable, care should be taken to ensure that risks can be managed through suitable adaptation measures, including through the planning of green infrastructure.
4.6 Predicting what the climate will be like in decades to come is extremely difficult. The scientific evidence produced by the Intergovernmental Panel on Climate Change in its 2014 report stated that there was a greater than 90% probability that human action had created the climate change that we are experiencing and will continue to experience unless action is taken to reduce global carbon emissions. The evidence indicates that we will experience hotter, dryer summers, warmer, wetter winters and rising sea levels due to thermal expansion and melting of glaciers. It will also result in more extreme and erratic weather, such as cloud bursts, as significant metrological features such as the jet stream change. The UK Climate Projections website (http://ukclimateprojections.metoffice.gov.uk/) allows users to access information on plausible changes in 21st century climate for the United Kingdom. It predicts that by 2080, in a medium emissions scenario, the mean temperature for Yorkshire and Humber is likely to rise by around 3°C. Winter rainfall is likely to increase and summer rainfall is likely to decrease.
4.7 As a densely built urban area next to the Humber with a river running through the centre, Hull is vulnerable to many of these changes. We therefore need to ensure that where we have the opportunity, we make development resilient and adaptable to a range of scenarios. As a result, climate change adaptation is integral to the overall approach of this plan. The following adaptation measures are described in other parts of the plan:
Require all new development to be located and designed to be safe from flooding over the next 100 years (Flood Risk Chapter); Require the sustainable management of water on developments through processes such as creation of sustainable drainage systems (SuDS) (Flood Risk Chapter); Protect and improve the network of green infrastructure in order to help with urban cooling, flood alleviation, and air quality (Natural Environment Chapter); Protect and improve sites important to nature conservation, and improve links between sites to allow wildlife to migrate (Natural Environment Chapter); and Sustainable building design (Design Chapter)
You Told Us
4.8 With regards to climate change adaptation:
Green Infrastructure can help in temperature and water management. Green Infrastructure should be planned and managed as critical infrastructure
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Recommend a commitment to soft defences such as aqua greens to help with flood alleviation. Use of Green Infrastructure in co-operation with the East Riding of Yorkshire Council (ERYC). Enhance community preparedness so that people are able to help themselves in an emergency. Prioritise flood strategy in Hull otherwise it could risk investment and the future economy. HCC needs to work with ERYC, the Local Enterprise Partnership, and the Environment Agency to bring forward policies and deliver flood defence schemes at the earliest opportunity.
Options
Option A: Incorporate climate change adaptation into the Spatial Vision and Strategic Priorities and ensure that the chapters on Flood Risk, Natural Environment, and Design deal with climate change adaptation fully and are effective.
Option B: Adopt a separate detailed policy in order to deal with climate change adaptation. However, this approach risks duplication as it is not clear what the policy would contain that is not already covered in other parts of the plan.
Option C: There is no ‘do nothing’ option as it is a legal requirement that the Plan addresses climate change adaptation.
Preferred Option
4.9 Option A
Justification
4.10 The Local Plan must address climate change adaptation. As this is a multi-faceted topic, the best way to tackle it is to ensure it is covered thoroughly throughout the plan. For this reason, Option A has been chosen. Mitigating climate change – moving to a low carbon future
4.11 The scientific evidence shows that climate change will increase in its impact on the planet if we continue to increase carbon emissions in the atmosphere. Current international agreements aim to slow down and stop carbon emission so that there is an increase in average global temperatures of no more than 2°C. Climate change mitigation is action that will reduce the emission of greenhouse gases to try to slow down the rate of climate change. We need to encourage low-carbon technologies and building forms that are more efficient and produce less pollution in order to protect Hull in the long term.
4.12 Paragraph 95 of NPPF relates to a low carbon future. It states:
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Plan for new development in locations and ways which reduce greenhouse gas emissions; Actively support energy efficiency improvements to existing buildings; and When setting any local requirement for a building’s sustainability, do so in a way consistent with the Government’s zero carbon buildings policy and adopt nationally described standards.
4.13 Similar to climate change adaptation, moving to a low carbon future is integral to the overall approach of this plan. The following list gives examples of how the Local Plan will help in this respect:
The overall spatial approach in terms of encouraging residents and businesses to locate to Hull, which is a compact city with an excellent range of services and good public transport and cycle network. Conversely, development in more rural areas would encourage greater car travel. The City Centre and Local Shops and Community Facilities sections for encouraging viable service centres that serve most day-to-day needs. Conversely, a more dispersed form of development would increase the need to travel. The Transport section, for promoting more sustainable forms of transport, such as walking, cycling and public transport. Sustainable Design section for encouraging low carbon building design to reduce energy consumption in buildings. The renewable and low carbon energy section for encouraging technology to generate energy (such as wind and solar) and more innovative methods for distributing energy (such as district heat networks) and identifying suitable areas for wind turbines.
4.14 The government publish carbon dioxide emission estimates every year. These are broken by sector for each local authority. The graph below shows that the general trend over the last seven years has been a fall in carbon dioxide emissions in Hull for each of the three main sectors. In fact, the total carbon dioxide emitted by Hull has fallen by 20% in that time, greater than the UK total which has fallen by just 14%. This difference is probably largely attributable to changes to industrial manufacturing processes employed in the city.
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Figure 4.1 Carbon dioxide emissions in Hull
4.15 The following table compares the carbon dioxide emissions for 2012 against the neighbouring East Riding as well as the national average. It shows that emissions in Hull are considerably lower than both these comparators. Although this is positive with regards to climate change, it should be noted that this difference is probably largely attributable to the fact that Hull residents are poorer than average. This means that they live in smaller houses, own fewer cars and are more likely to live in fuel poverty.
Table 4.1 Estimated carbon dioxide in 2012, tonnes per person(4)
Hull East Riding England
Industrial and commercial 2.6 4.4 2.9
Domestic 2.0 2.4 2.2
Transport 1.2 2.4 1.9
Total 5.7 9.4 7.0
You Told Us
4.16 With regards to ways that the Local Plan can reduce carbon emissions / mitigate climate change:
Need to think of strategy to encourage occupiers of existing buildings to improve energy efficiency in existing buildings.
4 Source: www.gov.uk/government/statistics/local-authority-emissions-estimates (retrieved 9 April 2015)
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Support a policy on passive solar design. Good convenient public transport that people want to use. Try to encourage people out of the motor car. More cycleways. Encourage building owners and occupiers to ‘green them up’. Create more green space, plant more trees. Invest in flood defence. Maintain and repair existing sewerage network, ditches and drains more effectively. Older properties facing east-west to always suitable for photo-voltaic panels. Improving insulation in older properties is essential. Establish a network of electric vehicle charging points. Switch HCC vehicles to electric. Change buses to electric. Support policies that promote renewables, including waste a source of energy.
Options
Option A
Make embracing low carbon technology part of the Spatial Vision supported by a Strategic Priority for reducing carbon emissions, and ensure that appropriate action is promoted throughout the document, particularly in the sections relating to Renewable Energy, Sustainable Design and Transport.
Option B
Adopt a separate detailed policy in order to deal with climate change mitigation. However, this approach risks duplication as it is not clear what the policy would contain that is not already covered in other parts of the plan.
Option C
There is no ‘do nothing’ option as it is a legal requirement that the Plan addresses climate change mitigation.
Preferred Option
4.17 Option A.
Justification
4.18 The Local Plan must address climate change mitigation. As this is a multi-faceted topic, the best way to tackle it is to ensure it is covered thoroughly throughout the plan. For this reason, Option A has been chosen.
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5. Economic Growth Introduction
5.1 The NPPF says the Local Plan should positively and proactively encourage sustainable economic growth. The Local Plan provides a framework that supports investment and development to achieve a successful and sustainable economy. In particular it builds on the LEP Strategic Economic Plan and the priorities of the City Plan.
5.2 The Local Enterprise Partnership (LEP) identifies economic sectors of strategic importance to the Humber area. The main growth sectors that are drivers in Hull are:
Engineering and Manufacturing closely linked to developments in renewables and the associated supply chain; Ports and logistics – the ports in particular are a centre of economic activity bringing added value to cargos as well as providing unique and critical infrastructure for a range of sectors, particularly the emerging offshore renewables sector. Agribusiness and food processing – Hull has some key employers in the food processing sector. Significant potential exists to create linkage with the wider region and attract further significant investment. Creative and Digital Services – the LEP recognises the strong focus of this sector within Hull through both research and development. Visitor economy – Hull is at the centre of this significant sector of the economy which is set to grow as a result of the catalyst offered by Hull: UK City of Culture 2017.
5.3 The City Plan has a main aim to increase the number of jobs and to help local residents to be ready to take up those jobs. Unemployment and insecure or low paid employment are linked to poor health outcomes. This is a particularly pressing issue in Hull which has some of the highest rates of job seekers nationally and where one in three children lives in poverty. The Health and Wellbeing Strategy recognises this by including 'more people will be in good quality secure jobs and earning at least the minimum income needed for healthy living as one of its measures.
5.4 A key target of the City Plan is to reduce the number of JSA claimants in the city by 7,500. The City Plan identifies Hull’s key drivers to be a leading UK Energy City, both in terms of manufacturing, but also energy production, and a World Class Visitor Destination. The City Plan has identified significant projects through which to implement these drivers. An indication of where some City Plan Projects will be located is provided on the Policies Map that accompanies this document.
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5.5 Economic growth in the city will have spatial implications; the City Plan recognises that a key enabler of its ambitions is the Planning Process. Key decisions are required as to how land and property can be utilised to meet priorities. Predicting future employment land requirements
5.6 A range of forecasts have been made within an Employment Land Review, produced in support of the Local Plan, to quantify what future development needs in the city could be. Forecasts have taken account of what the impact of projects being developed in the city to bring about transformational change could be, such as at Green Port Hull; as well as how market demand and development trends could inform ongoing development needs. It is estimated that current overall employment in the city is around 131,800. Projections suggest total employment could remain at a similar level to this over the plan period or alternatively grow to a highest level of up to 10,000 jobs across all sectors.
5.7 It is challenging to make forecasts against a context of economic recession and major structural change to the economy. To determine development and land needs it is usual to assess needs for manufacturing, logistics and office development (so called B uses as defined in the Planning Use Classes Order) as distinct from those jobs linked to services, for example, retail, tourism and leisure. Both types need to be catered for but can bring different development and location needs.
5.8 Econometric projections, which forecast how many future jobs might be created in the city, build on wider trends nationally and regionally and suggest a more negative view for 'B class' uses, particularly for manufacturing, than what has actually been occurring within the city over recent years.
5.9 Actual demand for new manufacturing space in the city, as demonstrated through recent development, has been strong over recent years. It is also projected that production output from local manufacturing, measured through GVA (Gross Value Added) is expected to continue to grow, aside from changes in job numbers. This is evidenced by the development of Green Port Hull. Therefore, there still seems clear justification to make provision for development of further floorspace to facilitate economic growth.
5.10 The ELR recognised that investment in the 56ha of site at Alexandra Dock was relatively unique and commitment to the scheme meant it was set apart in the projections. The schemes implementation now supports that approach. In addition to this site, projections suggested a requirement in the city of between 50–70 ha.
5.11 The qualitative nature of sites and the ability of supply to fully meet needs within the city means that actual supply requirements will remain higher than projected needs. The Employment Land Review expressed the need to provide sufficient land to accommodate for needs within different
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geographical and market areas within the city; the need to provide a portfolio of sites potentially much wider than actual projected need. The Employment Land Review identified a total of 149ha in addition to the 56ha of land at Alexandra Dock as potentially appropriate for allocation for employment development, stressing the benefit of retaining a relatively wide portfolio of sites and the need to be cautious in releasing land for other uses.
You told us
This approach adopts a supply side model; the issue facing Hull is that demand is just as important as supply and is being given insufficient weight. Certain areas of Hull are facing a structural challenge where there is simply very limited demand for employment uses. Therefore, a policy of retaining all employment sites unless sufficient supply exists in the market area does not reflect circumstances where there is little or no demand. (Montague Evans)
Options
Option A: Adopt the higher projection as a maximum level of land requirement across the city and so identify only sufficient land to meet projected requirements.
Option B: Use the higher projection as a guide for future requirements but allow a more flexible approach to be taken based on the qualitative nature of supply, including its distribution across different market areas of the city.
Option C: Adopt a lower level of projection to support the delivery of more housing.
Preferred Option
Option B is the preferred option. A potential policy for option B is:
Draft Policy 2
Future employment land requirements
1. A growing and competitive local economy will be supported through identification and maintenance of a wide portfolio of sites that meets predicted needs and can accommodate demand for development of 'B class' uses within defined market areas of the city.
Justification
5.12 The qualitative nature of sites, including their distribution across the city, suggests a need to provide a portfolio of sites that can readily provide for a full range of investment requirements in the city. There is not necessarily a clear relationship between demand and the location of existing supply in
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the city. It is therefore less clear how a quantitative supply can be identified to directly meet projected requirements. A wider portfolio land should therefore be identified to facilitate economic development needs in the city.
5.13 It provides the forecast requirements and the provision of new opportunities is critical to strengthening and developing the city's housing market.
5.14 Option A is based on an assessment of past development trends in the city. As such it has a view of how markets and industrial sectors have operated in the city. However it is limited in how it considers how past trends will translate to future needs. For example significant development has historically happened at Sutton Fields which is now almost at capacity. Development within the Eastern Corridor has been relatively low, but significant changes are occurring with the development of Green Port Hull. In quantitative terms the Eastern Corridor could itself accommodate for the total quantity of projected requirements, but clearly it would be nonsensical to not provide for clear needs in other parts of the city. The Western Corridor continues to demonstrate continuing market demand for development and so supply will need to be maintained. Therefore, it is appropriate to provide a portfolio which considers the qualitative nature of supply, not just quantitative projections.
5.15 While there is pressure for housing within some employment areas, sufficient housing sites can be identified elsewhere across the city. Delivery of housing on needed employment sites could prevent the delivery of the City Plan objective of creating 7,500 jobs and fail to support the long term strengthening of the housing market, which depends on a strong economy to boost peoples incomes and therefore ability to purchase houses. Option C is therefore not supported. Main employment areas and identified sites
5.16 Employment land and opportunities are located within various employment areas within the city. The character of these areas and their varying locational benefits, has significant influence on how they are able to contribute to economic ambitions. They define different property markets which influence the availability of development opportunities. Locational benefits also influence where different operators / industries choose to locate.
5.17 It is recognised that market areas overlay with adjoining Local Authority areas. Supply requirements are considered within the wider operation of the Functional Economic Area.
5.18 Within these areas the Employment Land Review (ELR) identifies a range of sites that could support economic development needs identified within the city. The ELR defined sites as those with Enterprise Zone and LDO status, which could provide 119ha of land, large sites over 2ha, which could provide 56 ha of land, and smaller opportunities below 2ha, which could provide 16ha. The majority of smaller sites tend to be under 1ha and can
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be seen as infill opportunities that have been identified through planning and marketing activity. They often simply reflect a point in time and other such opportunities could equally come forward over the plan period. It is therefore questionable whether there is need to specifically allocate these sites, although they do currently offer definite land opportunities. It could be more appropriate to record the existence of sites through the Employment Land Review and consider as part of a broader policy for designated employment areas - see next section. The ELR identified a number of expansion opportunities - mainly through planning permissions that existed at the time. These amounted to 6ha. However, while these contribute to economic growth they do not provide land available to the market and more general investment. They are not therefore considered appropriate to allocate, except where they remain as distinct parcels of land.
The Western Corridor
5.19 The Western Corridor runs from the western city boundary to the edge of the city centre, along the A63 corridor. At the western end is Priory Park Business Park. Beyond this industrial areas are located around Witty Street and English Street in a corridor between Hessle Road and the A63, and then between the A63 and Albert and William Wright Dock. This area is relatively densely developed, with the roads laid out in a grid system that largely determines the extent of opportunities. Around Freightliner and Wiltshire Road the areas are quite congested which limits future potential. The corridor is still the location of significant companies including ARCO and Smith & Nephew. This area demonstrates some of the highest industrial property values, although these are highest at Priory Park, lowering in the more established areas of the corridor.
5.20 The main sites identified within this area are the remaining parts of Priory Park which still provides 7.34ha of land split between 9 different plots. Proposals exist for a range of uses including office, manufacturing and warehouse. In addition a significant site of 1.88ha is held within the ownership of Arco for expansion of their existing warehouse. It could be appropriate to allocate this site to safeguard it to maintain its contribution to this location. Priory Park benefits from infrastructure already being in place. The former Birds Eye site (7.21ha) provides one of the single largest opportunities in the west of the city. This site has been subject to three separate Public Inquiries considering proposals to develop the site for all or majority housing. On two occasions it has been determined by the Planning Inspector that the site should be retained in its entirety for employment use. The most recent Inquiry is yet to report. At this stage therefore the site is put forward for allocation for employment uses.
The Eastern Corridor
5.21 The Eastern Corridor runs from the east of the city centre, along the A63 Hedon Road. To the south of Hedon Road is the ABP Port estate. For the purposes of this plan the eastern corridor describes those opportunities outside of the operational port estate, largely to the north of Hedon Road.
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Areas to the north do not present a cohesive industrial / business area with pockets of industry interspersed between other uses, for example the Prison, and with each area accessed separately off Hedon Road. Marfleet Village is located approximately mid way along the corridor. There are some relatively large operators in this area. It is characterised by significant areas of external storage, particularly in connection with the caravan and mobile building industry, and underused land. Sites have also been made available through clearance and targeted by past public funding initiatives. The Eastern Corridor has not demonstrated property values as high as the Western Corridor. This may change as Green Port Hull develops and demand potentially increases for development of accommodation for supply chain companies. Enterprise Zone status and the designation of Local Development Orders will provide incentive in the short term to encourage development in this location.
5.22 All large opportunities identified have Enterprise Zone Status. Kingston Parks Business Park (4.62ha), on the site of the former Hedon Road Maternity Hospital, has been identified as a major project within the LEP's Strategic Economic Plan (SEP). Initial phases are in planning. Burma Drive (4.64ha) is a long standing site that has seen some plots developed. Infrastructure, including roads, has now been put in place to allow the whole of the site to be developed in a number of plots. Land off Valletta Street (3.25ha), Land north of Wyke Works (1.67ha), East of Somerden Road (2.61ha), and at Elba Street (1.99ha) are all identified plots remaining to be brought forward.
5.23 Opportunity exists within the site of the former Isaac Newton School for small business units on approximately 3ha of land within the context of the wider site that was originally allocated for a mix of uses in the Holderness Road Corridor Area Action Plan.
The Port
5.24 The Port area is within the ownership of ABP, and therefore is governed by their operational needs. Green Port Hull presents a new direction for the port led by the investment by Siemens in a production and servicing facility for offshore wind turbines on a 56ha site at Alexandra Dock. Green Port Hull also includes major sites at Queen Elizabeth Dock (44.55 ha). These sites provide for major drivers of economic development, identified as locations for renewable energy development including manufacture, assembly, testing, servicing and transport of equipment; and energy transmission. These sites will most likely support land intensive uses where actual floorspace requirements are low but large areas of land are required for operational purposes. They will serve needs differently to other sites in the city where more typical plot ratios will apply and therefore align more closely to meeting projected land requirements.
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The River Hull Corridor
5.25 The River Hull Corridor area is characterised by a relatively dense pattern of occupation, with many heavier industries within a tight street network. It reflects its historical origins as the industrial heartland of the city running along the River Hull corridor. This areas stretches from just north of the city centre, northwards along the river Hull corridor, up to the area around Clough Road. There are some large operations within the area, including Reckitt Benckiser. Many service industries occupy older properties, potentially taking advantage of lower property prices. The nature of the area is such that redevelopment opportunities arise from redundant stock but greater challenges exist to bringing forward sites due to the need for clearance of sites and need to deal with potential contamination. Clough Road at the north of the area is characterised by a range of commercial retail and trade outlets, but there are industrial and service areas to the north including the large Croda plant.
5.26 The National Grid site (13.5ha), on Clough Road, presents a significant development opportunity. A large part of the site has had contamination remediated. Significant gas storage and distribution infrastructure remains elsewhere on the site making it less clear how these areas could come forward and the degree of remediation required. It is understood that remaining pipelines and storage tanks will be removed and so subject to associated timescales for this, the site could provide a large employment site in a prominent location, providing for a range of employment uses. A new Police Headquarters was constructed on part of the original site fronting Clough Road. Land west of Cleveland Street (4.85ha) has been identified as the location for an energy from waste plant. Work has been undertaken to clear the site but no construction has commenced. Indications are that this scheme will progress.
Sutton Fields
5.27 Sutton Fields was originally released to the market in the 1970's as a major Greenfield opportunity, with the specific purpose of creating a new industrial estate for the city. As such it presents a relatively well defined area. It has been very successful with most space now developed. It houses major companies such as Cranswick Foods. The relatively low density of plots has allowed expansion of companies, although options are now relatively limited and some companies may need to relocate to find space. A site of 1.52ha adjoins Donaldsons Filter Components which is believed to be held within their ownership although provides a clear and accessible plot of land.
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National Avenue
5.28 The National Avenue area sits away from the main industrial areas in the city. The location derives from the historical roots of the Ideal Company which remains the dominant operation with a substantial estate, some of it recently cleared to the rear of the site. Smaller areas adjoin this at Bontoft Avenue and Harpings Road.
Kingswood
5.29 Land has historically, through the Local Plan 2000, been identified for employment development at Kingswood. Aside from the few units developed, the area previously identified remains as an area of farmland running along the River Hull. Some parcels of land could potentially support a range of uses and so the amount of land available for 'B' class development could vary. The Kingswood Area Action Plan provides the planning framework for how this land could be developed.
City Centre
5.30 The City Centre provides a number of sites which could support office uses and potentially small scale light industries. Creative industries are seen as an important part of the centre's role. The majority of identified sites are likely to support a mix of uses and therefore it is difficult to quantify exactly how much development could occur. More detail of how sites could develop is provided in chapter 7 - City Centre.
Smaller opportunities
5.31 Across most employment areas, particularly older areas where redevelopment opportunities come forward, a number of smaller infill opportunities have been identified which could contribute to supply requirements. These are shown as potential allocations on the Policies Map that accompanies this document.
Conclusion
5.32 The city as a whole therefore presents a number of differing areas within which employment development could take place. Each presents differing opportunities and importantly the property market reflects these differences with different rental and capital values achieved. There are also important structural changes occurring, particularly on the back of Green Port Hull and potential for new inward investment to the city. Therefore any approach to meeting estimated demand for space must look beyond pure quanta of need, to how different areas of the city can actively work to support demand. A wide portfolio of sites that offers choice and flexibility is therefore an appropriate base to enable the plan to achieve its objective of supporting economic growth in the city.
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Picture 5.1 Main Employment Locations
You told us
Policies should support major developments which are planned for Green Port Hull.
The Council is proposing to over allocate land which is unsustainable as much of the allocated land will remain vacant throughout the plan period and therefore will not accord with NPPF para 22 which seeks to avoid long term protection of sites where there is no reasonable prospect of the site being used for that purpose.
Options
Option A: Allocate the range of identified sites, but only large sites over 2 ha as providing key development opportunities in the future. Allow for a supply of smaller sites to be identified through monitoring of planning and marketing activities, where these become available.
Option B: Allocate all identified sites, including smaller opportunities, reflecting the fact that these still represent definite opportunities that can contribute to needs.
Preferred Option
The preferred option is Option B and for the sites listed in the following policy to be allocated:
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Draft Policy 3
Potential Employment Allocations
1. The sites listed below are identified for a range of uses within industrial and business use under Use Classes B1(b) (c) and B2 and B8 (but not excluding B1a) and, where one exists, should be developed in accordance with the development brief or Local Development Order (LDO) :
a. Alexandra Dock (56ha) (ref: 69/104)
b. Queen Elizabeth Dock North (26.64ha) (Ref (69/105)
c. Queen Elizabeth Dock South (17.88ha) (Ref 69/106)
d. Kingston Parklands Business Park (4.46 ha) (Ref: 68/27)
e. Burma Drive (4.64 ha) (Ref: 68/02, 68/02-3)
f. Kingston International Business Park (2.61 ha) (Ref: 68/18-2, 68/18-3)
g. Valetta Street (3.25 ha) (Ref: 68/20)
h. Wyke Works (1.67 ha) (Ref: 68/21)
i. Elba Street (1.99 ha) (Ref: 68/103-1)
j. Priory Park (7.98 ha) (Ref:26/08 series)
k. Former Birds Eye, Hessle Road (7.21 ha) (Ref: 26/103)
l. National Grid Site, Clough Road (13.2 ha) (Ref:38/07)
m. Land west of Cleveland Street, including the site of the former Spillers Mill (4.85 ha) (Ref: 16/143 & 16/106)
n. Kingswood (up to 18 ha) (Ref: 41/10 series)
2. The site at the former Isaac Newton School (Ref: 66/02) is identified to provide up to 3ha for uses within Use Class B1(a)(b)&(c) amongst a mixture of other uses.
3. A number of smaller sites identified in the Council's Employment Land Review could provide development opportunities for use under Use Classes B1(b) (c) and B2 and B8 (but not excluding B1a) . These are shown as potential allocations on the Policies Map.
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Justification
5.33 Option B provides for greater clarity of where all opportunities exist within the city. The sites listed above have been identified through the Employment Land Review and subsequent updates, through the creation of an Enterprise Zone and Local Development Orders. They therefore reflect up to date evidence. A full assessment of sites will be undertaken through a site assessment methodology which will be undertaken in the intervening period to Publication of the Local Plan.
5.34 Allocating only the large sites, while the focus for the majority of land area available, concentrates directed opportunities within relatively few sites across the city. Future use of land within designated Employment Areas
5.35 NPPF Para 22 states that Planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose. Land allocations should be regularly reviewed. Where there is no reasonable prospect of a site being used for the allocated employment use, applications for alternative uses of land or buildings should be treated on their merits having regard to market signals and the relative need for different land uses to support sustainable local communities.
5.36 The city needs to provide sufficient sites / land to meet projected requirements over the plan period. Overall, identified sites could, in global terms and considered as a city wide supply, meet needs in terms of quantitative requirements. However it is recognised that some sites may still face delivery issues and competing pressures remain. It is also clear that much of supply in the city has emerged from previously developed sites. As opportunities arise therefore, and in the face of pressures for competing uses, it is important that a framework exists through which to properly assess how emerging sites can contribute to future development, and only then where there is clearly no reasonable prospect of sites being brought forward and there is not a need to retain land for employment uses, should they be considered for non-employment uses. The conclusions relating to land supply in the Hull Employment Land Review and subsequent updates will be a key consideration when making assessments of proposals for the development of land within defined employment areas. This will include assessment of market signals, including market demand, property prices and viability of development.
5.37 The definition of broad employment areas within the city allows a clear direction of where such a policy approach should apply. Areas are identified in the proceeding section to this together with the accompanying map. These areas present a clear focus for commercial and industrial activity, and so generally it is clear what a future use could be where redevelopment
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opportunities occur. It is recognised that business and industrial uses are acceptable within these areas, so generally there are not issues related to incompatibility of neighbouring uses.
5.38 Despite sites being identified therefore there will always remain a need for sufficient flexibility to allow for unforeseen opportunities, and to meet uncertainties over business changes.
You told us
Should clarify that the reuse of vacant land and buildings can include alternate uses to employment (class B1, B2 and B8) uses where appropriate.
Questions whether potential sites within the broad brush designation of substantial ‘employment areas’ are essential to meeting the economic priorities of the city when the Council have identified a range of employment opportunities across the city which collectively could meet projected needs.
If such a precautionary approach is taken and the designation of wider employment areas are justified, it is essential that a flexible approach is adopted in line with NPPF para 22, to allow for alternative uses on employment land where such sites are not capable of attracting alternative uses, to ensure on-going beneficial use of land and to maximise potential.
Any policy should therefore allow alternative uses where there is evidence that the site has been marketed for a reasonable period of time and there has been no take up for employment use or redevelopment, together with evidence of viability.
Alternative uses as well as business uses should all be considered whether the outcome leads to improvement or job opportunity. There are two types of growth inward investment being one but organic growth should not be forgotten.
Reliance can be placed on a currently unknown supply of recycling of land since market value and viability (market failure) is a big point rightly noted.
Policy requirements should not be so onerous that they impact negatively on viability and the ability of the city to attract inward investment
Consider it vital that the Council protects existing employment uses, with redevelopment only acceptable where sites have become unviable for ongoing business use. Any change to an alternative use should
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reflect the impact that a non-employment or sensitive use would have on a neighbouring employment use – with for example potential for noise complaints and unnecessary or prohibitive restrictions
Concern that the overprotection of employment land could undermine current investment programmes.
Land to the east of Stoneferry Road is shown on the evidence map as within a broad employment area. However in reality it is an isolated area of employment uses and the proximity of housing on three sides of the site restricts its viable use. The ELR shows city is well provided with employment land and the central area of the city is less attractive to the market for industrial development than the West and Port Areas.
Options
Option A: Do not define broad areas within which to have an initial presumption in favour of retaining land where the predominant use has been for employment use within that use
Option B: Define the areas but set out a more flexible range of uses for these areas – to broaden the scope of what can be acceptable.
Option C: Define the area with a presumption that where sites become available due to closure or relocation, the initial view is that future use will be for employment uses within B class uses or closely associated sui-generis uses. Release of sites will depend on adequate supply being retained.
Option D: Define broad areas but with significant review of where demand suggests a necessary structural change to presumed uses. Applications for alternative uses of land would then be treated on their merits having regard to market signals and relative need.
Preferred Option
5.39 Option D is the preferred approach. A potential policy for option D is:
Draft Policy 4
Future use of land within designated employment areas.
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1. Within designated employment areas, as defined on the Policies Map, non-employment development will not be allowed on land where there is no existing adequate provision of development land nearby and where loss of the land would lead to a shortfall of land available to meet predicted needs.
2. Development that is ancillary to a main employment use, that is complementary and may help support viability of development may be supported where this does not reduce capacity of land to meet identified requirements within the defined employment area where the site is located, or city wide.
Justification
5.40 The city has relatively limited opportunity for greenfield development and historically significant development sites have come from previously developed land. It is therefore necessary that future supply is not constrained by purely relying on a supply pipeline that is identified at the current time. While there is a quantitative supply that can be identified to meet projected requirements – it will always be necessary to consider where opportunities for development arise – to consider whether these offer better opportunities to meet demand for employment demand. Therefore this option allows for appropriate consideration to be given. It does not seek simply to retain land through over allocation and accords with NPPF para 22.
5.41 Option A relies only on using those sites that might be allocated within the plan, as currently identified. These sites quantitatively can be seen to offer more than sufficient land to meet projected requirements, and also provide a degree of flexibility through providing choice through type and distribution. However, inevitably they can only provide a snapshot of the main opportunities that exist at this time. To maximise the city’s ability to support economic growth objectives it is critical that new opportunities resulting from closure or relocation for example, can be properly assessed as to how they might support future opportunities before consideration of developing for alternative use, with the loss of an important resource.
5.42 Option B, by defining the range of uses that could be acceptable within the broad employment areas, risks losing the ability to properly assess the future contribution of sites to economic growth. Historically a range of commercial non B class uses have been developed within employment areas, often as enabling development to support weak land values and therefore make wider employment development viable. It is important however that a proper framework exists to assess development proposals, and the real potential of sites, rather than set out a presumption at the start to a wider range.
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5.43 Option C would be similar to the preferred option D, although the emphasis would be to retaining an adequate supply of land in areas of the city rather than a fuller assessment of demand requirements and the need for structural changes to some area of the city. University of Hull
5.44 The University presents both a key employer in the city, but also a key institution supporting research and development that supports economic growth in the city. It is therefore important that adequate provision is made in the plan to support its continuing investment needs, to enable plans for development and remodelling both within its existing estate, but also within the surrounding areas where this is necessary.
5.45 Such development can include for specific operational needs, but can also relate to student accommodation which can be equally as critical when the University is having to compete to attract students and research staff.
Options
Option A: Provide a policy framework that is generally supportive of a range of development needs associated with the University.
Option B: Be more prescriptive of the types of development that could be supported at the University, and within areas surrounding the University.
The preferred option is A
Draft Policy 5
University of Hull
1. The Council will support proposals for redevelopment and expansion of facilities at the University to enable it to fulfil its role as a key economic driver, through research and development.
2. Proposals which support upgrading of student accommodation, within the University and in adjoining areas will be supported.
Justification
5.46 The University is of significant importance to economic objectives of the city and it is important that these objectives are not fettered by unduly restricting proposals.
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Supporting evidence
SA Objectives
5.47 Maximise the use of previously developed land and buildings, and the efficient use of land
5.48 Deliver more sustainable patterns of development by ensuring links to a range of modes of transport
5.49 Create conditions which support sustainable economic growth, encourage investment, innovation, entrepreneurship and business diversity
5.50 The SA sees that the land sites retained for expansion [think this should be sites retained for employment uses rather than ‘expansion’ as this limits the viewpoint of the SA and doesn’t properly reflect the scope of the issue / option being considered] are mainly brownfield sites. Redevelopment of these sites will reduce pressure from Greenfield areas. Therefore this approach is generally positive assessed against a number of objectives.
Main evidence base
5.51 Employment Land Review 2014
5.52 Addendum to ELR - update of site survey.
5.53 Infrastructure Study 2015.
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6. Housing Introduction
6.1 The NPPF states that local plans should meet the full objectively assessed housing needs of their area; identify a supply of developable and deliverable housing sites for market and affordable housing for the overall plan period; and deliver a wide choice of high quality homes that are built in the right places and are the right type, widen opportunities for home ownership and create sustainable, inclusive and mixed communities. Housing demand
6.2 Hull needs to provide enough houses to accommodate the predicted increase in population and projected changes to average household size. The I&O document put forward a housing target of 760 new homes per year up to 2030, as recommended in the Strategic Housing Market Assessment (SHMA) 2013. New sub-national population projections (SNPP) and household projections have since been produced by the government. The Council has therefore updated the ‘objectively assessed need’ (OAN) for housing in Hull to take account of these new projections.
6.3 The Objectively Assessed Need (OAN) for Housing in Hull: 2015 Update firstly considers demographic trends (births, deaths, migration and household formation rates). Hull’s population is projected to increase by around 13,450 between 2011 and 2032 (from 256,123 to 269,571), an average of around 640 people per year. Over the same period, the government figures project an increase in the number of households by around 11,500 (from 112,423 to 123,925). This would result in a need for around 567 new homes per year (a total of 11,900 between 2011 and 2032).
6.4 The OAN Update then considers whether any local adjustments to the nationally-produced demographic projections are needed, particularly regarding migration and household formation rates. The analysis found justification for adjusting the net domestic migration rate to reflect improving economic conditions and a reduced level of out-migration from the city. This would result in a higher need for around 642 new homes per year.
6.5 The OAN Update also considers whether there is any justification for increasing the housing need figure to reflect employment forecasts only. However, the level of housing needed to support job growth was found to be less than 400 homes per year, well below the number identified by the demographic projections.
6.6 The OAN provides the starting point in determining the housing requirement, but past under-supply, future demolitions and cumulative impact of the local plan strategy and policies must also be taken into account. These elements
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would increase the potential annual number of homes identified within the OAN 2015 update to around 760 homes and the potential annual number of homes identified within the SHMA 2013 to around 870 homes.
You Told Us
Many respondents agreed that a housing requirement of 760 per year was a reasonable figure based on the available evidence.
Some considered this figure to be too low and suggested up to 1,350 per year; they considered the SHMA figure to be based on the economic recession and seek a more aspirational number that assumes economic growth.
The Objectively Assessed Need for Housing in Hull: 2015 Update had not been produced when consultation on Issues and Options took place.
Options
Option A: Build 640 new homes per year during the plan period, based on the OAN 2015 figure adjusted for local circumstances.
Option B: Build 760 new homes per year during the plan period, based on the Objectively Assessed Need 2015 Update, a figure of 640 homes. This allows for indicative levels of demolition and cumulative impact of Local Plan policy and strategy.
Option C: Build 870 new homes per year during the plan period, based on the Objectively Assessed Need identified in the Hull SHMA 2013, a figure of 760 homes. This allows for indicative levels of demolition and cumulative impact of Local Plan policy and strategy.
Preferred Option
6.7 Option B.
Draft Policy 6
Housing demand
Provision will be made for the development of 11,400 new homes in Hull during the period 2015 to 2030.
This housing requirement will be delivered at an average rate of 760 dwellings per year.
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Justification
6.8 National Planning Policy Guidance (NPPG) advises that ‘wherever possible, local needs assessments should be informed by the latest available information’. The Objectively Assessed Need (OAN) for Housing in Hull: 2015 Update is based on the 2012-2037 Household Projections published by DCLG on 27 February 2015. The OAN Update recommends an objectively assessed housing need figure of 640 (rounded down from 642) homes per year. This recognises recent demographic trends, but also the possibility that higher housing provision could result from potential improving economic circumstances.
6.9 The preferred option housing requirement of 760 homes factors in the housing delivery backlog for the period 2011 to 2014 within Hull, the indicative level of demolitions identified over the plan period 2015 to 2030 and a modest uplift for the cumulative impact of the strategy and policies suggested in this Local Plan preferred options document. The preferred option housing requirement of 760 homes ensures the housing requirement identified for the Hull part of the Hull Housing market, a housing market area which covers parts of the East Riding of Yorkshire, will be met in full and this modest uplift responds to the strengthening economy in Hull which the models are unable to quantify as it is difficult to forecast the impact of City of Culture,significant public sector investment into leisure facilities and a new industry (offshore wind). This figure of 760 is consistent with the numbers presented at the East Riding Local Plan examination. Housing land supply
6.10 The Local Plan is required to identify a supply of housing land that is sufficient to meet housing demand within Hull over the plan period. To assist this process, the Council produces an annual Strategic Housing Land Availability Assessment (SHLAA) which identifies potential sites for housing development.
6.11 The potential housing allocations are based upon the Strategic Housing Land Availability Assessment (SHLAA) 2014. Capacity of housing sites, trajectories and boundaries have been updated for 2015. Sites that remain suitable, available and developable for housing are considered for potential housing allocation. Deliverability and delivery rates will continue to reflect the methodology within the SHLAA 2014.
6.12 Sites within the Kingswood Area Action Plan (AAP) were considered for allocation within its latest stage the Publication Draft, June to July 2015. The Kingswood AAP has a potential for housing allocation of around 3,100 hew homes for the period 2015 to 2030. It is estimated the potential delivery of homes over the plan period will average over 1,100 new homes for periods 2015 to 2020 and 2020 to 2025. For the final five years of the plan the estimate is over 850 homes. The potential capacity and trajectory for Kingswood’s AAP housing sites is shown in Table 6.1.
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6.13 The potential housing allocations include some existing allocations, new sites proposed, sites with planning permission including those under construction and awaiting start, conversions and changes of use.
6.14 Potential housing allocations currently considered as commitments, shown in Table 6.2, include those sites with planning permission for change of use or conversions. Sites with planning permission under construction and nearing completion are also shown within Table 6.3. Sites nearing completion are identified for completeness of housing supply.
6.15 Potential housing allocations outwith the commitments listed within Table 6.2 are shown in Table 6.3. These include some existing allocations, some new sites proposed through the SHLAA 'call for sites' process, sites with planning permission (some larger sites under construction or known to have phased delivery or those awaiting a construction start) are identified as potential housing allocations.
Table 6.1 Kingswood sites capacity and trajectory of potential housing allocations for the period 2015 to 2030.
Reference Address 2015 to 2020 to 2025 to Potential 2020 2025 2030 housing Capacity 2015 to 2030
Kingswood Area 1,159 1,071 869 Action Plan (AAP) (17 Sites) 3,099
Table 6.2 Site Reference, address, capacity and trajectory of potential housing allocation sites for the period 2015 to 2030. These sites are known commitments nearing completion or conversions or change of use with planning permission.
Local Address 2015 2020 2025 Potential Plan/ to to to housing SHLAA 2020 2025 2030 Capacity 2015 to Reference 2030
6 13 - 25 George Street 130013
7 41 - 65 George Street (Upper 150015 Floors)
9 380 Beverley Road (Former 200020 Mayfair Cinema)
24 Former Princess Royal Hospital 360036
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Local Address 2015 2020 2025 Potential Plan/ to to to housing SHLAA 2020 2025 2030 Capacity 2015 to Reference 2030
30 Former Newland Primary 160160 School, Newland Avenue
32 Lambert Street Church 9900
38 East of 824 Holderness Road 4004
43 48 Pearson Park, HU5 2TG 6006
45 49 Pearson Park, HU5 2TG 5005
46 50 Pearson Park 140014
51 20-24 Lambert Street 9009
117 Reckitts Recreation Ground, 890089 Chamberlain Road
225 Former Grammar School, 2002 Cottingham Road
226 173 to 187 Cottingham Road 350350
250 Old Methodist Hall, Durham 6060 Street
291 114 Blenheim Street 5050
296 Land to rear or 41-45 Albert 5050 Avenue
314 Story Street, Upper Floors 8008
371 Marina Recreation Centre, 150015 Commercial Road
383 Friary Chambers (Upper 190019 Floors), 24 - 28 Whitefriargate
405 83-93 George Street 100010
431 44-46 Paragon Street 170017 Queens House Upper Floors, HU1 3NZ
433 Kings Building, South Church 240024 Side
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Local Address 2015 2020 2025 Potential Plan/ to to to housing SHLAA 2020 2025 2030 Capacity 2015 to Reference 2030
447 109- 111 Beverley Road (Upper 200020 floors)
504 Firethorn Close, Land To Rear 5005 Of 15 To 18, HU3 2RF
580 The Sidings Development, west 440044 of Calvert Lane
607 Amber Development, Boothferry 730073 Road
673 Newland Homes, Cottingham 140014 Road
728 64 - 86 Dibsdane, HU6 9AL 180018
879 The Lawns Club, 33 Lowgate, 150015 Sutton
917 Land to the rear of Holly Bank 9009 House, west of Astral Gardens
924 13 - 15 Savile Street (Upper 5005 Floors),
Total 967509 585
Table 6.3 Site Reference, address, capacity and trajectory of potential housing allocations for the period 2015 to 2030 in addition to those commitments identified within Table 6.2
Local Address 2015 2020 2025 Potential Plan/ to to to housing SHLAA 2020 2025 2030 Capacity 2015 to Reference 2030
2 Egginton Street 0240 24
8 25 - 27 Dock Street 9009
17 Holderness House, Holderness 0013 13 Road
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Local Address 2015 2020 2025 Potential Plan/ to to to housing SHLAA 2020 2025 2030 Capacity 2015 to Reference 2030
20 PR6 Preston Road Part 1 - 8000 HRC AAP 80
21 PR6 Craven Park - HRC AAP 01440 200
22 INGS1 Part1 - HRC AAP 0990 99
23 Land Nth of Bellfield Avenue, 0012 between Mitcham Road and Twickenham Close (Ings site D) 12
26 Former Goodfellows 0015 Supermarket - Sharp Street 15
27 West end of Sharp Street 0150 15
36 HRC AAP - David Lister School 0054 54
42 North Area of North 02500 Bransholme 250
44 Land to the east Of Hawthorn 0095 Avenue South of Greek Street And west Of Plane Street 95
47 Kinderscout Close, North 0250 Bransholme - Riverside Group Ltd 25
54 Sutton Place Safe Centre, 0035 Saltshouse Road - Hull City Council NPS 35
65 Leitholm Close, North 0410 Bransholme - Riverside Group Ltd 41
68 Scholars Gate, Spring Bank 023250 West 273
80 Gifford Close, North 090 Bransholme - Riverside Group Ltd 9
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Local Address 2015 2020 2025 Potential Plan/ to to to housing SHLAA 2020 2025 2030 Capacity 2015 to Reference 2030
102 North of Grassington Close, 0140 North Bransholme - Riverside Group Ltd 14
106 Land North East of Highlands 0450 Health Centre, Cumbrian Way, North Bransholme - Riverside Group Ltd 45
113 Land South of Saddleworth 0011 Close 11
119 Lorraine Street Bakery 0800 80
120 Land to the East of Stoneferry 0280 Road 28
121 Corner of Leads Road & Glebe 0180 Road 18
122 Corner of Leads Road & Glebe 005 Road 2/3 5
137 Wansbeck Road/ Frome Road 0160 16
138 Former Viking PH, Shannon 070 Road 7
164 Land Between Anlaby Road 201800 and Railway Line (Part 2) 200
170 106 - 108 Marfleet Avenue 9009
172 Land to North East of 141 0033 Marfleet Avenue 33
173 St Bedes, Wivern Road 0300 30
190 Hollywell Close 1000 10
192 Land north of Hopewell Road 0160 16
195 Fruit Market Site B 00109 109
197 Brandsby Grove 0350 35
198 Fruit Market Site D 02335 58
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Local Address 2015 2020 2025 Potential Plan/ to to to housing SHLAA 2020 2025 2030 Capacity 2015 to Reference 2030
199 Land to south of Oakfield 01480 School 148
212 Former Sports Ground, south 0860 of Goddard Avenue/east of Chanterlands Avenue 86
219 Goodfellowship Inn Pub, 008 Cottingham Road 8
231 Land between Bishop Alcock 0170 Road and Hotham Road North 17
232 Land at Bishop Alcock Road 0012 12
234 Land west of Bishop Alcock 0080 Road (former William Gee School) 80
254 Land surrounding Wath Grove 0320 32
313 Baker Street Garage 0620 62
316 Albion Square 201800 200
317 Former Edwyn Davies Building, 7000 Bond Street 70
318 31-53 Ferensway 01000 100
322 HRC AAP - INGS1 Part 2, Land 200 0139 west of Middlesex Road. 339
325 HRC AAP - INGS1 Part 5 0065 65
326 Land at Ganstead Grove/Exeter 0097 Grove/Rimswell Grove/Wyton Grove 97
327 HRC AAP PR6-3 Land north of 0056 Maybury Road (former Maybury School) 56
328 HRC AAP - PR6 Part 4, Land 00148 south of Marfleet Lane. 148
62 DRAFT JUNE 2015 Hull Local Plan: Preferred Options
Local Address 2015 2020 2025 Potential Plan/ to to to housing SHLAA 2020 2025 2030 Capacity 2015 to Reference 2030
329 HRC AAP - PR6 Part 5, Kedrum 00157 Road 157
331 East/West of Marfleet Avenue, 00129 Rear of Ceylon St. abutting Egypt St/Frodsham St/Cyprus St/Delhi St and part fronting Hedon Road 129
336 PR6 Part 9 HRC AAP, 2000 205 Regeneration of existing housing South of Preston Road 405
364 Land between Stanley Street 0020 and Derringham Street, Spring Bank 20
367 Hawthorn Avenue East 052225 277
370 NaSA 2 - Hawthorn Avenue, 250 0175 Former Amy Johnson Site 425
373 Humber Quays 0032 32
376 63-71 High Street 01000 100
385 Land to the west of Spring 421800 Street, Ferensway 222
398 High Street East of Blaydes 0640 Staith 64
399 2-5 High Street 0330 33
400 Blaydes Dock 0640 64
401 Mutiny on the Bounty Public 070 House 7
418 25-30 Albion Street 0034 34
428 Land North of George Street, 0300 between Carroll Place and Trippet Street 30
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Local Address 2015 2020 2025 Potential Plan/ to to to housing SHLAA 2020 2025 2030 Capacity 2015 to Reference 2030
429 Land To The West Of And 0017 Burnett House Castle Street 17
432 Former Co-Operative Building 7200 Jameson Street 72
482 Brunswick Avenue - Hull 0014 CC/Goodwin Trust AHP Bid 14
485 Former School of Architecture 0750 building, Brunswick Avenue 75
486 The Basin, St Andrews Dock 02050 205
502 HCC/Goodwin Trust. 0012 Successful AHP Bid - Land parcels to north of Walker Street 12
503 Land to the east of Wincolmlee 02000 fronting the River Hull 200
521 Land adjacent to 8 Louis Street 6060
522 40 Margaret Street 6006
524 Providence Row, Beverley 0240 Road 24
561 Trinity House Grounds, Calvert 201800 Lane 200
659 West of No's 288-264 Pickering 0030 Road, former LA Training Centre 30
721 Former Dane Park Primary 0080 School 80
723 The Danes, North of Hall Road 00160 160
757 Haworth Park playing fields 01600 160
784 Clarence Mills, Great Union 02460 Street/St. Peter Street 246
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Local Address 2015 2020 2025 Potential Plan/ to to to housing SHLAA 2020 2025 2030 Capacity 2015 to Reference 2030
785 Land at Tower Street/St. Peter 02100 Street, East bank of the River Hull (North) 210
787 Land at Tower Street/St. Peter 03900 Street, East bank of the River Hull - Phase 1 390
804 Field Street - Holderness Road 0200 20
805 Land at Minehead Road 01500 150
861 Land to north of Danby Close, 3600 140 Howdale Road Part 1 500
862 Land to north of Danby Close, 21600 Howdale Road Part 2 330
875 The Holden 00156 Centre/Tweendykes School, Leads Road 156
914 Gleneagles Centre, Gleneagles 0027 Park 27
927 Land at 103 8th Avenue, 9090
928 Land To The North Of Hall 0065 Road And South Of Homethorpe 65
936 Rear of 465-467 Priory Road 0100 10
Total 2,765 5,036 1,009 8,810
6.16 All proposed housing site allocations are shown of the Local Plan Policies Map, excluding the Kingswood sites which can be identified on the Kingswood Area Action Plan Policies Map.
6.17 The Council will carry out further assessment of these sites prior to the Local Plan publication stage. This will ensure all sites allocated for housing development will have been robustly tested for suitability, availability, deliverability and thoroughly examined within a site selection process.
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6.18 A summary of potential housing supply for the period 2015 to 2030 is shown in table 6.4 below.
Table 6.4 Summary of supply 2015 to 2030
Potential 2015 to 2020 to 2025 to housing Supply 2020 2025 2030 Capacity 2015 to 2030
Kingswood Area Action Plan (AAP) 1,159 1,071 869 3,099 (17 Sites)
Potential Allocation 509 67 9 585 (Committed)
Potential Allocation 2,765 5,036 1,009 8,810
Total 4,433 6,174 1,887 12,494
You Told Us
Some concerns were expressed regarding the impact of housing development on potential sites; these concerns included impacts on flood risk, wildlife, green corridors, green space, conservation areas and listed buildings.
There was support for more housing in the city centre and on brownfield land.
Some sought the re-allocation of employment land for housing, and others the redevelopment of greater numbers of obsolete houses in the Newington & St Andrews and Holderness Road areas.
Some questioned the suitability of Kingswood for housing.
It was mentioned that some sites are also suitable for the provision of a community facility.
A significant number of responses were concerned with the suitability of specific sites for housing development.
Options
Option A: Allocate for housing all of the sites shown on the Policies Map and listed in Table 6.2 and Table 6.3.
Option B: Allocate for housing some of the sites shown on the Policies Map and listed in Table 6.2 and Table 6.3.
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Option C: Allocate for housing other sites not shown on the Policies Map or listed in Table 6.2 and Table 6.3.
Preferred Option
6.19 Option A.
Draft Policy 7
Housing land supply
Sites shown on the Policies Map and listed in Table 6.2 and 6.3 are allocated for housing.
Justification
6.20 The Council must allocate sufficient land to meet its projected housing needs. Potential sites for housing are identified in the Council’s annual Strategic Housing Land Availability Assessment (SHLAA).
6.21 The SHLAA is an important evidence source to inform plan making but does not in itself determine whether a site should be allocated for development. This is because not all sites considered in the assessment will be suitable for development (e.g. because of policy constraints or if they are unviable). It is the role of a SHLAA to provide information on the range of sites which are available to meet need, but it is for the development plan itself to determine which of those sites are the most suitable to meet those needs.
6.22 The sites in the SHLAA have been assessed in greater detail to decide which are most suitable for housing. This includes a site selection process including a robust range of criteria, for example the impact a proposed use would have on flood risk.
6.23 Enough sites must be identified to meet projected housing needs over the plan period. The most suitable sites have been proposed for allocation for housing in the Local Plan. Type and mix of housing
6.24 Hull has an oversupply of older, small, terraced properties and a lack of larger family houses. Many people move out from the city to the East Riding where newer and larger detached and semi-detached houses have been developed. There is a need to address the imbalances in the current stock, particularly through the provision of aspirational housing. The Strategic Housing Market Assessment identifies a recommended mix of house sizes, in terms of the number of bedrooms, for both market and affordable housing. This was based on analysis of a range of demographic and economic factors.
DRAFT JUNE 2015 67 Hull Local Plan: Preferred Options
You Told Us
There were mixed views on setting targets, in terms of the number of bedrooms, to increase the number of larger houses.
Some considered that indicative targets for bedroom numbers would be useful in terms of encouraging a shift to more aspirational housing.
Others thought that the market should determine the type of provision.
Options
Option A: Require 40% of new market housing in Hull to contain at least 3 bedrooms, and 70-80% of affordable housing to contain no more than 2 bedrooms.
Option B: Require 50% of new market housing in Hull to contain at least 3 bedrooms, and 60-70% of affordable housing no more than 2 bedrooms.
Option C: Require 60% of new market housing in Hull to contain at least 3 bedrooms, and 50-60% of affordable housing no more than 2 bedrooms.
Preferred Option
6.25 Option C.
Draft Policy 8
Type and mix of housing
The Council will seek to re-balance the housing stock in the city, with the requirement that:
60% of new market housing over the plan period will contain at least 3 bedrooms; and 70-80% of new affordable housing over the plan period will contain no more than 2 bedrooms.
Justification
6.26 The Council is seeking to encourage a wider choice of homes in the city, and the SHMA 2013 has found a need for more 3+ bedroom family properties to be provided. This will assist potential buyers who presently look to the East Riding for their needs to be met. However, market conditions and demand for different types of property can change rapidly. It is therefore appropriate to seek an increase in the provision of larger family properties over the plan period with the understanding other factors may impact on affordability and drive demand for smaller properties. Regarding affordable housing, the SHMA found the need to be for 1- and 2-bedroom houses,
68 DRAFT JUNE 2015 Hull Local Plan: Preferred Options
particularly in response to recent and proposed welfare reforms. This takes account of smaller household sizes and will enable down-sizing from existing stock to occur. Housing on brownfield land
6.27 Developing previously developed (‘brownfield’) land in preference to greenfield is a more efficient and sustainable use of land. Around sixty percent of sites identified for potential allocation for housing in Hull are brownfield sites compared to 40 percent greenfield sites.
6.28 The Government has requested 90% of brownfield sites for housing are supported by a local development order (LDO). Given that in Hull the vast majority of housing will be on allocated sites, it is not considered necessary for allocated sites to be supported by an LDO. However large windfall sites suitable for housing and not needed for employment will be supported with the production of an LDO as they come forward.
You Told Us
There was general support for prioritising brownfield land, but with some reservations that this could hinder delivery of the housing requirement.
Others emphasised that, in accordance with the NPPF, brownfield sites with high environmental value should be excluded.
Options
Option A: Aim for 50% of new housing in Hull to be developed on brownfield land.
Option B: Aim for 60% of new housing on brownfield land.
Option C: Aim for 70% of new housing on brownfield land.
Preferred Option
6.29 Option B.
Draft Policy 9
Housing on brownfield land
The Council will encourage the re-use of brownfield land in the city, with the aim that 60% of new housing over the plan period will be developed on brownfield sites. Such sites should be suitable for housing and not needed for employment purposes.
DRAFT JUNE 2015 69 Hull Local Plan: Preferred Options
Justification
6.30 The NPPF encourages re-using brownfield land and allows local authorities to set a target for this. A majority of sites in Hull are brownfield and a target should encourage these sites to be prioritised for development. But this needs to be realistic and accept that some brownfield sites are not viable and a significant amount of housing over the plan period will be delivered at Kingswood. Affordable housing
6.31 Although house prices in Hull are relatively low by national standards, incomes are also low and consequently there is considerable demand for social housing in the city. It is expected that much of this demand will be met by the existing social stock and the private rented sector; however some new provision will also be needed.
You Told Us
There was only limited support for an affordable housing requirement.
Many commented that housing in Hull is already more affordable than in most other places and that the large stock of social and private rented housing is capable of accommodating the need.
Many believed that the imposition of an affordable housing requirement would undermine viability, and in combination with other planning requirements could make proposals unviable.
It was suggested that any affordable housing requirement should vary depending on its viability in an area.
Options
Option A: Require the following level of affordable housing provision in market housing developments, subject to viability:
15% in the City Centre, Newland and Avenue;
10% in Haworth Park area and the Western Suburbs areas; and
10% for the remainder of the city on sites of 15 or more dwellings.
Option B: 10% in all areas of the city on sites of 15 or more dwellings.
Option C: No requirement for affordable housing.
Preferred Option
6.32 Option B.
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Draft Policy 10
Affordable housing
Developers of market housing will contribute towards the supply of affordable housing by delivering the following gross affordable housing targets, subject to viability:
10% in all areas of the city on sites of 15 or more dwellings.
Justification
6.33 An objective of the NPPF is the creation of mixed and balanced communities, and providing affordable housing within market housing developments helps to achieve this. The Hull Strategic Housing Market Assessment (SHMA) 2013, and the Objectively Assessed Need for Housing in Hull: 2015 Update, identify a need for some new affordable housing provision. The SHMA suggested that in new developments an affordable housing target of around 15% may be appropriate. The Affordable Housing Viability Assessment 2011 suggested a variable requirement for different areas of the city. However a flat rate of 10% across the city is the preferred option. This reflects that Hull already has a good supply of existing affordable housing and the costs of building new affordable homes still remain relatively high. In addition there are few sites of 15 plus dwellings in Newland and Avenue and support needs to be given to affordable housing provision in the City Centre . Specialist housing
6.34 Specialist housing provides for people with specific housing needs, particularly in relation to impaired physical and mental health, and old age. The need for specialist housing is likely to increase in Hull as there is an ageing population and relatively high levels of poor health.
6.35 The City is the only council in the country delivering extra care accommodation (PFI) of over 300 units on 3 sites in the city.
You Told Us
It was recognised that specialist housing needs particular consideration with regard to flood risk, for example bungalows include ground floor sleeping accommodation and need to be located in the lowest risk flood zones.
Others referred to the need for specialist housing to be distributed around the city and close to shops, buses etc.
DRAFT JUNE 2015 71 Hull Local Plan: Preferred Options
Options
Option A: Identify specific sites for specialist housing.
Option B: Set locational criteria for specialist housing, e.g. flood risk, access to shops, bus routes, health facilities etc.
Option C: Support the provision of specialist housing in general, without setting locational criteria or identifying specific sites.
Preferred Option
6.36 Option B.
Draft Policy 11
Specialist housing
Specialist housing should be located with particular regard to flood risk and the likely need for its residents to access relevant services and facilities.
Justification
6.37 Residents in specialist housing are likely to need easy access to services and facilities such as shops, buses, and health. Flood risk is a particular issue. Specialist housing provision should therefore be located appropriately. Houses in multiple occupation
6.38 Houses in Multiple Occupation (HMOs) are prevalent in parts of Hull and can have a detrimental impact on local communities. However, HMOs are an important part of the housing supply. Planning permission is normally required to change a single family dwelling to a shared house of more than 6 unrelated people. Article 4 Directions can be introduced in specific areas to require planning permission for a dwelling to be occupied by 3-6 unrelated people. Limits can be placed on the number of HMOs allowed in an area. An Article 4 Direction already exists in parts of Northern and Wyke Committee areas in the vicinity of the University, see Map 6.1.
You Told Us
Concern was expressed that HMOs should be located in areas of lowest flood risk (as they usually include ground floor sleeping).
72 DRAFT JUNE 2015 Hull Local Plan: Preferred Options
Some wanted restrictions on the number of HMOs, referring to the problems caused by transitory occupiers and poorly maintained properties.
Others wanted to see no restriction on the number of HMOs and thought they should be provided to meet the demand.
Options
Option A: Introduce Article 4 Directions to limit the number of small HMOs allowed in specific areas of the city.
Option B: Limit the number of HMOs allowed in areas of the city where family housing needs to be protected.
Option C: Introduce no specific restrictions on the number of HMOs.
Preferred Option
6.39 Options A and B.
Draft Policy 12
Houses in multiple occupation
Article 4 Directions and limits on the number of HMOs allowed will be introduced in areas of the city where family housing needs to be protected or a specific need for an Article 4 Direction has been evidenced.
Justification
6.40 An over-proliferation in the number of HMOs can change the character of an area and undermine the creation of mixed and balanced communities. A limit on numbers may be needed in order to maintain the amenity of local areas.
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Map 6.1 Article 4 Direction
74 DRAFT JUNE 2015 Hull Local Plan: Preferred Options
Traveller provision
6.41 The Council is required to assess the need for traveller sites and to identify land for sites. Residential caravan accommodation is classed as ‘highly vulnerable’ in terms of flood risk and should not be located in zone 3. A recent survey (2012) indicated that 51 pitches are needed in Hull by 2028. With most of the city within Flood Risk zone 3, this will be a major challenge. The city currently has 70 residential pitches on four sites but no transit pitches or sites.
You Told Us
It was recognised that traveller sites should be located within flood risk zones 1 and 2 and not in zone 3.
It was also suggested that there should be a distinction between permanent residential use of caravans and transit/ temporary/ holiday caravans as the vulnerability classes are different.
Options
Option A: Seek to identify land to accommodate residential pitches for all traveller types in Flood Risk Zones 1 and 2. If there is insufficient land available in these zones, seek sites in Flood Risk Zone 3a if mitigation measures are possible.
Option B: Seek to identify land to accommodate residential pitches for transit/ temporary caravans in Flood Risk zones 1 and 2. If there is insufficient land available in these zones, seek sites in Flood Risk Zone 3a if mitigation measures are possible.
Option C: Seek to identify land to accommodate travellers only in Flood Risk Zone 1 and seek for any unmet demand to be provided in neighbouring local authority areas.
Preferred Option
6.42 Option B.
Draft Policy 13
Traveller provision
The Council will seek to identify sites to accommodate transit/ temporary traveller pitches, firstly in Flood Risk Zones 1 and 2, and secondly, if insufficient land is available in these zones, in Flood Risk Zone 3a if mitigation measures are possible.
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Justification
6.43 The Council is required to make provision for travellers but the areas where this can take place in Hull are limited owing to flood risk. Sites will be sought by following a sequential approach and applying the exception test, in accordance with planning guidance for flood risk. The government is intending to amend the definition of travellers to exclude those who do not travel. This is likely to reduce the requirement to provide permanent pitches but increase the need for transit sites. Designing for Housing
6.44 Housing development should create places which are attractive, safe and meet the needs of the residents. It has been identified throughout the plan that improving the quality of housing is an important aspect of the wider regeneration of Hull. In the case of many development sites in Hull, they will be integrating with the existing built form of the city. It is important that this is done sympathetically.
You Told Us
All homes should meet Secured by Design minimum standard which is higher than those proposed in the recent Level 2 security option. This is an important consideration in Hull and has value for some of the most vulnerable groups in our community. The Council also has a duty under the Crime and Disorder Act.
New speculative housing space and quality standards continue to fall.
The plan needs to think about people, the street and amenity.
An open and flexible approach often delivers a better result.
Residential developments should be designed to reduce the likelihood of crime, encourage community engagement and reduce social isolation.
Options
Option A: Do not include a specific policy about design of housing developments. Applications could be determined in line with the general design principles established in the Local Plan, with further detail from NPPF and PPG.
Option B: Include a policy setting out principles for design of housing developments. This would set out principles to be addressed without being overly prescriptive.
Option C: Include a policy requiring development to achieve 10 of the Building for Life standards. This would provide a recognised standard for development to achieve.
76 DRAFT JUNE 2015 Hull Local Plan: Preferred Options
Preferred Option
6.45 Option C.
Draft Policy 14
Designing for housing
Applications for housing development will only be allowed where it has been designed to achieve at least 10 of the 12 Building for Life levels.
Justification
6.46 The quality of housing is a key issue in Hull: it is necessary for a strong policy approach to reinforce this. For this reason, Option A is not taken forward. Design and distinctiveness policies elsewhere in the plan provide a sufficient local context to inform applications. Building for Life is a recognised standard which is achievable but provides flexibility for developers to reflect the circumstances of particular sites. For this reason, Option C is preferred over option B. Density
6.47 Hull is a high density city but the main demand now is for lower density suburban-type housing with car parking. Typical residential densities in the city are around 30 dwellings per hectare (dph), but they range from 25 to 250 dph. Lower densities do not make the most efficient use of land and can be out of character with the local area. It is anticipated that most development would be 30-40 dph, but higher in the city centre where flats will predominate. In assessing housing potential, the SHLAA uses indicative densities based on local neighbourhoods.
You Told Us
Many favoured flexibility regarding densities rather than strict requirements. Some supported higher densities in the city centre, and others preferred lower densities in general so as to attract families.
Options
Option A: Require a housing density of 30-40 dwellings per hectare (dph) across the city and 50 dph in the city centre.
Option B: Set housing density guidelines that vary across the city but are not a requirement.
Option C: No housing density requirement or guidelines in the city.
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Preferred Option
6.48 Option C.
Draft Policy 15
Density
Housing densities should encourage the provision of family housing and have regard to the surrounding area and existing character of the city.
Justification
6.49 Housing densities should encourage the provision of family housing but have regard to the existing character of the city. Given the aim to improve the range of housing stock and the large number of constrained sites, fixed density requirements would not be appropriate. A careful balance with housing needs has to be met and well designed high density development may be appropriate in locations throughout the city. Therefore it is not considered necessary to set a density requirement. Housing space standards
6.50 The government has proposed national space standards for new housing. However, the standards will be optional and only apply if local authorities include them in their local plans. The Council is therefore consulting on the standards as part of the local plan preparation process. The standards are set out in Table 6.5 below.
Table 6.5 Proposed National Space Standard – Minimum gross internal floor areas and storage (m2):
No of No of bedspaces 1-storey 2-storey 3-storey Built-in bedrooms dwellings dwellings dwellings storage
Studio 1 person 39 (37*) N/A N/A 1.0
1 2 person 50 58 1.5 bedroom
2 3 person 61 70 2.0 bedroom 4 person 70 79
3 4 person 74 84 90 2.5 bedroom 5 person 86 93 99
6 person 95 102 108
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4 5 person 90 97 103 3.0 bedroom 6 person 99 106 112
7 person 108 115 121
8 person 117 124 130
5 6 person 103 110 116 3.5 bedroom 7 person 112 119 125
8 person 121 128 134
6 7 person 116 123 129 4.0 bedroom 8 person 125 132 138
6.51 Hull local Plan 2000 Policy H12 sets minimum internal floorspace for properties before conversion to self-contained flats or houses in multiple occupation (HMOs). Hull Supplementary Planning Guidance (SPG) Note 17 advises minimum floorspace standards for properties after conversion to self-contained flats or HMOs. The standards are set out in Table 6.6 below.
Table 6.6 Hull Local Plan and SPG17 Standards for Conversions to Self-contained Flats and HMOs
Accommodation type Policy H12 – Minimum SPG17 – Minimum floorspace of property before floorspace of unit of conversion accommodation after conversion
HMO 150m2 30m2
Self-contained 1-bedroom 110m2 30m2 flat: 2-bedroom 45m2
3-bedroom 57m2
6.52 The Council’s Housing Service has amenity space standards for licensed HMOs in the city. The standards are set out in Table 6.7 below.
Table 6.7 Hull CC Housing Service’s Amenity Standards for Licensed HMOs
Shared house Bedsit/ Shared Bedsit house
Bedroom 1 occupier 6.5m2 1 10m2 1 15m2 occupier occupier
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2 occupiers 11m2 2 15m2 2 21m2 occupiers occupiers
Combined living room and 3-5 occupiers 11m2 N/A N/A dining space 6-10 16.5m2 N/A N/A occupiers
Combined kitchen and 3-5 occupiers 11.5m2 3-5 11.5m2 N/A dining space occupiers
6-10 15m2 6-10 15m2 N/A occupiers occupiers
Kitchen 3-5 occupiers 5m2 3-5 5m2 N/A occupiers
6-10 9m2 6-10 9m2 N/A occupiers occupiers
Combined kitchen, living 3-5 occupiers 16m2 N/A N/A and dining space 6-10 25.5m2 N/A N/A occupiers
You Told Us
Housing space standards were not considered at the Issues and Options stage.
Options
Option A: Require space standards for new housing based on the national standards in Table 6.5, for flat conversions based on the local standards in Table 6.6, and for houses in multiple occupation based on the local standards in Table 6.7.
Option B: Require other space standards for new housing, flat conversions and houses in multiple occupation.
Option C: No requirement for minimum space standards.
Preferred Option
6.53 Option A.
Draft Policy 16
Housing space standards
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New housing development should meet the minimum internal space standards set out in Table 6.5.
Flat conversions should meet the minimum internal space standards set out in Table 6.6.
Houses in multiple occupation should meet the minimum internal space standards set out in Table 6.7.
Justification
6.54 Research has found the UK to have the smallest average dwelling sizes in Europe. The government recognises this to be an issue and has proposed national minimum space standards to bring consistency across the country. Minimum standards mean that dwellings are more likely to meet the needs of residents. If standards in Hull were to be lower than the national standard, the city would find it more difficult to attract new residents. Residential gardens
6.55 Gardens are a significant element of housing development. They fulfil a number of functions, including amenity, but there is a common perception that garden sizes are reducing in recent developments. Garden sizes often result from considerations of ensuring adequate daylight and privacy in new dwellings. A commonly adopted standard is 21m back-to-back between the facing windows of 2-storey dwellings. This gives rise to a 10.5m length for back gardens, which, with a notional width of 5m for a new house, produces a benchmark minimum garden size of around 50m2 for a typical 2- or 3-bedroom family house. Flats have a different level of provision based on communal space for the occupants.
You Told Us
Residential garden sizes were not considered at the Issues and Options stage.
Options
Option A: Require a standard minimum garden size of 50m2 per dwelling or 25m2 per flat.
Option B: Require a minimum garden size based on the dwelling type, e.g. terraced 50m2, semi-detached 60m2, detached/ bungalow 70m2, flats 25m2.
Option C: Require a minimum garden size based on the number of bedrooms, e.g. 1-bedroom 40m2, 2-bedroom 50m2, 3-bedroom 60m2, 4+ bedroom 70m2, flats 25m2.
Option D: No minimum garden size requirement.
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Preferred Option
6.56 Option C.
Draft Policy 17
Residential gardens
Residential development should provide each dwelling with a garden based on the following minimum sizes:
Houses: 1-bedroom 40m2, 2-bedroom 50m2, 3-bedroom 60m2, 4+ bedroom 70m2.
Flats: per unit 25m2 communal provision.
The garden should be orientated and designed to provide appropriate amenity, leisure and garden space.
Justification
6.57 A minimum size of garden is required to ensure that residents can enjoy amenity, daylight and privacy. A standard based on the number of bedrooms relates the requirement to the likely number of occupants of the property. Residential extensions and alterations
6.58 House extensions and alterations have the potential to have a significant impact on the amenity of the surrounding neighbours. The relatively small size of houses in Hull means that extending property is often a logical step for householders to take.
You Told Us
No comments were received specific to this issue.
Options
Option A: Do not have a policy on extending property. Having a policy on house extensions may be considered too onerous. A supplementary planning document could be developed which could be aligned with the key design policy.
Option B: Have a policy on extending property. A policy could clearly establish the considerations when designing house extensions.
Preferred Option
6.59 Option B.
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Draft Policy 18
Residential extensions and alterations
House extensions should be designed to minimise their impact on the amenity of neighbouring occupiers and the surrounding area. The design should:
1. Not over-dominate or unduly enclose the neighbouring properties or the property itself 2. Minimise the impact of overshadowing, loss of daylight and loss of privacy 3. Be subordinate to the main dwelling 4. Be well related to the existing building in terms of size, siting, materials and detailing. 5. Not lead to a reduction in garden space to below that stated in draft policy 17. 6. Respect the context of the surrounding area
Justification
6.60 House extensions are commonplace in Hull due to the generally small size of dwellings in the city and the City Council is keen to support residents who wish to remain living in the city. However, much of the city’s housing stock is terraced and/or designed at a relatively high density. This means that there is potential for conflict. It will be of use to householders and designers to be clearly aware of what is expected from house extensions, and a specific policy is considered to be the most effective approach. Inclusive housing design
6.61 Inclusive housing design is about ensuring that new housing meets the needs of a wide range of people in society, including those with a physical disability. In particular, inclusive design should make wheelchair access possible by making the entrance and ground floor step-free, and by making sure that doors and stairs are wide enough for disabled users. Although many households will not need these design features at present, due to illness or accident they may need them at some point. Building more homes that are accessible and adaptable to wheelchair users will mean that the occupants can stay in them for longer.
6.62 NPPF (2012) requires local planning authorities to:
Plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community (including older people and people with disabilities).
6.63 The National Planning Practice Guide goes on to say that it is critical to provide housing for older people given the projected increase in the number of households aged 65 and over.
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6.64 The Newington and St Andrews and the Holderness Road Corridor AAPs both made the Lifetime Homes standard a policy requirement in order to address this issue. Lifetime Homes is a set of 16 design criteria maintained by Habinteg to ensure that homes are accessible and inclusive. However, in March 2015 the Government issued a Ministerial Statement that tells planning authorities that they should no longer require Lifetime Homes. Instead, we can specify new optional Building Regulations for improved accessibility and adaptability.
6.65 With regards to accessibility, the existing mandatory Building Regulation is:
Part M4(1) - visitable dwellings
6.66 And the new optional Building Regulations are:
Part M4(2) - accessible and adaptable dwellings Part M4(3) - wheelchair adaptable / accessible
6.67 The Government guidance tells us that planning policy should state clearly what proportion of new dwellings should comply with the optional building regulations. The requirements need to be justified with the evidence that demonstrates that there is a need and that the impact on viability has been considered.
6.68 Part M4(2) is considered to be roughly equivalent to the Lifetime Homes standard. Part M4(3) is a much higher standard that attracts considerably higher costs. Although it is desirable for the city to have some new Part M4(3) dwellings, these are only likely to be delivered as specialist social housing. We therefore do not think it appropriate to require M4(3) dwellings from developers alongside general-purpose residential housing.
6.69 In terms of need, in 2013, 805 households who took out a new social housing tenure in Hull did so because they had a disability-related housing design or adaptation requirement. In the same year there were 155 households on the housing waiting list that had to move on medical grounds, which included grounds relating to disability. These indicators of demand are likely to increase with time. The Council's Strategic Housing Market Assessment predicts that there is likely to be a 60% increase in the population aged over 85 from 2011-30. In addition, there is forecast to be a 40% growth in people with mobility problems over that same period.
6.70 A key consideration in Hull when considering setting a requirement for more accessible homes is flood risk. Because much of the city is in Flood Zone 3, ground floor levels have to be raised, which makes providing a step-free entrance more difficult. In addition, build costs are often higher, which, when coupled with low sale prices, means that development viability is often marginal. Additional requirements can risk making new development
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unviable. We will consider the cumulative impact on viability of all the requirements in the Local Plan before we submit it to the Government Planning Inspector for examination.
You Told Us
Lifetime Homes need to take account of the impact of flood risk over the lifetime of the development. Set standards too high and you will defeat the plan where you want to build more houses. Much of the city has significant viability issues and therefore inclusion of additional standards over and above the building regulations are likely to compromise overall plan delivery. It is expected that the population will get older and more people will suffer from dementia. Standards should therefore include higher safety standards such as domestic sprinklers, and adaptive technology such as automatic gas cooker shut-off devices. Bungalows with 2 bedrooms as well as 1 bedroom bungalows are urgently needed, mainly for elderly people, some of whom have disabilities. As there are young disabled people who need bungalows, these should be built in several areas so that young people can make a variety of friends. A disabled person of 30 will find life harder if all the neighbours are 70+.
Options
Option A: New dwellings should be built to Building Regulation M4(2) standard unless it is agreed that it is not feasible due to physical constraints. An example of a physical constraint is when there is insufficient room for a ramp up to the entrance. It should be noted that this option does not consider development viability and so could dissuade developers and thereby reduce housing delivery.
Option B: New dwellings should be built to Building Regulation M4(2) standard unless it is agreed that it is not feasible due to physical constraints or it is not viable to do so. Developers will need to submit a viability statement which clearly demonstrates that complying with the policy is not viable under realistic circumstances.
Option C: A proportion of new dwellings on each site to comply with Building Regulation M4(2). This policy could set a percentage of dwellings in each development that should comply. It allows for the fact that in many cases it will not be feasible or viable for all dwellings to meet the standard. For example, approximately 30% of new dwellings built recently in the Newington and St Andrews area are set to meet the Lifetime Homes standard.
Option D: All new dwellings built in Flood Zone 1 to comply with Building Regulation M4(2). This is a similar policy to that proposed in the forthcoming Kingswood AAP. Flood Zone 1 is the lowest flood risk area and therefore it represents a safer place for people with mobility issues to live. Typically there are also lower costs associated with building in Flood Zone 1, and it does not require
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the raised ground floor levels that areas of higher flood risk require. The disadvantage is that there are few areas in the city that are in Flood Zone 1 - most areas lie in Flood Zone 3.
Option E: Do not set a policy requiring optional building regulations. This could be because you do not think that there is sufficient evidence of need or viability to justify such a policy.
Preferred Option
6.71 Option B in order to require M4(2) dwellings, plus an allowance for M4(3) dwellings in certain circumstances.
Draft Policy 19
Inclusive housing design
1. New dwellings should be built to Building Regulation M4(2) standard unless it is agreed that:
it is not feasible due to physical constraints; or it is not viable to do so.
2. The City Council will seek to deliver dwellings built to Building Regulation M4(3) on suitable housing sites, when there is a demonstrated need.
Justification
6.72 This preferred option should help address the issue of an ageing population by requiring as many new dwellings as possible to comply with Building Regulation M4(2). At the same time, the policy should not discourage developers from building in the city in circumstances where delivering the enhanced standard would not be feasible or viable. Supporting Evidence
Sustainability Appraisal Objectives
2. Maintain and enhance water quality and limit water consumption to levels supportable by natural processes and storage systems, taking into account the impact of climate change;
3. Ensure that new development does not increase flood risk and protects or enhances the capacity and integrity of flood storage areas;
4. Minimise the loss of soils to new development and encourage remediation of contaminated land;
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5. Reduce the impacts of climate change, with a particular focus on reducing the consumption of fossil fuels and levels of CO2;
6. Ensure that development is capable of withstanding the effects of climate change;
7. Achieve good air quality;
8. Maximise the use of previously developed land and buildings, and the efficient use of land;
9. Use natural resources, both finite and renewable, as efficiently as possible, and re-use finite resources (including waste) or recycled alternatives wherever possible;
10. To maintain and enhance historic and cultural assets;
11. Conserve and enhance the landscape and townscape, encouraging local distinctiveness;
12. Encourage healthy lifestyles and reduce the health impacts of new developments;
13. Deliver more sustainable patterns of development by ensuring links to a range of modes of transport;
14. Promote equity and address social exclusion by closing the gap between the poorest communities and the rest through a more equitable sharing of the benefits of prosperity;
15. Ensure that everyone has access to good quality housing that meets their needs;
16. Enhance community identity and participation;
17. Reduce both crime and fear of crime;
19. Ensure that people have equitable and easy access to shopping, community and other services and facilities;
Sustainability Appraisal Working Paper Comments
The SA Working Paper found some specific areas that will need further improvement. Regarding housing, within the phasing of the housing delivery during the plan period it recommended considering a flexible approach in terms of delivery that anticipates and responds to market demand, as well as a planned approach, in association with East Riding of Yorkshire.
Main Evidence Base Sources
Hull Strategic Housing Market Assessment (SHMA) 2013
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Hull Strategic Housing Land Availability Assessment (SHLAA) 2014
Objectively Assessed Need for Housing in Hull: 2015 Update
Local Authority Housing Statistics - https://www.gov.uk/government/collections/local-authority-housing-data
COntinuous REcordings (CORE) - https://www.gov.uk/government/collections/rents-lettings-and-tenancies
Ministerial Statement (March 2015) – https://www.gov.uk/government/speeches/planning-update-march-2015
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7. City Centre Introduction
7.1 The city centre performs a key economic, strategic and cultural role as the focus for the city and the wider region stretching out to areas of the East Riding and beyond. It plays a key role in taking forward one of the main themes of the City Plan – to make Hull a World Class Visitor Destination by improving the offer of the centre and by making the most of the city centre as a window on the city through which to raise its profile.
7.2 The city centre has many roles to fulfil. It is a key economic driver for the city, as a location for large-scale shopping, leisure, food and drink, financial and cultural activities. It is also a location for a significant proportion of the city’s office-based businesses. The centre also serves to meet the needs of Hull’s residents through the service and community facilities available, including local government offices and schools and colleges. The city centre also has an established resident population and will continue to be a location for housing development, often as part of a mix of uses within larger regeneration and redevelopment projects.
7.3 These uses allow the city to attract inward investment which brings economic benefits to the whole of Hull. Defining the City Centre
7.4 To bring clarity to how and where future policies might apply it is critical to define exactly which properties and locations will be defined as being within the city centre. The Local Plan 2000 defined a boundary to the city centre as the basis of determining where specific policies would apply. In many respects this boundary remains relevant, with a clear city centre core. However, there are some locations which suggest options to alter this boundary, particularly around more peripheral areas where uses and ambitions for areas suggest city centre policies will not be relevant. By redefining some of these areas as essentially edge of centre would not necessarily preclude certain uses from being located here but it does allow the plan to give greater clarity to the future direction, and being edge of centre ultimately allows greater scrutiny to proposals for development in these locations.
7.5 The northern edge of the city centre boundary could be more sensibly defined by Freetown Way which forms a physical barrier to easy pedestrian movement, but perhaps more importantly the areas to the north of Freetown Way are characterised by residential and industrial uses which don't serve as city centre uses. There are some office and college uses within these locations, for example at Blundell's Corner at the corner of Beverley Road
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and Spring Bank, and around Syke Street. Although these are still relatively peripheral locations, they do contribute to the commercial and educational roles of the city centre.
7.6 To the east of the city centre, the area called Garrison Side is largely industrial in nature and does not have a clear relationship with the city centre. This should therefore not be designated as within it. The Premier Inn and strip of land running adjacent to the River Hull, including the site of the former Clarence Mill being developed for hotel and student accommodation, do have strong links, particularly through the new footbridge and therefore indicate where a boundary should be designated.
7.7 The south of the city centre is defined by the waterfront areas along the Humber frontage that are a critical part of the growth plans for the city centre economy. There is a question of whether to include the more peripheral areas of Kingston Retail Park, the Ice Arena, Cinema and Tennis Centre. The Retail Park operates as a largely self contained location with dedicated car parking which doesn't readily encourage linked trips with other parts of the city centre. However in a broader sense it potentially adds to the wider commercial purpose of the city centre. Equally the leisure facilities contribute to the city centre offer. This would suggest that they be designated as within the city centre.
7.8 The western edge of the city centre is defined largely by Ferensway, the transport interchange, and St Stephen's shopping centre. To the rear of St Stephens and around Spring Street there are office uses, as well as opportunities for development which, while appearing more as back land in character, could still support uses that support the functioning of the city centre. Areas along Anlaby Road up to Park Street offer opportunities for significant regeneration recognising the potential for this to be a key gateway to the city centre, particularly connected with the railway station.
You told us
Suggest the City Centre boundary includes the whole of Humber Quays development site.
Suggest the boundary should include Park Street.
Suggest excluding properties lying within the Spring Bank Conservation Area, properties lying within the southern part of the Beverley Road Conservations Area, much of the area between Anlaby Road and St Luke's Street, area to the west of Commercial Road / Manor House Street, and area lying to the north of Freetown Way.
Suggest the boundary should include the whole of the English Street area including Smith & Nephew, Albert Dock and part of the Great Thornton Street Estate (around the A63).
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Suggest should exclude all areas east of the River Hull (except the Deep and surrounding area) all areas north of Freetown Way and Park Street area.
Definition of broad areas within the city centre based on current and emerging roles considered of extremely limited value and little benefit in guiding future development
Support for defining broad areas but boundaries would need redefining.
Should not use broad areas to reserve them for specific uses as flexibility is the key to delivery of a viable development.
If areas to be subdivided need to link to a strategy for each area, and define uses accordingly.
It would be helpful to be able to identify those areas where policies for the conservation of the historic environment.
In the long term could the Citadel be included in the City Centre.
Support for a more compact City Centre.
Question of what constitutes a city centre use.
Options
Option A: Adopt a widely defined boundary similar to that in the saved Local Plan 2000.
Option B: Define a boundary based on the suggested alterations described above.
Preferred Option
7.9 The preferred option is Option B. The following map illustrates a preferred option for how the city centre boundary could be defined. It is shown alongside the boundary of the city centre as defined by the Saved Local Plan 2000.
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Picture 7.1 Proposed City Centre Boundary
Shops and Services
7.10 For many residents and visitors, the primary role of Hull city centre is as a destination for shops and services. Despite some challenging economic circumstances the centre continues to perform relatively well. The city centre is the primary location for large scale retail and retail that draws from a significant catchment. The city centre is ranked 32nd in the UK's top shopping locations. For it to retain or improve this ranking and therefore to support the economic growth potential of the centre, it is critical that this shopping role is supported by giving it appropriate focus. Chapter 8, 'Shops, Service and Community Facilities', sets out the overall hierarchy of centres in the city. It clearly defines the city centre at the top of this.
Primary Shopping Area
7.11 To enable the Local Plan to give a coherent direction for retail development in the city centre it is necessary to designate a primary shopping area as NPPF directs. This is defined based on an assessment of what properties make up what are termed primary and secondary frontages. Primary frontages are those which typically include a high proportion of shops and retail services, particularly high street shops. They tend to be where footfall is highest and therefore present the core of the retail centre. Secondary
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frontages usually adjoin primary frontages and offer greater scope for a diversity of uses such as more independent shops, retail services, including restaurants and financial services and other business uses.
7.12 Recognising the primary shopping area as the focus for major investment in shops is important to the future success of the city centre’s role. Within the city centre a key driver for retail location is footfall. Retailers seek to locate where this is highest, allowing them to attract in as many shoppers as possible, maintaining the required financial turnover of stores. It is well known that anchor stores can drive the success of particular locations. Of key importance to the city centre is therefore how people circulate within shopping centres and between them along main high streets, and therefore an understanding of what makes up the core of the shopping centre should guide future plans for expansion of retail floorspace in the city centre. Without this focus and understanding of how retailers function could lead to a more dispersed approach which ultimately could undermine the strength of the core retail locations in the city centre.
7.13 Retail and leisure provision is focused within the city centre's three shopping centres, St Stephen's, Princes Quay and the Prospect Centre, as well as those locations which serve as the centre's traditional shopping high streets, including Jameson Street, Prospect Street. King Edward Street and stretching along Whitefriargate. Other locations around these, along Paragon Street and Carr Lane and parts of the Old Town provide a more secondary offer, including larger numbers of services. These areas therefore define what should form the primary shopping area for the city centre.
7.14 The St Stephens shopping centre has helped the city centre to strengthen its attraction as a retail destination and maintain the centre's ranking in the UK's top shopping locations. However, recent years since the opening of St Stephen’s shopping centre have seen shifts in terms of the strength of retail function of other areas of the city centre, with a corresponding fall in footfall, and resulting high levels of vacancy in shopping areas such as Whitefriargate and Princes Quay. A strategy for change is important, either through revitalising areas through active management, for example using pop-up shops or mean-while uses, with a view to either attracting back more permanent occupiers, particularly leading high street stores, or through changing the role of areas. Princes Quay Shopping Centre has suffered loss of retailers, but has adopted a strategy towards attracting leisure operators, including a cinema, bowling alley and restaurants.
7.15 The changes and demonstrated weaknesses certainly reinforce the need for a strong focus within the wider city centre, to enable a policy approach to be applied that enables the Council and partners to properly manage uses. It was suggested in the Issues & Options document that a primary shopping area should be defined to reflect how the centre functions and how the primary shopping area can therefore best enable a policy framework that seeks to fully support aspirations for a growing and more prominent city centre. The saved policies of the Local Plan 2000 defined a much broader 'central shopping area' to guide the application of policies. Such a
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broad area would not provide the focus that would be expected to promote a strong and competitive retail core. The central area included Queens Gardens, and other streets around the centre which are characterised by residential and office uses rather than strong shopping frontages.
7.16 The primary shopping area will guide the application of the sequential approach to directing future retail development as required by NPPF. (see Chapter 8) Other areas of the City Centre could be classed as edge of centre or out of centre for the purpose of locating retail development. The primary shopping area will also guide policies that enable management of the range and location of uses, and ultimately the vitality and viability of the City Centre.
7.17 It was suggested in the Issues and Options document that the area of land adjoining Princes Quay, known as Quay West, could be included in the primary shopping area. This was based on the potential for significant retail development on the site that would support main high street shops typically expected within a primary shopping area. Emerging plans for the site indicate that a significantly reduced shopping development could come forward on the site and therefore it would not be appropriate to extend the primary shopping area across this area.
You told us
Suggestion that the boundary of the primary shopping area should include the area to the West of Myton Street and the land to the east of Waterhouse Lane that is currently used as Princes Quay car park and service yard. An alternative view was that the primary shopping area should not be expanded to include proposed retail development until it is delivered, otherwise there is a risk that other out of centre locations could be considered edge of centre locations in the interim to development coming forward.
Disagree with the primary shopping area including the area between Myton Street and Waterhouse Lane and suggest that this should be developed as a conference complex.
Support contracting the extent of the existing core retail area of the city centre (as shown in the 2000 saved Local Plan) but suggest that the PSA boundary may need to be reduced further in order to ensure the continued vitality and viability of the heart of the city.
General supporter for focusing on the primary shopping area, particularly around the three main shopping centres in the city centre.
Options
Option A: Define a wide shopping core similar to that adopted in the saved policies of the Local Plan 2000.
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Option B: Define a primary shopping area based on how retail operates within the City Centre enabling the City Centre to continue to perform strongly.
Preferred Option
7.18 The preferred option is B. The following diagram illustrates how the primary shopping area could be defined in the city centre based on the pattern of current shopping provision:
Picture 7.2 Proposed City Centre Primary Shopping Area
Primary Shopping Frontages
7.19 NPPF also states that primary frontages can be defined to guide policies for where changes of use might be more acceptable. The Government has introduced greater flexibility to change of use from retail to office and residential. By defining a strong frontage policy the Council has the ability to still retain control of uses within shopping areas. Pressure exists for change of use within some areas of the city centre. This may be appropriate where there are strategies for change recognising new roles for areas, as referred to above, but equally such pressure should not be allowed to undermine the retail function of core areas of the city centre. The saved policies of the Local Plan 2000 do not designate primary frontages.
You told us
General support for the primary frontage as defined, although suggestion that it should include Whitefriargate.
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Options
Option A: Do not designate primary frontages
Option B: Define primary frontages based on areas where there are strong representations of main high street retailers and a high proportion of comparison shops.
Preferred Option
7.20 The preferred option is B. The following diagram illustrates where primary frontages could be defined within the city centre:
Picture 7.3 Proposed Primary Frontages
Maintaining vitality and viability
7.21 NPPF states that local planning authorities should be positive and promote competitive town centre environments, as well as setting out policies for the management and growth of centres over the plan period. They should also pursue policies to support their vitality and viability. Vitality and viability is a term which references a number of measures which are considered act as indicators of health or performance of a centre. They include; diversity of uses (e.g. retail, leisure and services offer), retailer representation and demand, vacancy, accessibility and parking provision, quality of environment, investment and footfall. From these measures it becomes clear how different actions can be taken to maintain or improve vitality and viability of centres.
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7.22 Diversity of uses and retailer representation is assessed based on unit and floorspace data gathered through street survey. Comparison of time series data allows a review of change, and comparison of mix with other city centres allows relative performance to be determined. It is important because it helps define the role and make up of the centre and to understand how this needs to be maintained or might change to improve peoples access to shops, services or other facilities.
7.23 The city centre is dominated by comparison retailing with 41% of shops in the primary shopping area occupied by comparison retailers, compared to 6% of shops by convenience retail. 35% of units are occupied by service uses which include retail services, financial and personal services as well as food and drink and leisure providers. Financial services include key retail banks which are often an important part of the mix of high streets within high footfall areas, often designed now to have active frontages. Personal services include hair salons, launderette's and post offices. These tend to be located in more secondary areas.
7.24 The city centre is the focus of a number of main high street retailers with a large number of national or regional chains or multiples. These are important because of the draw they have. People often identify with particular brands and will travel to fulfil these needs. Accommodating these is therefore seen as a critical part of a strategy towards maintaining a strongly performing centre. St Stephen's has been successful largely because of its ability to attract these major brands - some of them new to Hull. Linked to this is the demand from some of the leading retail companies for accommodation that meets strict operating requirements.
7.25 Secondary and peripheral areas feed off the higher footfall of people visiting the shops within primary frontage properties. They play an important contribution to the overall offer and critical mass of the city centre. These areas can also be important in providing for the resident population of the city centre, providing for day to day shops and services, as well as passing trade from commuters and visitors.
7.26 The city centre has seen a growth in the convenience offer. The large Tesco Extra within St Stephens provides a substantial floorspace split between comparison and convenience goods. It serves city centre shoppers but will also serve bulk food shopping needs for a large catchment in areas adjoining the city centre. More centrally there are now a number of smaller format convenience food outlets. Convenience shopping occupies a relatively small proportion of the market within the city centre, reflecting how people meet their main bulk food shopping requirements in supermarkets or stores elsewhere, using the city centre as a focus for fashion and other higher value goods.
7.27 The main policy options considered within this section of the document consider how to manage the change of use of units, to maintain and improve diversity and retailer representation that is optimum for a strongly performing city centre. Typically this is done through determining the range of acceptable
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uses within frontages. This can be controlled by setting proportions, either through numbers within areas, or through measures of lengths of frontages. While the types of shops and services in a centre can be classified by type, for example comparison and convenience shops, and this is the basis for estimating future need for shops, the classification of an occupiers use for the purpose of controlling any change is made according to the Town and Country Planning (Use Classes) Order 1987 and Use Classes Amendment Order 2005. Within this categories are relatively broad. The A1 use class includes all shops, but also retail services including for example post office, travel agent, hairdressers. It does not include professional and financial services, including banks (A2) or food and drink uses (A3 - A5).
7.28 Classifying uses according to use class shows that approximately 56% of all units within the Primary Shopping Area of the city are in A1 use. Within Primary frontages the proportion is higher at 68% in A1 uses. Within Secondary frontages 44% of uses are A1. Secondary areas are characterised by a higher proportion of food and drink uses as well as leisure, medical and government services. Food and drink uses are a key part of the city's role as a visitor attraction. Within Primary Frontages 8% of uses are food and drink (A3 - A5). The majority of food and drink uses (22%) are located in surrounding Secondary frontages.
7.29 Vacancies within both primary and secondary frontages are high with 15% of units within primary frontages vacant, and 19% in secondary frontages and it will be necessary to apply strategies that encourage reoccupation of these units to strengthen the health of the city centre.
7.30 Accessibility and parking is considered in the Transport Chapter under City Centre Parking.
7.31 Quality of the environment is considered in the section below - Leisure & Tourism - which considers the wider environmental quality of the city centre related to planned improvements identified through the City Plan and planned to support the objective of making the city a world class visitor destination. The Design and Heritage chapter also considers quality of design in the city centre. Significant improvements to public realm are planned as part of City Plan investment in the city centre.
You told us
No requirement for additional restrictions to those embodied within NPPF if the primary shopping area and primary frontage are defined appropriately. Suggest a flexible approach
Supportive of proposals to restrict change of use within the Primary Retail Frontage to prevent activities likely to threaten the vibrancy of the area. However need to be clear that long term viability is unlikely to depend on retail use alone and there will be a need to provide for an increasing amount of leisure based development.
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The Local Plan needs to address the continuing decline in the heart of the Old Town (including Whitefriargate) and suggests that strategies to revive these areas need to be more flexible than on the past, allowing alternative uses (including meanwhile uses).
Not entirely supportive of the PSA boundary given the quality of some of the retailing and retail buildings covered by it.
Shopping habits are changing (home delivery networks, internet shopping etc.) - question of how the Local Plan recognises this.
Plan needs flexibility in order to consider the wider cultural needs of the city by linking these with the shopping offer to enhance the visitor attraction.
Whitefriargate needs more investment following a shift of retailing, and may be a change of focus for the area.
Options
Option A: Within primary frontages just control change of use from retail use , 'A class', to other non A uses - so not being prescriptive about proportions allowed within the 'A class'.
Option B: Within primary frontages control change of use from A1 shops to other uses to maintain the level of 70% of all units within primary frontages as A1 use. Within other parts of the primary frontage allow other A class uses but do not allow non retail (non A uses).
Option C: Within primary frontages prevent an over concentration of uses which can disrupt active frontages to prevent fragmentation of frontages and disruption to footfall and dilution of primary retail use.
Option D: Within primary frontages control change of use from A1 shops maintaining a percentage based on the length of frontage rather than number of units within A1 use.
Preferred Option
Options B and C are the preferred approach. A potential policy is:
Draft Policy 20
Maintaining Vitality and Viability
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1. A concentration of shops with ground floor frontages should be maintained in the primary shopping areas of the city centre to promote its continuing vitality and viability. Proposals for non-retail use (non A1) should not result in the proportion units within the retail frontage falling below 70% in primary frontages and below 45% in secondary frontages.
2. Proposals for uses outside the 'A' Use Class will not be permitted within designated ground floor primary frontages.
3. Change of use from A1 shops to other A class uses will not be permitted within primary frontages where this would lead to an over concentration of non shopping uses that would lead to inactive frontages, including to food and drink outlets with limited day time opening hours.
Justification
7.32 The preferred option suggests maintaining a proportion similar to existing, with approximately 70% of all units retained in A1 use. It could be suggested this should be higher. There is scope for example for vacant units to be occupied. If these were occupied by A1 units then this could push the proportion much higher, to around 80%. Ultimately it will depend on where these vacant units are located within frontages, whether it is equally appropriate for other A uses to be located within a frontage. For example retail banks can contribute to a strong frontage as much as a shop. Therefore it would be appropriate to have a policy which retains a proportion similar to the existing split of uses.
7.33 Critical to the success of the centre is footfall. While an overall proportion of uses guides the broad makeup of centres, the mix also influences how individual streets or runs of shops operate. For example, if a number of financial, professional or food and drink uses locate close together this could lead to a lack of active frontage. It is therefore appropriate that policy allows control of uses to prevent an over concentration. Food and drink uses can have restricted opening hours which might impact on frontages being shuttered during the day.
7.34 Adopting a much more flexible approach as in Option A, restricting use just with in the 'A class' range of uses, could potentially undermine stronger retail frontages and undermine the ability to manage uses within the primary shopping area. The suggested preferred threshold still provides for a significant element of flexibility for accommodating a range of different uses within primary and secondary frontages of the city centre.
7.35 Controlling use by frontage length, as suggested in Option D, could be an appropriate way of directing policy. However length of frontage within each use class is not available. Further evidence will need to be collected to support such a policy.
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Allocating for future retail growth
7.36 The Hull Retail Study 2013 identifies a need for up to 56,000m2 of new comparison floorspace in city over the plan period. There is scope for some of this need to be absorbed by reoccupation of vacant units by new businesses, with the Retail Study identifying 17,500m2 of vacant retail space within primary frontages. However inevitably there is pressure from retailers to provide for new requirements, both size and layout, and this translates to need for new development. It was previously identified that a substantial amount of projected retail expenditure growth could be accommodated within a major development scheme on land adjacent to Princes Quay Shopping Centre, known as Quay West. The scope of this area to support major retail development is now much reduced. There may therefore be need to identify, or make allowance for further retail development in other locations within the city centre. Outside of the City Centre there could also be scope for meeting this need in other locations where development needs are identified, and where any schemes can demonstrate that they will not adversely impact on the City Centre. Kingswood District Centre has been designated within the Kingswood Area Action Plan and defined to allow for identified expansion pressures in that location.
You told us
Retail, as the review of Kingswood Retail Park has shown, is continuously evolving so options must be kept flexible.
The evidence of retail need in the town centre means the Council should direct new retail into the City Centre before identifying new land elsewhere in Hull. The Local Plan should clearly demonstrate how identified retail need is being accommodated within the City Centre.
Options
Option A: Don't allocate to meet estimated needs for future floorspace development.
Option B: Allocate specific sites to meet identified need.
Option C: Allocate general opportunities for where need could be met.
Preferred Option
Option C
Draft Policy 21
Allocating for future retail growth.
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The City Centre will be planned to accommodate development of additional comparison retail space, within an extension to Princes Quay, through occupation of vacant retail space within Primary Frontages and in other areas within or closely related to the Primary Shopping Areas.
Justification
7.37 The preferred option takes into account that there are significant uncertainties for how schemes could come forward within the City Centre, while still providing a general steer as to preferences for how future development within the City Centre could be brought forward, particularly within the larger development opportunities (see section below).
7.38 Option A would give little clarity in the plan.
7.39 Option B is not feasible given lack of clear schemes for retail development within the larger development opportunities identified within the City Centre.
Retail Warehouses
7.40 Retail Parks and Retail Warehouses exist in several locations across the city. They have become established as shopping destinations given the range of popular brand retailers that have located within them. It is recognised that the Primary Shopping Area of the City Centre will not be an appropriate location for large scale retail warehouse type retailers who operate on the basis of selling bulky items often within large scale show room environments, for example furniture stores, or stock large volumes of items, for example DIY and household goods . As current retailers within these locations currently operate to strict conditions as to the range of goods they sell, and to prevent such locations being significant destinations for major retail that can compete with the City Centre, any future development of this nature outside of the city centre should be controlled by condition to prevent impact.
You told us
Support the retail warehouse allocation on Clough Road as it will provide certainty for current and future investors.
Should set a criteria for retail parks based on the robust NPPF test of impact and the sequential approach, although an element of flexibility is required to accommodate new and emerging retail formats which may not be appropriate for city locations.
Support a plan led approach where it intends to support non-bulky retailing.
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There is an opportunity to explain what is defined as a 'bulky good' - this definition should include office supplies, pet supplies and toys.
Shouldn't allow out of centre retail warehouse developments - should always prioritise the city centre first.
Options
Option A: Do not give recognition to existing retail warehouse locations as a location for future retail development, limiting those that exist to their current extent and directing all future development to retail centres.
Option B: Give recognition to retail warehouse locations as an established place for certain types of retailing, but put in place controls to prevent retail development that could adversely impact on the City Centre or District Centres.
Preferred Option
The preferred option is B
Draft Policy 22
Retail Warehouses
1. Where it is demonstrated through a sequential test that large scale retail is of a nature and format that cannot readily be located within the Primary Shopping Area of the City Centre, or areas on the edge of this, then, subject to the proposal not having an adverse impact on the City Centre or District Centres, it will be expected that such development will be directed to existing retail warehouse locations so as to promote linked trips and make best use of existing infrastructure where possible. Development within these locations will be subject to conditions controlling the range of goods, and amount of floorspace devoted to certain goods, where these criteria are used to justify how a potentially adverse impact on the City Centre or other defined centres is mitigated.
2. General A1 retail development will not be supported within retail warehouses simply on the basis of scale.
Justification
7.41 Option B provides the most realistic option, reflecting the approach that has been applied successfully to proposals for retail warehouse type development within the city. It is recognised that the type of retailing located within these locations is of a type and nature that can operate successfully under restrictive planning conditions.
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7.42 Option A promotes a centre focused approach to retail development which supports broad objectives but does not take account of the practical limitations of providing for certain retail formats within centres in the city. Leisure and Tourism
7.43 The City Plan recognises that the city’s culture and history play a key role in attracting more people to come to the city centre bringing significant economic benefits. The city’s successful City of Culture bid has brought these elements to the fore.
7.44 The city is increasingly attracting attention, providing events and venues that attract visitors from a wide area. These include large-scale events like the annual Freedom Festival, as well as attractions such as museums, the iconic Deep Submarium, renowned arts venues, theatres and top flight sporting events. The City Plan is supporting projects including remodelling of Hull New Theatre and Ferens Art Gallery. It is also supportive of proposals of a new conference facility on the site adjacent to Princes Quay Shopping Centre, and a cruise terminal on the river frontage at the Deep.
Public Realm and Heritage
7.45 Important facilities that support the stay of visitors include hotels, restaurants and bars. Specific opportunities have been identified for hotel development in the city centre on the site of the former LA's nightclub west of Ferensway, and at Trinity Quays.
7.46 It is also important that the routes people use to access the city, particularly along main arterial roads and at key destinations for public transport, provide a positive impression. Design briefs have been prepared for key development opportunities that exist in the city centre with the intention of promoting this positive approach. Further detail of how the Local Plan supports design is provided in chapter 9 of the Local Plan.
7.47 The City Plan supports a number of projects within the city centre which are supportive of the general quality of the public realm of the city centre. It will be critical to the success of the centre in the future that strong linkages can be made between key parts of the centre to maximise the wider economic benefits of tourism. Strongly defined routes could revitalise public realm and encourage new uses within areas of the centre that have declined. These could also help to sustain newly developing parts of the city centre, for example the Fruit Market. The City Plan promotes Primary Public Realm Routes in the City Centre. Major work is commencing to improve the quality of the street scape along these routes.
7.48 The Urban Panel visited Hull in 2010 and produced a number of recommendations for the Old Town. It was considered a huge asset whose potential was not being maximinsed. The complex building fabric of the Old
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Town makes the area costly to redevelop but provides some uniquer opportunities. The establishement of a Heritage Action Zone, Enterprise Zone or Local Development Order (LDO) will support its development.
Development opportunities outside the city centre
7.49 Inevitably, a number of facilities that provide for cultural and leisure activities or are an attraction to tourists are located outside of the City Centre. It will be appropriate in certain circumstances to support development that can maximise the economic potential of these, as long as there is strong rationale, such as uniqueness of location, and proposals do not adversely impact on the city centre.
You Told Us
Suggest that CIL monies should be directed to public realm improvements in the City Centre.
The reuse of vacant and underused buildings should be encouraged, especially along the Primary Public Realm route.
Suggest improving the public realm, encouraging the evening economy and promoting the city centre.
Suggest that the Local Plan supports and promotes Hull's museums, to strengthen the city centre tourism offer and support Hull's City of Culture Status.
Provide more leisure uses and restaurants in the City Centre, especially when there are uncertainties about the delivery of A1 retail floorspace.
Suggest public realm improvements (particularly increasing pedestrianisation of parts of the City Centre. Increase the number of hotels, improve transport links between the ferry terminal and transport interchange, introduce river cruises and develop a visitor centre.
Introduce more visitor attractions.
Improve 'gateways' into the City Centre.
Mixed use development should be encourages along the waterfront areas of the City Centre.
The provision of a variety of community infrastructure for tourism - cultural heritage and facilities - are vital for their contribution to residents and visitors life satisfaction, including maintaining and enhancing existing facilities to provide modern facilities that visitors expect.
Need to improve City Centre open spaces and create strong green links, to sustain visitor attraction.
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Shopping offer is disconnected and links could be made to the rest of the city centre by creating better public realm, including art and culture.
Support the intention to concentrate resources ion key cultural and tourism projects.
Options
Option A: Define a policy that provides detail of specific projects.
Option B: Define a policy that provides broad support for public realm and tourism projects.
Option C: Allocate sites identified specifically for hotel development.
Option D: Designate a Heritage Action Zone to enable greater focus to activities within the Old Town of the City Centre.
Option E: Support tourism and leisure development outside of the City Centre subject to strict criteria to prevent adverse impacts.
Preferred Option
The preferred option is a combination of B, C, D & E
Draft Policy 23
Leisure and Tourism
1. The Council will support the development of leisure and tourism projects, and the provision of infrastructure that promotes the key objective to make Hull a World Class Visitor Destination.
2. Sites at the former LA's nightclub, (ref 14) and at Trinity Quays, (ref 19) are allocated for hotel development.
3. The Old Town area of Hull City Centre will be designated as a Heritage Action Zone and a master plan and or Local Development Order produced to influence the development of the area to secure its long term viability and to support the areas as a key visitor destination.
4. Proposals for Leisure and Tourism facilities outside of the City Centre will be supported if uniqueness of location justifies such a location, or where the draw of the facility would not adversely impact on the visitor attraction of the City Centre.
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Justification
7.50 A number of proposals have been identified by the City Plan which support the broad objective of making Hull a World Class Visitor Destination. The policy could give more detail of these proposals. At this stage it is considered appropriate to put forward a much broader policy.
7.51 Clear proposals have been put forward on two sites for hotel development, one supported through the City Plan.
7.52 Actions are progressing to bring additional funding to the Old Town area and designation of the Heritage Action Zone will support this.
7.53 There will be circumstances where there is clear need to provide leisure and tourism facilities outside of the City Centre. Office-based businesses
7.54 The largest amount of Office space within Hull remains focused in and around the city centre. Hull is also the principal location for offices in the Humber region, based on amount of office stock. Growth in office stock over the period 2000 - 2012 through new development was estimated at 6.8%. This compares with 32.6% within the administrative area of the East Riding of Yorkshire Council. This is potentially driven by more attractive markets and development opportunities. It reinforces a need for the City Centre to be able to attract or retain key businesses, through providing appropriate accommodation. It is clear of course that the property markets of Hull and the surrounding areas of the East Riding continue to be extensively interlinked, operating virtually as a single market area. What is clear for Hull is that despite large amounts of office accommodation, this is often not fit for purpose. At March 2015 vacancy was estimated at 21.7%, higher than other Humber authorities. The high vacancy figure is significantly affected in the City Centre by several older 1970's buildings which have not been refurbished, and demonstrate long term vacancy. This has been added to by a significant amount of vacant Council accommodation being made available to the market.
7.55 Hull does have limited quality Grade A office space available. It is a priority therefore that development opportunities are provided to ensure that the city centre can offer a range of properties to accommodate Grade A office space. In this way, the city can offer an office-based business core to compete with other cities in the region, and attract a high level of inward investment. Some attempt has been made to bring a critical mass of office uses within locations such as Humber Quays [check permissions / intentions for remainder of this location]. Some office space could be provided within other major development opportunities that exist within the City Centre. Albion Square has previously been identified as having potential for supporting significant office development although no recent strategy has been put forward for delivery. The Fruit Market masterplan has identified
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potential for an element of workspace within the commercial elements of the mixed use scheme. The C4DI development brings a high quality facility to the Fruit Market area, signficantly enhancing the offer
7.56 As the city develops to be a leading Energy City, it is also important that appropriate office space can be provided for companies potentially allied to wider manufacturing and logistics businesses, and potentially located closer to operational uses outside of the city centre. Business park space on the west of the city is extremely popular in Hull, and demand currently outstrips supply, particularly for small scale freehold office buildings. The Beacon, off the A63 to the west of the city, provides a prominent Grade A office location that is nearing completion. The Bridgehead site within the East Riding currently provides for larger high quality headquarter offices.
What you told us
Broadly supportive but attraction rather than manipulation Focus on the city centre first. Supportive of out of centre office development where complementary to the City Centre.
Options
Option A: Focus large scale office development in the city centre.
Option B: Support office development outside of the city centre where this is specifically required to support the wider business operations of manufacturing, medical or logistics companies.
Preferred Option
A combination of options A and B
Draft Policy 24
Office Based Business
Large scale office development will be located in the City Centre to promote ease of access by public transport, including rail, as well as to promote connections with other businesses within the City Centre.
Office development outside of the City Centre will be supported:
where they are located in proximity to businesses that they support including shops and services, and there is an operational need / advantage to this location; or where they are of a small scale (individually each unit under 500 sqm) and can support a specific business park development.
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Justification
7.57 There is a need and demand for a range of office accommodation in the city and this cannot be provided for exclusively in the city centre. It is therefore appropriate to set a policy approach which defines how different office types can be developed sustainably within different locations. City Centre Living
7.58 The provision of housing in the city is covered under Chapter 4: Housing. However it is clear that housing provides a key contribution to the success of the city centre. The plan’s evidence base suggests that up to 2,500 dwellings could be provided in the city centre. The City Centre population has grown over the last decade and the resident population adds to the mix of needs and acts as an economic driver in the centre. The Urban Panel, supported by English Heritage, in 2014 supported increasing the City Centre population and encouraging an Urban Village concept. A growing City Centre Population is a key objective for the city.
7.59 A growing City Centre population also brings added vitality to the centre throughout the day and evening. Certain locations have been identified as providing suitable and available sites for housing development through the Strategic Housing Land Availability Assessment (SHLAA). Housing can be particularly important as part of a mix of development, helping sometimes to add to the viability of schemes by raising scheme value. However, particularly on larger opportunities where specific development proposals have not come forward, it is not yet clear exactly how many dwellings will be provided. Further description of the larger opportunities available in the City Centre is provided below. Actual provision will depend on the detailed planning of these larger sites.
You told us
City centre living is already well established.
Encouraging residential uses back into the city centre could help revive it and increase its vitality.
Support for city centre housing providing a contribution to a viable mix of uses in larger development schemes.
Support for growing city centre population.
Options
Option A: Identify housing supply in the city centre only from existing SHLAA numbers
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Option B: Identify a broad requirement for the city centre based on an estimate of what could potentially be achieved in the city centre and determine the level of supply expected to be achieved in the city centre as a whole
Preferred Option
Option 2 is the preferred option. An example of a policy could be as follows:
Draft Policy 25
City Centre Living
Within the City Centre it is expected that at least 2,500 houses or flats will be provided over the plan period. These will be provided across a range of sites. Where large scale development opportunities are brought forward involving a mix of uses.
Housing is encouraged above ground floor within the Primary Shopping Area, or above commercial units in other areas, providing it would not compromise the retail, leisure or office function of the city centre.
Justification
7.60 NPPF does allow for a certain amount of housing supply to be sourced from broad locations. While the estimates of housing supply established for some sites will be superseded as new schemes are brought forward, there remains a need for housing to be provided and therefore it is appropriate that there should be an expectation that housing will therefore be part of the mix of uses within larger schemes.
7.61 The nature of buildings within the main shopping high streets of the city centre are such that there is significant scope for residential use above ground floor. City Centre development sites
7.62 The following outlines the key development opportunities that exist in the city centre and guides how other policies might apply within these areas. The sites have potential to support a range of city centre uses, and this flexibility helps support what is required to deliver a range of competing requirements including the needs of emerging City Plan projects. Development Briefs have been prepared for the sites to guide more detailed design. In total these could provide up to 15 ha of land. They therefore present greatest opportunity for significant development and are critical to the capacity of the City Centre to be able to support the ambitions and priorities of the City Plan, as well as strengthening the overall offer of the city centre and its ability to successfully compete for future expenditure.
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Albion Square
7.63 This opportunity provides the opportunity to strengthen the physical and functional connection between the Georgian New Town and the Primary Shopping Area of the city centre, and to help strengthen this area as a distinct quarter of the centre. The overall site is substantial, although the area includes vacant buildings, the most prominent of which are the former Coop building built in the 1960s, and the former Edwin Davies store. A substantial area is currently used as a short stay surface car park. The Wilberforce Health Centre has been built on the site of the former Grattan's catalogue depot, to the Story Street Frontage.
7.64 A development strategy was created for the area in 2010, but this has not been updated. The areas was seen as an ideal opportunity to create a business Quarter with potential for an office led mixed scheme - to provide a strong Grade A offer balancing out of town supply by meeting demand for high quality space in a city centre location. The Maltings areas located adjacent to the site demonstrates the potential opportunities for meeting demand for office space in this location. There is clear opportunity within such a large site to provide for a wide range of uses, creating sufficient critical mass to repair the built environment, including public realm and creating a scheme that contributes to the city centre as a whole. The site is adjacent to Kingston House which is currently for sale following the council declaring the accommodation as surplus to needs.
7.65 Kingston House provides options for either refurbishment or redevelopment. Redevelopment provides clear opportunity to bring a greater area into the wider Albion Square area with potential for remodelling of Bond Street which is currently oversize for its use, being a remnant of what would have been a much bigger highway route through the city.
7.66 Albion Street car park is seen as a critical part of the parking infrastructure within the city centre. It will therefore be important to ensure that a capacity similar to that existing is maintained within a future development.
Land around Myton Street, to the west of the Princes Quay Shopping Centre.
7.67 This site, given its prominence and proximity to the A63 Castle Street improvements, could deliver an impressive gateway to the City Centre, promoting a perception of the city centre as a vital and dynamic place from the busy A63 approaches. A development brief has been prepared for the site. This stresses the need for a comprehensive and coordinated approach to determining how the site should be brought forward, recognising the current 'back street' and servicing function of the area, and the poor environment that has so far been created through a piecemeal approach. A significant constraint to the site is its limited connection with the core of the city centre. Opportunities therefore rely on making adequate connections, which are therefore likely to still include links with the Princes Quay Shopping Centre.
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7.68 On the west side of the site is the Myton Retail Park which is part of the CIT estate and currently operates as an edge of centre development including Staples, American Golf and Maplins. Myton Retail Park is a very prominent site in terms of the western approaches to the City Centre and has the scope to make a strong architectural statement, and allows for greater penetration into the site strengthening the contribution of the site in this more comprehensive scheme. There is currently no intention by the owners to redevelop these units as part of wider development. [is there any indication that these units should be included within an allocation?]
7.69 The site had planning permission for a major £300m retail development of 62,000m2 in 60 shops and two department stores, which had potential to absorb estimated growth in retail expenditure in the city, and provide a major anchor scheme for the city centre. [put in reference from Retail Study]. The scheme also included a leisure complex of 25,000m2 and a 175 bed hotel. It was announced in October 2010 that the scheme would not go ahead following a change in ownership of Princes Quay Shopping Centre. Actual viability of such a scheme has clearly faltered in the face of the economic downturn, no doubt reflected in the performance of the existing shopping centre that has struggled with footfall and vacancy, as well as reduction of regeneration funding available. Through the City Plan a proposal has been identified for a new conference and live music venue. The Council's cabinet has agreed to enter into negotiations to appoint an operator for the venue, and has committed £29.4m towards the cost of building a complex. Princes Quay owners CIT, who have wide experience in shopping centre asset management and have significant investment backing, have also committed to delivering a new hotel on the site. There is therefore a clear momentum towards a development solution for the site.
7.70 Ultimately the range of uses that could be feasible on the site is still wide, and this could still include substantial retail, although not of a scale as originally envisaged. Allocation therefore should be relatively broad, although recognising the complexities of the site, as well as clear emerging opportunities / development intentions of the owners of the site.
The Fruit Market and Digital Quarter.
7.71 The Fruit Market area is currently subject to a comprehensive regeneration scheme. The masterplan that is guiding development sets out the following broad quanta for what is likely to be delivered by the area. It splits the area into four distinct sites.
7.72 To the east of the Fruit Market has been identified through a feasibility analysis as a favoured location for a new cruise terminal, with potential for a significant new waterside development next to the terminal. Similar terminals elsewhere in the UK feature shore based shopping and leisure attractions within walking distance. A joint venture partnership is expected to be formed to deliver the project, with a view to attracting Government funding. The project is supported by the City Plan.
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Humber Quays
7.73 Approximately 1.8ha of land remains available for development adjacent to offices developed at Humber Quays. Permission has previously been granted for housing development in this location. The area has previously been linked with the Bullnose across the lock gates that form the entrance to the Albert & William Wright Dock. ABP has signalled its intention to retain this dock as needed for their operational requirements. Therefore it is not clear whether the Bullnose could still feasibly be incorporated into a development scheme. Plans for a cruise terminal have considered the potential for this location but the area around the Deep is considered more suitable.
East Bank of the River Hull.
7.74 A strip of land formerly known as the Boom exists to the east of the River Hull. This was previously identified as the location for a major housing scheme involving apartment blocks. This scheme subsequently fell away as the scheme was no longer viable. The former Rank Hovis building to the north of the site is now being redeveloped for student housing and a hotel and casino. This therefore demonstrates some confidence in the area. The new innovative footbridge provides a key linkage between the Old Town across to areas around the Deep and the Fruit Market. This link naturally promotes the potential for the area on the east bank to develop.
Former Central Police Station and George Street Car Park
7.75 The former Central Police Station at Queens Gardens has now ceased operations and has moved to a new headquarters at Clough Road. The site therefore presents a redevelopment opportunity. It has been suggested that George Street car park would be retained within any future development of this site with improvements made to allow a comprehensive design of the scheme to be achieved. The site presents opportunity for a range of uses given its proximity to the college allowing for potential expansion and frontage to Queens Gardens that could make it attractive to residential or office development.
Land Adjacent to Central Fire Station
7.76 Agreement has been reached for a land transfer allowing for land adjacent to the Fire Station to be used to allow expansion of Hull New Theatre, as well as to allow construction of a University Technical College.
You told us
The Fruit Market development should prove popular with employment prospects nearby.
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Greater emphasis needs to be given to supporting the development of strategic regeneration sites including Quay West, the Fruit Market and emerging employment locations along the River Hull (including Marina Court and the Dry Dock).
The Quay West development scheme has significant potential to support the city centre's role as a visitor attraction.
It is essential that any developments in the city centre safeguard those elements which give thee area its distinct identity.
Suggest the use of development briefs, in house EIAs and heritage impact assessments for heritage sites.
Public sector need to work closely with developers to deliver sites.
Support allocation of the Humber Quay's development scheme as a mixed-use site.
Should consider meanwhile uses for sites in the interim to their development - e.g. Urban food production / parks.
Options
Option A: Allocate large development opportunities in the Centre as mixed use sites recognising the potential for a range of uses to be developed on them.
Option B: Provide detailed guidance for how the sites can develop through master plans and development briefs.
Option C: Adopt development briefs as part of the Local Plan.
Preferred Option
The preferred option is a combination of all those presented.
Draft Policy 26
City Centre Development Sites
1. The following large scale development opportunities identified within the City Centre will be developed for a mix of uses.
a. land at Albion Square (0.85 ha); (ref 1, 15 & 18)
b. land around Myton Street (west of Princes Quay) (3.8 ha); (ref 2)
c. land at Humber Quays (4.75 ha); (ref 3)
d. the Fruit Market and Digital Quarter (4.77 ha); (refs 4, 5, 6, 7 & 17)
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e. East Bank of the River Hull (0.79 ha); (refs 8, 9, 10)
f. Former Police Station and George Street Car Park; (ref 20)
g. Land Adjacent to Central Fire Station. (ref 21).
2. The sites will be developed in line with development briefs that will be adopted as part of the Local Plan.
Justification
7.77 The development options for the sites are wide as described in the preceding paragraphs. It is crucial that future development is properly integrated with the rest of the City Centre by ensuring development supports the envisaged role for areas. Such sites should therefore be guided by master plans and development briefs. By adopting these as part of the policy framework of the Local Plan will greater weight to how they guide development of these significant opportunities. Supporting Evidence
7.78 Information for this chapter mainly came from:
Hull Retail and District Centres Study, 2013 Hull Employment Land Review, 2013 Hull Strategic Housing Land Availability Assessment, 2013 Hull Strategic Housing Market Assessment, 2013
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8. Shops, Services and Community Facilities Introduction
8.1 The National Planning Policy Framework (NPPF) states that local plan policies should be positive, promote competitive local centre environments and set out policies for their management and growth over the plan period. Planning Practice Guidance reinforces this, by referring to how local centres can provide diverse places where people want to live, visit and work.
8.2 The NPPF stresses that town centres (for Hull, town centre refers to the three different types of centre based on their size and the function they perform, i.e. district, local and neighbourhood centres) should be seen as at the heart of their communities and that the planning system should pursue policies to support their vitality and viability by affording them appropriate planning protection. Establishing a centre hierarchy
8.3 To help guide policies and strategies for centres the NPPF states that local plans should define a network (the pattern of provision of centres) and hierarchy (the role and relationships of centres in the network) that is resilient to anticipated future economic changes. Hull has a large number and range of different centres across the city that act as a focus for shopping, leisure and community facilities. They differ greatly in size and nature, but all promote sustainable shopping patterns which enable people to shop and access services locally, reducing the need to travel and maintain community access to a full range of shopping facilities and community services in one location.
8.4 Hull's many centres vary significantly in scale and character. Hull City Centre functions as the key location for large scale shopping, leisure and cultural activities in the city and for the wider region. The city centre is considered in more detail in Chapter 7. Policies within this chapter concerning the application of the Sequential and Impact tests are also to be taken into account when considering development proposals that could affect the city centre.
8.5 Beyond the city centre the Hull Retail and District Centres Study 2013 confirmed that four centres should be defined as district centres. Hessle Road and Holderness Road are older centres, that have historically developed as long linear high streets running along main arterial routes into the city. North Point is focused around the purpose-built shopping centre within the wider Bransholme estate. These three centres were defined as district centres in the saved Local Plan 2000 and this status remains relevant. Kingswood has developed from a retail park, and evidence now suggests
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it can function as a district centre. The Kingswood Area Action Plan designates it as the Kingswood district centre. District centres offer a wide range of shops, services and community facilities, including superstores or larger supermarkets and health centres. Their scale and diversity of provision means that they serve a wide catchment area and significant areas of the city.
8.6 The Hull Local Plan, Issues and Options document (May/June 2014) identified a potential network of other centres and classified them as local and neighbourhood centres. A recent assessment of centres made through the Hull Retail Survey Autumn/Winter 2014-15 identified a potential for 27 local centres to be designated as such. These are generally smaller than district centres, although some within the west of the city do accommodate a greater number of commercial units. The major distinction between these two types of centre is that the offer and function of district centres leads them to attract customers from a much larger catchment population than that of local centres. Nevertheless local centres do provide an important community hub which often, in addition to retail provision, provide an accessible location for essential public services such as medical practices and libraries.
8.7 A further 30 potential neighbourhood centres or parades have been identified in the most recent annual retail survey (2014-15), located across the city. They are typically smaller in size and generally contain 10 or fewer commercial units. They tend to be dominated by retail services and food and drink outlets, but they can still help to maintain vital facilities and services of ‘neighbourhood significance’ and provide essential opportunities for day-to-day convenience shopping (bread, milk, fresh food and newspapers). The saved policies of the Local Plan 2000 do not explicitly identify these individual neighbourhood centres. The NPPF sees the importance of strong neighbourhood centres in supporting healthy communities through the promotion of social interaction and their direct impact on local economies, as they often comprise of businesses owned by, and employing local people. These factors would suggests a policy approach which gives emphasis to them by placing them within a centre hierarchy.
8.8 Table 8.1 'Schedule of Centres' (at the end of this chapter) outlines the makeup of centres identified in the Hull Retail Survey autumn/winter 2014-15 and their locations within Hull are shown on Map A.
You Told Us
Broad agreement with the proposed hierarchy but several respondents expressed concern that any new designation should not undermine the vitality and viability of the city centre and other existing local centres
Some support for the re-designation of Kingswood Local Centre as a district centre and its need to create a fuller range of services and community facilities to justify this designation
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However equally, concern was raised over this proposed designation and its possible detrimental impact on other existing centres
One comment disagreed with the designation of Holderness Road/Morrison’s centre as a neighbourhood centre and suggests it should be shown as a local centre
Options
Option A: Adopt a centre hierarchy which includes the city centre, district centres and local centres, but does not include neighbourhood centres, as the best framework for directing the location of future shopping, leisure and community facilities and show these centres on the policies map (see Table 8.1 and Map A for a list of centres and their location).
This option's centre hierarchy is similar to the saved policies of the Local Plan 2000, in that it identifies district and local shopping centres but does not identify neighbourhood centres.
Option B: Adopt the proposed centre hierarchy suggested on the Hull Local Plan Issues and Options document as the best framework for directing the location of future shopping, leisure and community facilities and show these centres on the policies map.
The proposed centre hierarchy suggested in the Issues and Options document (May/June 2014) includes district, local and neighbourhood but was based on the 2013 Retail Survey and the 2011 Smaller Local Centres Survey.
Option C: Adopt a centre hierarchy which defines all levels of centres including neighbourhood centres (as outlined in the preferred option below) as the best framework for directing the location of future shopping, leisure and community facilities and show these centres on the policies map. These centres are listed in Table 8.1, and indicative site boundaries are shown on are shown in detail in the 'Part 4 - Site Designations' document accompanying this document.
The proposed retail hierarchy suggested below was based upon the 2014-15 Retail Survey.
Preferred Option
Option C
Draft Policy 27
Defining the Centre Hierarchy
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The following network of centres will be used to guide the distribution of future shopping, leisure, food and drink, financial, and community facilities and other uses which are likely to attract a significant number of people for day-to-day activities.
1. City Centre
Hull City Centre
Hull City Centre will be the main comparison shopping destination and the primary focus for retail, office, leisure, public services, civic amenities, cultural facilities and tourism development of city wide significance, which cumulatively or individually serve to support and reinforce it's role serving a wide catchment area across the city and the wider region.
2. District Centre
Hessle Road Holderness Road
Kingswood North Point
District centres will be the main focus for shops, services, and community and leisure facilities outside of Hull City Centre. District level retail, service, leisure and community uses which attract people from a citywide catchment area will be expected to be located in these centres.
3. Local Centre
Anlaby Road Holderness Road/Morrison's
Annandale Road Ings Centre, Savoy Road
Beverley Road/Cave Street Marfleet Lane
Beverley Road/Cottingham Road Newland Avenue
Beverley Road/Washington Street Orchard Park
Chanterlands Avenue Princes Avenue
Cottingham Road/Hall Road Shannon Road
Endike Lane Southcoates Lane
Gipsyville Spring Bank
Grampian Way Spring Bank West
Grandale Sutton Village
Greenwich Avenue Tween Dykes Road/Ings Road
Greenwood Avenue (west) Willerby Road
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Holderness Road/Faraday Street
Local centres will be the main focus for shops, services, and community and leisure facilities primarily serving local catchment areas but at a level above neighbourhood centres.
4. Neighbourhood Centre
Anlaby Road/Anlaby Park Dalsetter Rise
Anlaby Road/Calvert Lane Greenwood Avenue (east)
Anlaby Road/Coltman Street Goodwin Parade, Walker Street
Anlaby Road/East Ella Drive Holderness Road/Woodford
Askew Avenue Hotham Road South
Barham Road Inglemire Lane/Hall Road
Bethune Avenue James Reckitt Avenue
Beverley Road/Melrose Grove Kingswood Village Centre
Beverley Road/Riversdale Road Preston Road Village
Beverley Road/Strand Close Priory Road
Beverley Road/Sutton Road Spring Bank West/Luton Street
Boothferry Road/Belgrave Drive The Quadrant
Boothferry Road/North Road Victoria Dock
Bricknell Avenue Wawne Road/Zeals Garth
County Road South Wold Road
Neighbourhood centres will be the focus for shops, services and community facilities primarily serving local residents day-to-day needs.
All centres within the centre hierarchy are defined on the policies map.
Justification
8.9 All of the broad options put forward support the key role of Hull city centre and the district centres. The key difference is the policy recognition given to neighbourhood centres. The preferred option and suggested policy recognise the role that neighbourhood centres play in the city and allows greater clarity of how the plan can respond to needs across all centres. Option A would not allow this. The preferred approach supports the future Local Plan’s aim to develop, support, retain and invest in sustainable local
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centres across the city. It will help reduce transport emissions, promotes equity and address social exclusion by ensuring residents have easy access to key facilities, local services and local employment opportunities at a reasonable cost, in a reasonable time and reducing the need to travel by private car.
8.10 The Issues and Options document put forward a hierarchy of centres including neighbourhood centres. Option B simply reflects what was put forward in that document which was based on older evidence. A more recent audit of centres was completed in autumn/winter 2014-15. Noticeable differences from the Issues and Options document, suggested by the audit include the addition of two neighbourhood centres on Beverley Road, the inclusion of a local centre at Holderness Road/Faraday Street, the re-designation of Holderness Road/Morrison’s neighbourhood centre to a local centre and Greenwood Avenue (east) and Beverley Road/Sutton Road local centres to neighbourhood centres. Defining the extent of centres
8.11 The NPPF states that local planning authorities should define the extent of their centres and primary shopping areas within them, based on a clear definition of primary and secondary shopping frontages and set policies that make it clear which uses will be permitted in such locations. Primary shopping areas and primary frontages are those areas containing the main concentration of shops and traditional high street uses. Identifying them allows local plan policy to more effectively manage the function of centres by balancing the provision appropriate use. This is considered in the next section - 'Ensuring the vitality and viability of centres'. Definition of boundaries for the City Centre are considered in Chapter 7 - City Centre. This chapter considers district, local and neighbourhood centre boundaries.
8.12 Indicative boundaries for each centre designated within the proposed centre hierarchy are shown on the Policy Map, and in more detail in the 'Part 4 Designations' document to show where policies will apply. The boundaries are delineated to include all commercial units, as well as service and community facilities, when these are thought to form part of a cohesive and recognisable centre.
8.13 Within designated centres, where there is a strongly defined retail core that is distinct from other uses and functions of the centre, it can be helpful to define a primary shopping area to indicate where specific policies related to shopping may apply. In larger centres, this can help define the role of different parts of the centre, for example between retail and community facilities, and suggest strategies for where change may happen. In many instances, particularly in the case of neighbourhood centres, the primary shopping area may be one and the same as the centre boundary its self where the centre is just made up of commercial units. For the district centres, the Issues and Options Document suggested defining a primary frontage within the primary shopping area, and within a wider overall centre boundary. Designating a primary frontage could allow stricter control regarding change
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of use within a frontage, but would only serve a purpose where there are clear distinctions between properties that allow definition of primary and secondary frontage. Where there is not, then policy would be better directed to a primary shopping area as a whole.
You Told Us
One respondent objected to the boundary (as shown on the Evidence Map) of the Holderness Road District Centre and suggests that it should reflect the boundary used in the Holderness Road Area Action Plan. And that the identified extensions to the Area Action Plan boundary (the areas to the north of Southcoates Lane, either side of Holderness Road) should be reclassified as a separate neighbourhood and local centres
Some support for the expansion of the Kingswood Local Centre boundary to reflect its potential re-designation as a district centre, although the requirement to change the nature of its future retail units (from large floorplate properties) was questioned as it was felt by the respondent that sufficient services and community facilities were provided at the new Kingswood Village Local Centre
Support for the idea proposed in the City Centre of expanding the PSA where sites for future retail development have been identified but schemes have not been implemented - e.g. Retail led expansion at Kingswood.
However equally, concern was also raised over this expansion, and an objection was submitted to the boundary extension, the respondent stating that it may critically undermine investor confidence in the city centre’s committed development sites match
Options
Option A: Define centre boundaries to include all commercial uses, including shops, services and food and drink outlets, as well as community facilities.
Option B: Within centre boundaries designate primary shopping areas for every designated district, local and neighbourhood centre as identified within the retail hierarchy.
Option C: Within primary shopping areas designate primary frontages for designated district centres.
Option D: Do not show either the primary shopping areas or primary frontages as distinct from centre boundaries for any designated district, local and neighbourhood centre on the policies map.
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Preferred Option
Options A, B and C are combined as the preferred option and are illustrated by the indicative boundaries shown on the Policies Map.
Justification
8.14 The preferred option supports the Local Plan’s aim to develop, support and invest in sustainable local centres across the city. This option allows policies to focus more effectively on managing the balance of uses within centres. Identifying the primary shopping areas for all potential retail centres designated in the hierarchy will provide greater clarity to what uses will be allowed and where, particularly how retail and non retail, including community facilities make up and contribute to a centres role and function. National guidance is clear in that all key shopping areas and high streets (including neighbourhood parades) should be protected as they each have a crucial role to play in supporting their surrounding community. Defining primary frontages will allow greater control over change of use in larger centres where particular runs of shops are important to anchoring footfall within the centre.
8.15 Option D does not take advantage of NPPF which gives local planning authorities greater opportunities to ensure the vitality of local centres by identifying primary shopping areas and allowing local plan policies to make clear what type of uses will be and not be permitted in these areas which is critical to insuring the vitality and viability of local centres. Ensuring the vitality and viability of centres
8.16 The NPPF states that Local Plans should plan positively to support the vitality and viability of local centres, to generate local employment, help to reduce social exclusion, promote beneficial competition between centres that allow for customer choice and create attractive, diverse places where people want to live, visit and work.
8.17 National Planning Practice Guidance states that Local Plans should contain appropriate strategies to help determine the future of its centres, based on evidence of each individual centre’s current function and role. This positive vision should consider what the most appropriate mix of uses should be to enhance each centres overall vitality and viability. The nature, role and success of local centres across Hull differs significantly; some centres are strong and vibrant, while others are showing signs of decline, with higher vacancy rates and poorer local amenity values. Some of this reflects various national and local trends that present challenges to retail provision within the city, including shift towards more car-borne retail, the dominance of large and discounter supermarkets, and internet shopping, which have affected shopping patterns for residents.
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8.18 Strongly performing centres are usually seen as having a healthy diversity of uses, including a good range of convenience and comparison shops, with a presence of multiples and of independent traders. The larger centres have a significant amount of food shopping, particularly the district centres, as well as some well known high street brands selling household goods, chemists and clothes. Centres also contain financial services such as banks, estate agents, and advice offices, as well as cafés, pubs and takeaways; uses which can complement the primary shopping function of the centre and help attract people to a centre. In weaker centres, it is often more difficult to promote an appropriate mix of uses and this can result in an over-concentration of certain non-shopping uses, such as betting shops and hot food takeaway outlets which have an impact on the character and function of a centre and can lead to a change in its role. This is often the case in smaller centres where the loss of one or two main stores can quickly tip the balance. The negative impact of such uses include making the shopping street less appealing to visitors due to the over proliferation of dead frontages where uses have only evening opening hours resulting in shuttered properties in the day; and the loss of variety in the shopping offer available, particularly outlets providing day-to-day essentials. Such uses can also lead to the loss of local amenity through extended opening hours, increased traffic and on-street parking, disposal of refuse, noise and general disturbance and other community safety issues. Betting shops can be perceived as promoting debt problems.
8.19 Because of these issues it is appropriate for the Local Plan to introduce a policy that enables the management of the range of shops, services, food outlets and community services in some or all of Hull’s local centres in order to maintain or increase their vitality and viability. Planning is able to control the use of units within centres by the way in which it classifies them. While the types of shops and services in a centre can be classified by for example the type of goods they sell, for example comparison and convenience shops, and this is the basis for estimating future need for shops, the classification of an occupiers use for the purpose of controlling any change is made according to the Town and Country Planning (Use Classes) Order 1987 and Use Classes Amendment Order 2005. Within this categories are relatively broad. The A1 use class includes all shops, but also retail services including for example post office, travel agent, and hairdressers. It does not include professional and financial services, including banks (A2) or food and drink uses (A3 - A5). The Use Classes mean that planning permission has to be sort before an existing shop unit can be changed into an office, pub or fast food outlet for example. It does allow Local Plan policy the option of setting a minimum level or threshold of A1 retail uses within a centre or it’s primary shopping area, based on evidence of current mix of uses within the city’s various centres. The approach could therefore be to maintain a balance which is akin to that which exists if that is considered to represent a healthy centre, or alternatively an optimum balance could be sought where is is considered this is achieved elsewhere.
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8.20 It is clear from evidence that within district centres and larger of the local centres the higher numbers of units supports a % threshold being applied so that an overall balance is achieved. Evidence suggests that these centres currently offer between 40 - 50% of A1 uses. Within the district centres the preferred approach outlined in the last section is to designate primary frontages. These suggest a more focused policy approach, similar to the city centre where differing thresholds are applied depending whether within primary or secondary frontage. This is most applicable to Hessle Road and Holderness Road where the nature of the centres suggests differentiation of frontages. As North Point is a purpose built shopping centre, the compact layout and active management of occupiers means there is less differentiation in frontages. Kingswood is dominated by retail outlets that could all be considered as presenting primary frontages. Kingswood district centre is designated by the Kingswood Area Action Plan. Evidence suggests that the proportion of A1 uses within the Hessle Road and Holderness Road District Centres is around 65%. Within the North Point a this is much higher at 75%.
8.21 Within smaller centres, particularly neighbourhood centres, the issue is often more an over dominance of A1 retail service uses, as well as food and drink. In neighbourhood centres food shopping is not as prominent although can still have an important role. They may have a newsagent that doubles as a corner shop selling basic food items or a single 'branded' convenience store. These centres often do have a chemist or medical services. They are also locations for smaller independent non food shops. Often the range of goods is influenced by the presence of other centres or supermarkets nearby. What is clear is that a policy approach that applies a percentage threshold to A1 uses is not beneficial to neighbourhood centres.
8.22 More critical is ensuring that remaining shops that serve for day to day needs, particularly food shopping, are protected from pressure for other uses where the food shop use would otherwise remain viable. While the Use Class Order does not prevent A1 service uses it does allow control of professional services and food and drink outlets and therefore a policy to directly control these to prevent the loss of food shopping outlets would be appropriate. The section below considers how the Local Plan can help to promote healthy communities, particularly focused on hot food takeaway outlets. The Use Class Order also allows prevention of change of use to for example residential.
You Told Us
Concern was expressed over the shifting in the main function of certain local centres from a primarily shopping use to a greater leisure use.
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Some support was voiced for imposing restrictions on non A1uses (specifically in this comment A3/A4 & A5 leisure uses) in local centres to protect the shopping offer available for the benefit of users, existing businesses and residents.
However one comment disagreed with this view and stated that local plan policies should not set prescriptive policies about the appropriate range of uses within local centres.
Options
Option A: Adopt a flexible approach for managing uses within designated centres. New shopping development and related local centre uses, such as financial and professional services, food and drink development and community facilities will be allowed in existing centres if they do not undermine it's vitality and viability and do not weaken it's core shopping function.
This option seeks to ensure new shopping and related development satisfies a general location criteria (i.e is located in a existing centre) and that any such proposals, should not have an unacceptable effect on the shopping core of the centre in question. This option would be most relevant to an approach where no primary shopping area or primary frontage was defined - see Option D - 'Defining the extent of centres'.
Option B: Adopt a more prescriptive policy which manages uses in the primary shopping areas of all designated local centres, by setting a threshold to ensure that there is no net loss of A1 shop units at street level in these areas. Elsewhere in the centre other ancillary high street uses may be allowed, but the focus would be on non-retail uses and Community Facilities.
This policy seeks to maintain a balance of uses within centres active frontages in the main shopping core of all designated centres. This option would link to the preferred option of designating a primary shopping area for all centres - see Option B - 'Defining the extent of centres'
Option C: Adopt a policy which manages uses in primary frontages of the city’s four district centres to ensure that there is no net loss of A1 shop units at street level in these areas, by setting differing thresholds for both primary and secondary frontages.
This policy aims to maintain active frontages that promote strong footfall in the principle shopping core of the district centres, maintaining the presence of main anchor retailers and high street shops which serve to attract from a wider catchment. This option would link to the preferred option of designating a primary shopping area for all centres - see Option C - 'Defining the extent of centres'
Option D: Adopt a policy that seeks to retain day-to-day shopping provision and local services within the city. This policy will ensure that the range of shops available in a given locality is appropriate to meet local shopping demand.
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Preferred Option
Option B, C & D
Draft Policy 28
Ensuring the vitality and viability of centres
1. Within the primary shopping area of district and local centres, a change of use from an A1 retail use to another high street use (A2, A3, A4 and A5) may be permitted if it does not have an adverse impact on the rest of the centre or the surrounding local area or when the application premises have been vacant for sometime (usually over six months), and if no less than 50% of all retail units are occupied by A1 shops in the district centres and local centres.
2. Within the primary frontages of district centres proposals for non retail use (non A1) should not result in the proportion of A1 units within the frontage falling below 65%.
3. In the city's neighbourhood centres such a change of use from an A1 use will not be allowed if it leads to the loss of food shops or essential services when these are not readily accessible in the immediate neighbourhood.
4. In areas outside of defined centres, corner shops and local convenience stores will also be protected from change of use, except where it can demonstrated that there is already a sufficient supply of local, day-to-day shopping provision within walking distance of surrounding residential areas.
Justification
8.23 This preferred option and policy support the Local Plan’s aim to have a positive vision to support the vitality and viability of local centres across Hull. It will allow decision makers to consider what the most appropriate mix of uses should be to enhance the overall sustainability, vitality and vibrancy of the city's district, local and neighbourhood centres. This policy seeks to maintain active frontages in the main shopping core of all designated centres, as per the advice given in the planning practice guidance dealing with retail provision. While it recognises that non-retail uses can add to vitality and vibrancy of a centre by providing a wider and more diverse local centre offer, it also acknowledges that an over-concentration of non-A1 shops (specifically, betting shops and hot food takeaways) can have a detrimental impact on the ability of local residents to access basic day-to-day provisions such as essential items including fresh fruit and vegetables and regular services. By actively seeking to prevent the loss of A1 shop units
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in the primary shopping areas of these centres, this policy establishes a robust policy direction for the local planning authority to use when determining an application for a non-retail use in a primary shopping area.
8.24 This policy also tries to address persistent vacancy rates (which have been an issue in some centres) by accepting that in some circumstances an alternative non-A1 use may be preferable to a long term vacant shop unit. The policy also addresses the need to retain local corner shops and convenience stores in areas that could otherwise be deficient; these stores have seen resurgence recently reflecting needs and changing shopping patterns.
8.25 Option A takes a similar approach to that of the previous local plan, in that it encourages all new shopping development to be located in established centres. And while it does consider the cumulative impacts of such development on a centres vitality and viability it does not offer a check to the over-proliferation of non A1 retail units within them. Other comparative local planning authorities have applied a minimum proportion of ground floor frontages to be retained as A1 shops in main shopping areas in policies wishing to preserve the primary retail function of local centres.
8.26 Option D recognises the importance to local communities of food or convenience shops in neighbourhood centres and of individual small scale corner shops and local convenience stores outside of centres, especially in Hull where the lack of car ownership means that these individual shop units have a greater role to play in communities than in other cities. Applying the sequential and impact tests
8.27 In defining centres and establishing a mechanism for maintaining or increasing the vitality and viability of centres it is important for the Local Plan to set a framework for how new development can be accommodated to achieve these broader objectives. NPPF states that local planning authorities should allocate sites to accommodate the scale and type of retail, commercial and other development needed in town centres. The Local Plan makes allocations where sites have been identified to meet needs. However there will continue to be circumstances where specific sites cannot currently be identified, or where new proposals will come forward.
8.28 In seeking to allocate land NPPF states that local planning authorities should, where no appropriate in centre sites are available, allocate appropriate edge of centre sites. If sufficient edge of centre sites cannot be identified, then the Local Plan should set policies for meeting identified needs in other accessible locations. NPPF also states that local planning authorities should set policies for the consideration of proposals for main town centre uses which cannot be accommodated in or adjacent to town centres.
8.29 NPPF sets two main policy approaches that local planning authorities can use to meet these aims; the sequential approach to locating development proposals; and a requirement for an impact assessment if development is
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over a proportionate locally set floorspace. The Local Plan provides a locally distinctive approach to how these tests can be applied in Hull, taking into account the role and function of different centres and therefore how future proposals might contribute to or impact adversely on their vitality and viability.
Sequential Test
8.30 Under the sequential test, local authorities should require planning applications for main town centre uses (e.g. shops) to be located first in the city centre, followed by district, local and neighbourhood centres, then on the edge of centre (dependant on the scale and nature of proposal), and, if suitable sites are not available in these locations, out of centre. When considering edge of centre and out of centre proposals, preference should be given to readily accessible sites that are well connected to existing centres. The intention of the sequential test is to ensure that shops and other main local centre uses are not located in such a way as to draw trade away from the city centre and established centres.
8.31 The Local Plan policy approach could simply be to require that any retail development proposal that is not in a centre should be guided by a sequential approach. There is no threshold in NPPF for determining when a sequential approach should apply. The area of search would then be a matter of each individual proposal. The alternative would be for the Local Plan to set a threshold for how different types of development would be expected to consider a sequential approach, therefore to give greater clarity to when and how a sequential approach would be applied within the city.
8.32 In applying a threshold it would be necessary to determine how different centres could be expected to accommodate development and therefore which centres would need to be considered in applying the sequential approach. Larger scale proposals that are likely to have a significant draw from a large catchment will depending on the scale and nature of the proposal, be most appropriately directed either to the city centre or to district centres. Other smaller scale proposals, for example where they are designed to serve local needs, will be appropriate within local centres or neighbourhood centres. It is likely that local and neighbourhood centres will not typically be subject to significant expansion.
8.33 The saved Local Plan 2000 put forward a threshold for applying the sequential approach in which it defined what could be classed as major development. This was defined based on different types of retailing, finance and professional and food and drink uses. Major development would then be directed to the city centre or district centres. Development below the thresholds would be directed to any of the centres within the defined hierarchy.
8.34 For the sequential approach to be applied successfully an adequate and appropriate supply of development opportunities have to be offered to meet identified needs. The requirement within the sequential test for a developer to apply flexibility in the format and design of proposals, does not necessarily
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mean that the applicant has to site a new store within an existing vacant unit(s) or within a constrained site on a traditional high street. Rather, local planning authorities should take a realistic approach and appreciate that retailers expect to be able to compete for trade with other retailers and that an important part of this ability is driven by such factors as size, layout and design issues.
8.35 If the sequential approach is to be relevant to guiding development, there is a need to either identify possible development sites or provide a policy framework that supports flexibility in the development of identified centres. This approach has been successfully demonstrated within Hull's district centres, where expansion has occurred in recent years. In Hessle Road and Holderness Road District Centres for example, where older properties to the rear of the centre (not within the centre at the time) were acquired for redevelopment, and replaced with larger, more modern units which were then incorporated in the original centre. In the case of Hessle Road, this created a new retail park based around a square, now known as St. Andrews Retail Park. At North Point new stores have been introduced through the remodelling of the older purpose built shopping centre and redevelopment in its original parking area.
Impact Test
8.36 NPPF states that when assessing applications for retail, leisure and office development outside of town centres, which are not in accordance with an up-to-date Local Plan, local planning authorities should require an impact assessment if the development is over a proportionate, locally set threshold. If there is no locally set threshold the default threshold is 2,500 sqm. The default represents a store of significant size equivalent to a large superstore or retail warehouse. Of importance to the city is that a number of proposals have come forward within the city in recent years that have been well below this size of floorspace, but which had potential to have an adverse impact on established centres, particularly for centres with more local catchments. Therefore it would be appropriate to define a lower locally set threshold that reflects the current retail profile of the city.
8.37 The intention of the impact test is to assess the impact a given proposal could have on the vitality and viability of existing centres, including the impact on local consumer choice and trade levels within the centre and its catchment area. Impact could arise where for example edge of centre development could enhance the competitive position of that centre, with potential for that centre to become over dominant within a wider network of centres. Equally an out of centre store could have potential to draw trade away from stores within centres. If this was significant it could undermine a store that might be an anchor to a centre, and therefore undermine the overall vitality and viability of the centre. Impact is likely to be greatest where it affects a weaker centre.
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8.38 The important point to note is that the threshold is not one that determines whether or not an application should be refused, but whether an application be subject to an impact assessment. Therefore to set a lower threshold potentially offers a safety net to allow fuller assessment of applications. Thresholds can be defined based on typical sizes of units within centres, the inference that larger units than those existing could potentially have a higher turnover and a bigger trade draw, depending on the retailer, and therefore have an adverse impact. On this basis then it could be argued that a tiered approach is taken, depending on the types of centres as defined in the hierarchy of centres. If a proposal is located within proximity of a smaller centre where the average size of unit is small then it could be appropriate to consider a lower threshold. If the proposal is more likely to draw trade from a larger centre where units are larger then it could be appropriate to apply a higher threshold in those cases.
8.39 The alternative view could be to suggest that the nature of distribution of centres within Hull is such that it would be very difficult to be absolutely clear of which centres a proposal might impact on without a proper assessment. Therefore rather than constrain an assessment by a more rigid tiered approach, it would be better to apply a standard threshold that reflects the lower sizes of units within centres, then to determine the scope of any assessment based on for example the size and catchment of a proposal and therefore the likely range of impacts. An assessment would therefore be commensurate with the scale of proposal.
8.40 The NPPF is clear that if an application for an out of centre development fails to satisfy either of the above tests, it should be refused.
You Told Us
Support for the use of both tests when determining scales of development but caution also expressed that this is only an element of decision making
Some acceptance that a lower threshold may be appropriate, but policy needs flexibility to ensure that the level of impact assessment matches the nature and scale of the proposed development
Options
Sequential Approach
Option A: Adopt an approach similar to the saved policies of the local plan (adopted May 2000) which set thresholds of 950 sqm or over for convenience shopping and 500 sqm or over for comparison shops when applying the sequential approach.
The saved Local Plan 2000 adopted these thresholds when considering planning applications for major retailing developments and considered these sizes of site to be appropriate for applying the sequential test.
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Option B: Do not set a threshold to guide the sequential approach, but consider how each individual proposal could be accommodated within relevant centres, dependent on the scale and nature of the proposed retail.
Option C: Take a proactive approach by applying a policy which encourages expansion of primary shopping areas of the city centre and district centres to enable sequentially preferable sites to be created.
Impact Test
Option D: Adopt a tiered approach to setting local floorspace thresholds, based on the location and function of centres within Hull's centre hierarchy when applying the impact test, for example, Hull city centre 800 sqm (gross), district centres 500 sqm (gross) and local and neighbourhood centres 200 sqm (gross).
Option E: Adopt a local set floorspace threshold of 300 sqm (gross) of all designated centres.
Option F: Don't adopt a locally set threshold and use the NPPF default national threshold of 2,500 sqm (gross) when applying the impact test. NPPF allows local planning authorities to set a proportionate, locally set floorspace threshold, over which an applicant would be required to submit an impact assessment. In the absence of such a local threshold the default national threshold would apply.
Preferred Option
For the Sequential Test - Option B & C; and for the Impact Test - Option E.
Draft Policy 29
Applying the sequential and impact tests
1. Planning proposals for main town centre uses should, depending on their scale, nature and catchment, be located in Hull city centre, followed by the district, local and neighbourhood centres. When the proposal cannot be located in these centres due to its size, layout or format, it may be considered appropriate for it to be located on an edge of centre site. For proposed development outside these areas applicants should demonstrate that there are no sequentially preferable sites that can serve a similar catchment to the proposal.
2. Main town centre development proposals above 300sqm should be accompanied by an impact assessment.
3. Applicants should demonstrate flexibility on issues such as format and scale. Where an application fails to satisfy the sequential test or is likely to have an adverse impact on existing centres or existing, committed or planned investment in these centres, it will be refused.
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4. Where detailed planning considerations allow the Council will support expansion of the primary shopping area of the city centre and district centres where this can promote the creation of sites that can accommodate larger floorplates and layouts required by retailers to allow proposals to be directed to more sequentially preferable locations.
5. The Council will expect the scope of any impact assessment to be commensurate with the scale of the proposal.
6. Where it is demonstrated that an otherwise adverse impact of out of centre development can be mitigated through a restricted range of goods, then conditions will be applied to control this.
Justification
Sequential Test
8.41 Option B would allow greater flexibility in how the sequential approach was applied. It would still require consideration of factors such as the scale of the proposal, the nature of the retail and importantly the likely catchment so it is clear how existing locations could meet requirements. NPPF does not suggest a threshold to guide the application of the sequential approach.
8.42 Option C reflects the need for a positive policy framework to guide consideration of proposals by ensuring that larger proposals could readily be accommodated within centres. If no potential exists for sites to be identified or made available then the sequential approach will potentially fail to direct proposals to centres.
8.43 Option A refers to the approach adopted in the saved policies of the Local Plan 2000. That policy used locally set thresholds to determine which centres a proposal should consider when applying the sequential approach. The thresholds it used were considered appropriate in the context of local circumstances. This option could be seen as too rigid in how proposals could be guided, particularly where schemes were just under the threshold.
Impact Test
8.44 Option E is preferred because it is considered that this provides a clearer basis for guiding applicants as to when and where an impact assessment will apply. For Option D, while providing a framework based on detailed assessment of how the different types of centres are currently performing and average size of units; it is considered that the large network of centres and potential for overlapping of catchments would make a tiered approach less workable.
8.45 Option F would simply apply the NPPF default threshold. NPPF makes provision for a locally set threshold to be set, and it is clear that there is justification for a lower threshold in the city.
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Promoting healthy communities
8.46 The NPPF advises that the planning system has an important role to play in facilitating social inclusion and creating healthy communities, and requires planners to consider health in a range of different way. These include measures to create strong neighbourhood centres with active frontages where members of the community, who might not otherwise come into contact with each other can socialise, shop and work together; improving access to healthy food and reducing obesity.
8.47 Local access to affordable fresh food is an important consideration for planning, as it affects people’s ability to regularly make healthier lifestyle choices and eat well. Across Hull, on some shopping streets certain uses (such as hot food takeaway outlets) and their over proliferation can have a negative effect on local amenity by creating ‘dead frontages’ (premises being shuttered) during the day. And a detrimental effect on community's access to healthy food with the displacement of convenience shops selling basic day-to-day food items including fresh fruit and vegetables. This shift from smaller essential shops such as grocers, butchers and greengrocers to other 'A' class uses such as betting shops, hot food takeaways and sandwich bars is of increasing concern when considering health issues for local communities. For example, the consumption of fresh food combined with increased physical exercise can help reduce levels of weight gain and obesity. Evidence suggests that people who eat at least five portions of fresh fruit and vegetables a day are less likely to succumb to Type 2 diabetes, heart attacks and strokes. And by improving easy access to shops selling these types of goods, along with encouraging community growing schemes, future local plan policy can ensure all areas of Hull do not become 'food deserts' (parts of urban areas where cheap nutritious food is virtually unobtainable).
8.48 Public Health England’s briefing paper ‘Healthy people, healthy places’ similarly highlights several other reasons why the presence of hot food outlets may be undesirable from a public health perspective, for example, many hot food takeaways generate substantial litter in areas well beyond their immediate vicinity, generate discarded food waste, produce night-time noise and create extra short-term car parking which may contribute to traffic congestion.
8.49 Also research shows a strong link between high levels of deprivation and the clustering of hot food takeaway outlets, with deprived areas having more hot food takeaways per 100,000 population (although the link between takeaway availability and obesity is still relatively undeveloped). The English average was 77.9 hot food outlets per 100,000 (2012) and Hull, in common with most urban areas has a higher number of outlets per 100,000 population at 121 outlets (based on 2014 data supplied by Hull City Council).
134 DRAFT JUNE 2015 Hull Local Plan: Preferred Options
8.50 A particular concern is that older schoolchildren are tempted to source such food from easily accessed hot food takeaway outlets rather than purchasing healthier options offered within their schools. Research indicates that once an obese weight is reached it is difficult to treat. Public Health England stated in 2015 that overweight and obese children are more likely to become obese adults and have a higher risk of disability and premature mortality in adulthood. By restricting the opening of new hot food takeaways in areas where younger people meet, such as near secondary schools local plan policy could help address this concern, although to be successful it is recognised that this has to be part of a range of measures, usually in partnership with schools.
8.51 The saved Local Plan predates NPPF and therefore did not place as much emphasis on encouraging people to make healthier choices about food as is now a requirement of conforming local plans. Hull City Council has also issued a policy direction of encouraging healthy eating in younger people to discourage obesity in later life.
You Told Us
Bricknell Estate, parts of National Avenue and the Wises Farm Estate (west Hull) were highlighted as areas where residents do not have easy access to fresh food shops, following shop closures and poor public transport links
Support for restricting hot food takeaway outlets, particularly in places where younger people meet and also for restricting opening hours of outlets located near schools during school hours. While agreeing with the initiative caution was also voiced over whether such restrictions could be sustained on appeal
One respondent suggests that such restrictions would be contrary to NPPF advice to encourage sustainable growth and not-over burden businesses with planning policy expectations. They suggest that there is a lack of evidence to demonstrate that purchases in fast food outlets are any more or less healthy than purchases in other A1 shops and point to a lack of direct evidence of a link between locating A5 uses within certain distances from schools and poor health outcomes for students
Options
Option A: Adopt a policy which allows new hot food takeaway outlets (A5) within some existing centres if it does not undermine the shopping function of the centre and if the street-level frontage is designed to be compatible with the shopping area?
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This option recognises that although hot food takeaways can provide an important role in a centre, for example maintaining its function into the evening, it can also have a detrimental effect on local amenity and applies a policy to minimise these factors.
Option B: Adopt a more restrictive policy which seeks to avoid the over dominance hot food takeaway outlets within existing centres by applying a more explicit measure against how to control changes.
This policy aims to address the problem of the over-proliferation of hot food takeaways in existing centres by introducing measures to limit the percentage proportion of A5 uses in them.
Option C: Adopt a policy which prevents new A5 uses gaining planning permission near schools and other youth facilities.
This policy aims to address the problem of easy access by school aged children of hot food takeaways by limiting the number of new outlets opening near to schools and other areas where younger people may meet.
Preferred Option
Option B and C
Draft Policy 30
Promoting Healthy Eating
Preventing the over-concentration of hot food takeaway outlets in existing designated centres
This policy defines the proportion of A5 uses that shall not be exceeded within established centres, based on each centres function within the retail hierarchy.
These percentages are:
No more than 6% of all retail units within a district centre should be a hot food takeaway outlet and planning applications for a change of use to A5 will usually be refused if this quantity has been, or will be surpassed No more than 20% of all retail units within a local centre should be a hot food takeaway outlet and planning applications for a change of use to A5 will usually be refused if this quantity has been, or will be surpassed
No more than 35% of all retail units within a neighbourhood centre should be a hot food takeaway outlet and planning applications for a change of use to A5 will usually be refused if this quantity has been, or will be surpassed
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Planning applications will also take into account other environmental factors and potential negative impacts such as noise and disturbance levels, smells/discharge of fumes/litter mitigation measures, traffic generation and deliveries issues and opening hours when being considered by the local planning authority
Proximity to schools, playing fields and youth facilities
Planning approvals for A5 use either within an existing centre or out of centre, will not normally be given if within 400m of a secondary school or sixth form college, playing fields, and children play spaces.
Justification
8.52 This policy supports the local plan’s aim to encourage healthier lifestyles, promote healthy eating amongst Hull's residents and seeks to ensure that communities have easy access to fresh food. It aims to address the problem of the over-proliferation of hot food outlets in existing centres, promote local access to healthier foods and limit the number of new A5 use outlets opening near to schools, and other areas where younger people may meet.
8.53 This policy is specific in guiding decision making, it gives a maximum percentage amount fast food outlets over which a change of use to or a new development of, will not usually be allowed. The percentage figures used in the draft policy reflects the latest survey data information which shows that the majority of existing centres across Hull are currently functioning with 15% of all units within A5 use, or below, although there is a quite wide variation between the different types of centre, and these are reflected in the spilt of percentages suggested in the policy.
8.54 This policy would not usually allow new A5 uses within 400m of schools, playing fields and children play spaces. Accepted good practice is to use a distance of 400m to define the boundaries of a hot food takeaway exclusion zone, as this is thought to equate to a walking time of approximately five minutes. In ‘Healthy people, healthy places’ (March 2014) Public Health England point out that a number planning authorities have had planning decisions (which considered healthy eating and proximity to school) challenged through the appeal process. Some appeals have been allowed, but many have been dismissed. But this issue was a consideration in a number of cases. It was not the sole or determining factor in the final decision so far (except for one occasion) however it has been given substantial weight in some appeals when it was considered as an adopted local plan policy. Secondary schools and sixth form colleges were included in the 400m exclusion zone for new A5 uses but not primary schools as primary school children are not normally allowed out of school at lunch times and are less likely to make their own way home from school without adult supervision.
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8.55 Option A offers a more flexible policy approach to new hot food outlets proposals than the other two options, in that it does not explicitly say that no more A5 use outlets will be allowed, rather it provides design, local amenity and environmental constraints limiting their over dominance in centres. And whilst this policy, in principle, could limit the potential clustering of A5 uses in established centres and the over dominance of ‘dead frontages’ through the design qualifications, it does not address planning permissions for properties outside of designated centres or within close proximity to schools and youth facilities. This option can guide decision makers in protecting the function of a centre and so, enhance its overall vitality and viability as per NPPF guidance but it does not fully take into account national policy guidance to give greater emphasis on linking planning with public health priorities.
8.56 Option B aims to check the potential over dominance of hot food takeaway outlets in some existing centres by offering a more specific policy to guide decision makers, in that it can, give a maximum percentage of A5 uses to be permitted in a given centre. Again, like option A it does not fully take into account national policy guidance that links the planning system with public health concerns. Specifically this policy does not address the proximity of hot food takweaway outlets to schools and other youth facilities, which was one of the ten recommendations of the Academy of Medical Royal Colleges 2013 report on obesity. The recommendation said that "Public Health England should undertake an audit of local authority licensing and catering arrangements with the intention of developing formal recommendations on reducing the proximity of fast food outlets to schools, colleges, leisure centres and other places where younger people meet". Delivering Community Facilities
8.57 Another important element in promoting healthy communities is to ensure that all sections of the community enjoy equal access to a wide range of facilities which support and enhance sustainable, vibrant neighbourhoods. These social and community infrastructure include health provision (such as GP surgeries and NHS walk - in centres), nurseries, schools and colleges, cultural, leisure and sports facilities, community growing spaces and allotments and places of worship. This list is not exhaustive as local needs may change over time.
8.58 The NPPF states that planning policies and decisions should guard against the unnecessary loss of valued existing facilities and services, particularly where this would reduce neighbourhoods ability to meet its day-to-day needs.
8.59 Across some of Hull’s district, local and neighbourhood centres there has been a move towards combining the provision of health care, some education resources and other services in a single place, within or adjoining the local centre. Locating such community facilities in one place allows them to be easily accessible for all, especially important for older people and those without the use of a car. The combining of shopping trips, with the
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use of community facilities and services has helped maintain the role of certain centres in the city and has gone some way to determining where a centre sits in the suggested hierarchy of centres.
8.60 The NPPF likewise, recognises the importance to communities of having access to high quality education provision and sufficient educational capacity to meet need. Research indicates a link between good education facilities and learning and better health outcomes. Public Health England’s publication ‘The link between pupil health and well-being and attainment’ (2014) highlights that research evidence shows that education and health are closely connected, and that pupils with better health and wellbeing are likely to achieve better academically. And it is also acknowledged that health inequalities are greater where educational attainment is low, children growing up in poorer families emerge from school with substantially lower levels of attainment (Joseph Rowntree Foundation - poorer children’s education attainment 2010). And since educational qualifications are such a strong determinant of later-life income and life opportunities, it is an important issue for the city. In Hull, to date significant levels of investment in school provision have taken place over recent years, with most secondary school buildings being replaced or up-graded and a number of primary school buildings still in a programme of replacement and re-modelling. Any potential expansion of these programmes will be supported by future Local Plan policy, along with the delivery of expanded or new schools should areas of deficiency arise over the local plan period. The new facilities created at these re-modelled schools have been designed to act as community facilities for the surrounding local population and planning policy will continue to support this role for schools.
8.61 The importance of readily accessible community services and facilities for meeting a wide range of social needs of Hull’s residents means that future Local Plan policies should make appropriate provision for them, endeavour to protect and enhance existing facilities (including school resources), provide appropriate school places to meet the anticipated need, and recognise that when these community services and facilities are combined with other retail functions within or near to existing centres they can act as important community hubs.
8.62 The Saved Local Plan (2000) adopted policies which aimed to maintain, support and improve community services and facilities. Its policies also looked to ensure good accessibility for these facilities, and so are still relevant. However as the previous plan was published before the NPPF was issued, it does not fully conform with current national guidance, in that its policies do not specifically guard against the loss of existing community facilities.
You Told Us
General support for co-locating health, education and other community services, including community growing schemes in sustainable locations
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and identifying these as community hubs within the retail centre hierarchy Support for including other public services, such as Humberside Fire and Rescue Service in community hubs and their future development Some support for making more use of school facilities for community use, although one respondent emphasised that child protection issues could compromise this
Options
Option A: Do not adopt a policy on new community facilities, but, with the exception of education facilities, rely on the NPPF presumption in favour of sustainable development. With regard to nurseries, primary and secondary schools and further and higher education facilities, development will generally be permitted if it is addressing local need.
Option B: Adopt a policy which allows community facilities development if its location and detailed planning considerations are acceptable. This policy would support improving existing community facilities, including the reuse of vacant buildings for community use.
Proposals resulting in the loss of existing community facilities would not usually be allowed.
With regard to nurseries, primary and secondary schools and further and higher education facilities, development will generally be permitted if it is addressing local need.
This option aims to protect and enhance new and existing community facilities if located in a suitable location.
Option C: Adopt a policy that allows community facilities development if located in the a designated centre in the first instance,with particular regard for co-locating multi-use facilities in other community facilities. This policy supports improving existing community facilities in centres, including the reuse of vacant buildings for community use.
Proposals resulting in the loss of existing community facilities located will not normally be permitted.
With regard to nurseries, primary and secondary schools and further and higher education facilities, development will generally be permitted if it is addressing local need.
This option, like option B aims to protect and enhance new and existing community facilities but suggests that they should usually be located in the city centre, district, local or neighbourhood centres. It also gives particular weight to reusing and co-locating activities in one place to reduce the need to travel.
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Preferred Option
8.63 Option C
Draft Policy 31
Encouraging and protecting new and existing community facilities
Within designated centres, proposals for new community facilities (including education and health facilities and places of worship) will usually be supported if:
existing sites used for community services within a designated centre are not available that can accommodate the proposal, including the dual use of premises; and, the scale of the proposal is appropriate to support and enhance the character and viability of the particular centre considered; and, that there is no unacceptable impact on the surrounding areas or on the local amenities
Proposals for the extension or redevelopment of existing community facilities will usually be supported where the proposal is of a scale appropriate to the centre concerned and does not adversely affect its vitality and viability.
Proposals involving the loss of community facilities will not be permitted unless the applicant can show that:
that the site is no longer needed for community use or the loss would not create, or add to a shortfall in the provision or quality of such uses within its locality; the land or buildings in question are no longer suitable to accommodate the current use and cannot be retained or adapted to accommodate other community services; the community use is to be incorporated or replaced within a new development or redevelopment of the site; existing nearby community uses can be improved to accommodate the loss or suitable alternative facilities are provided close by No specialist community use will be lost which cannot be provided elsewhere in the locality.
Justification
8.64 This policy supports the future Local Plan’s aims to ensure that all Hull's residents have equitable and easy access to social and community services and facilities, and good access to high-quality school provision and health resources. It recognises the benefits these facilities have for their
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surrounding residential areas, and that they preform an essential function for communities, enabling successful social interaction and community cohesion.
8.65 In terms of the development of new community facilities, the preferred option aims to locate such uses towards the city's established centres,as they are often functioning as community hubs and combine shopping trips with essential public services and other social activities. The majority of these centres already have a diversity of community uses within their locality which have proven to be accessible to the surrounding local neighbourhood by walking, cycling and public transport. And this principle underpins the NPPF guidance that local plans should plan positively for the provision and use of shared space and community facilities to enhance the sustainability of communities.
8.66 This policy particularly supports the co-location of services where this provides convenience for the user, resource efficiency for providers and monetary value for the public and voluntary sectors.
8.67 With regard to the protection of existing community facilities this policy offers a robust policy direction to not usually allow such losses subject to the given caveats. This again concurs with NPPF advise to guard against the unnecessary loss of valued community services.
8.68 When assessing the merits of the other two options, option A relies on the NPPF's objective to allow all sustainable development, with the exception of school provision which will be guided by local need and government and local authority priorities. However, this option does not necessarily give decision-makers clear guidance on the what is the best possible location of new facilities, based on the accessibility requirement for older people, the less mobile and residents without access to a car (the equitable requirement of the NPPF). Option B takes a stronger approach than option A, in that allows some consideration to be given to the location and planning considerations of the proposal but again it was felt most appropriate to guide new community facilities towards existing centres in the first instance. Supporting evidence
Sustainability Appraisal Objectives
5. Reduce the impacts of climate change, with a particular focus on reducing the
consumption of fossil fuels and levels of CO2; 7. Achieve good air quality; 8. Maximise the use of previously developed land and buildings, and the efficient use of land; 12. Encourage healthy lifestyles and reduce the health impacts of new developments; 13. Deliver more sustainable patterns of development by ensuring links to a range of modes of transport;
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14. Promote equity and address social exclusion by closing the gap between the poorest communities and the rest through a more equitable sharing of the benefits of prosperity; 16. Enhance community identity and participation; 17. Reduce both crime and fear of crime; 18. Ensure that everyone has access to education at all ages and levels, raising attainment and enhancing local workforce skills that much current and future business requirements; 19. Ensure that people have equitable and easy access to shopping, community and other services and facilities; 21. Enhance the vibrancy and vitality of the city centre and local centres and encourage a complementary appropriate mix of uses and facilities within centres.
Sustainability Appraisal Working Paper Comments
Encouraging community growing spaces and community allotments will create or enhance local biodiversity. New large retail units will add to the overall energy demand of the city so future local plan policy has the potential to encourage such large units to adapt energy efficient methods in their design. As new health and education facilities are both huge consumers of energy, future local plan policy should address this. To promote good public health and encourage more healthy lifestyles future local plan policy could restrict the number of new fast food outlets opening within reasonable walking distance of secondary schools, youth centres, playing fields, parks and play spaces; support the provision of community growing schemes and encourage the release of land for community allotments. The hierarchy of centres will provide a good distribution of community services across the city, however there appears to be some pockets of the community that are not within easy walking distance of a centre, notably the eastern and marfleet areas of Hull. These centres if supported and enhanced will help support local economic growth. If the preferred option results in increased integration of health and education resources within centres (as community hubs) equitable access to community facilities will occur. Setting a locally specific threshold for the scale of future retail development will support small local businesses , however it is not determined whether the options identified will discourage new medium sized units from being located in centres.
Main Evidence Base Sources
Smaller local centres and neighbourhood parades survey (2011) Hull Retail and District Centres Study (2013) Hull Retail Survey (2014 - 15)
DRAFT JUNE 2015 143 144 ulLclPa:PeerdOptions Preferred Plan: Local Hull
RF UE2015 JUNE DRAFT Table 8.1: Schedule of centres
Classification Name No. of No. No. of A1 shops No. of key No. of A5 retail of & % of units multiples outlets & % of units convenience units units City Centre 1. Hull City Centre 614 38 343 - (56%) 59 14 - (2%)
District Centres 2. Hessle Road 228 24 125 - (55%) 9 14 - (6%)
3. Holderness Road 163 18 93 - (57%) 9 6 - (4%)
4. Kingswood 421 16 - (76%) 11 0 - (0%)
5. North Point 965 45 - (69%) 9 2 - (3%)
Local Centres 6. Anlaby Road 132 14 52 - (39%) 2 16 - (12%)
7. Annandale Road 515 12 - (80%) 1 3 - (20%)
8. Beverley Road/Cave Street 1761 34 - (56%) 4 8 - (13%)
9. Beverley Road/Cottingham Road 454 22 - (41%) 1 10 - (19%)
10. Beverley Road/Washington Street 640 20 - (50%) - 6 - (15%)
11. Chanterlands Avenue 1183 50 - (60%) 1 6 - (7%)
12. Cottingham Road/Hall Road 124 11 - (46%) - 3 - (13%)
13. Endike Lane 530 20 - (67%) 1 6 - (20%) Classification Name No. of No. No. of A1 shops No. of key No. of A5 retail of & % of units multiples outlets & % of units convenience units units 14. Gipsyville 948 21 - (44%) 1 8 - (17%)
15. Grampian Way 310 5 - (50%) - 2 - (20%)
16. Grandale 316 8 - (50%) - 6 - (38%)
17. Greenwich Avenue 717 13 - (76%) 1 2 - (12%)
18. Greenwood Avenue (West) 717 12 - (71%) 1 3 - (18%)
19. Holderness Road/Faraday Street 330 13 - (43%) 1 7 - (23%)
20. Holderness Road/Morrison’s 222 11 - (50%) 1 6 - (27%)
21. Ings Centre, Savoy Road 518 10 - (56%) 2 3 - (17%) Options Preferred Plan: Local Hull
22. Marfleet Lane 517 11 - (65%) 1 2 - (12%)
23. Newland Avenue 170 25 74 - (44%) 1 13 - (8%) RF UE2015 JUNE DRAFT 24. Orchard Park* 313 7 - (54%) - 2 - (15%)
25. Princes Avenue 773 33 - (45%) - 5 - (7%)
26. Shannon Road 417 7 - (41%) - 3 - (18%)
27. Southcoates Lane 330 14 - (47%) - 7 - (23%) 145 146 ulLclPa:PeerdOptions Preferred Plan: Local Hull
RF UE2015 JUNE DRAFT Classification Name No. of No. No. of A1 shops No. of key No. of A5 retail of & % of units multiples outlets & % of units convenience units units 28. Spring Bank 104 17 52 - (50%) 1 9 - (8%)
29. Spring Bank West 442 23 - (55%) 1 6 - (14%)
30. Sutton Village 131 19 - (61%) 1 2 - (6%)
31. Tween Dykes Road/ Ings Road 314 9 - (64%) - 3 - (21%)
32. Willerby Road 321 11 - (43%) - 4 - (19%)
Neighbourhood Centres 33. Anlaby Road/Anlaby Park 37 4 - (57%) - 2 - (29%)
34. Anlaby Road/Calvert Lane 111 4 - (36%) - 2 - (18%)
35. Anlaby Road/ Coltman Street 316 6 - (38%) - 2 - (13%)
36. Anlaby Road/East Ella Drive 19 8 - (89%) - 1 - (11%)
37. Askew Avenue 16 3 - (50%) 1 1 - (17%)
38. Barham Road 19 2 - (22%) - 4 - (44%)
39. Bethune Avenue 17 3 - (43%) - 2 - (29%)
40. Beverley Road/Melwood Grove 111 5 - (45%) - 2 - (18%)
41. Beverley Road/Riversdale Road 212 5 - (42%) - 4 - (33%) Classification Name No. of No. No. of A1 shops No. of key No. of A5 retail of & % of units multiples outlets & % of units convenience units units 42. Beverley Road/Strand Close 215 5 - (33%) - 3 - (20%)
43. Beverley Road/Sutton Road -7 2 - (29%) 1 1 - (14%)
44. Boothferry Road/Belgrave Drive 110 7 - (70%) - 1 - (10%)
45. Boothferry Road/North Road 210 7 - (70%) - 1 - (10%)
46. Bricknell Avenue 27 3 - (43%) - 3 - (43%)
47. County Road South 18 3 - (38%) - 2 - (25%)
48. Dalsetter Rise 14 2 - (50%) - 1- (25%)
49. Greenwood Avenue (east) 311 6 - (55%) - 2 - (18%) Options Preferred Plan: Local Hull
50. Goodwin Parade (Walker Street) 29 5 - (56%) - 1 - (11%)
51. Holderness Road/Woodford 120 13 - (62%) - 2 - (10%) RF UE2015 JUNE DRAFT 52. Hotham Road South 26 4 - (67%) - 1 - (17%)
53. Inglemire Lane/Hall Road 18 2 - (25%) - 2 - (25%)
54. James Reckett Avenue 29 6 - (67%) - 1 - (11%)
55. Kingswood Village Centre 27 3 - (43%) 1 0 - (0%) 147 148 ulLclPa:PeerdOptions Preferred Plan: Local Hull
RF UE2015 JUNE DRAFT Classification Name No. of No. No. of A1 shops No. of key No. of A5 retail of & % of units multiples outlets & % of units convenience units units 56. Preston Road Village 16 1 - (17%) 1 0 - (0%)
57. Priory Road 24 4 - (100%) - 0 - (0%)
58. Spring Bank West/ Luton Street 19 5 - (56%) - 2- (22%)
59. The Quadrant -7 3 - (43%) - 1- (14%)
60. Victoria Dock 16 3 - (50%) - 1- (17%)
61. Wawne Road/Zeals Garth 15 1 - (20%) - 1 - (20%)
62. Wold Road 316 7 - (44%) - 4 - (20%)
* Orchard Park Local Centre was undergoing an extensive regeneration programme at time of survey Hull Local Plan: Preferred Options
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9. Design and Heritage 9.1 The need for good quality design that takes account of the history and unique features of a place is fundamental to good planning. There is evidence to suggest that good quality, well designed places add value to people's lives by promoting opportunities for walking, cycling and social interaction. It is important that the policy framework continues to require good design in all applications to ensure that the quality of the built environment in the city is improved where possible. Design
9.2 Paragraph 58 of the National Planning Policy Framework advises that Local Plans should develop robust and comprehensive policies that set out the quality of development that will be expected for the area. The policies should be based on stated objectives for the future of the area and an understanding and evaluation of its defining characteristics.
9.3 It then goes on to advise that policies should aim to ensure that developments:
will function well and add to the overall quality of the area over the lifetime of the development; establish a strong sense of place and create attractive and comfortable places; optimise the potential of sites; respond to local character and history while not preventing or discouraging appropriate innovation create safe and accessible environments are visually attractive
9.4 Paragraph 61 also advises that policies should address the connections between people and places and the integration of new development.
9.5 A note of caution is sounded in Paragraph 59 which advises that while design codes could be used where they could help deliver high quality outcomes, policies should avoid unnecessary prescription or detail.
9.6 The Saved Local Plan (2000) has saved Policy BE1 which contains a credible detailed list of criteria against which design would be assessed.
You Told Us
In terms of the approach to be taken through the plan, opinions were mixed. There was some support for key design principles being set out in the Local Plan with more detail later in formal supplementary planning guidance documents However, it was expressed that less prescription delivers better outcomes and architects should have the freedom to design great buildings.
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It was put forward that safeguarding key views and vistas should have a specific policy approach, while there should be design guidance about tall buildings in the city centre, retrofitting flood mitigation measures and incorporating biodiversity into development.
In addition, the potential for food growing, reducing crime and anti-social behaviour and improve the appearance of main arterial roads were all put forward as areas that should be considered in the preparation of the plan.
Options
9.7 In this case, reasonable options relate to the criteria which are included within the policy. To this end, only a preferred option is put forward but additions or deletions may be necessary to ensure the effectiveness of the policy.
Preferred Option
Draft Policy 32
Design
Applications will be required to demonstrate how their design supports the creation of an attractive environment in Hull. Development proposals will need to demonstrate and have regard to:
1. the relationship between the development and any existing linkages and built form of the city in terms of:
1. layout
2. scale
3. massing
4. architectural structure and enclosure
5. detailing and materials
6. density
7. use and surrounding uses
8. setting and relationship to key heritage assets
2. encouraging active and healthy lifestyles
3. their contribution to public art
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4. opportunities to minimise the risk of crime
5. the creation of public spaces which provide places for community interaction through:
1. inclusive access
2. active frontages
3. high quality public realm
4. appropriate soft and hard landscaping
5. minimising the potential for anti-social behaviour.
Justification
9.8 It is important for there to be clear standards by which applications will be assessed. Design addresses a wide range of physical factors and the policy criteria above show how these will be considered.
9.9 However it is made clear in the NPPF that design goes beyond this: the built environment has a role to play in social cohesion through providing places where people can interact. Well designed places also encourage people to use them which can have positive health benefits through increased physical activity and mental health benefits. All of this is of particular importance in Hull in the run up to City of Culture and in encouraging people to visit and spend their leisure time in the city. This policy approach sets out the criteria that the evidence base for Hull suggests are important in ensuring the design of developments achieves the vision and objectives for the city.
9.10 This policy could be supported by a number of supplementary planning documents which will provide further advice and guidance on aspects of this policy if necessary such as about landscaping, materials, public art and minimising the risk of crime. Local Distinctiveness
9.11 The NPPF also advises that policies should aim to ensure that developments respond to local character and history, although it cautions that this should not prevent or discourage appropriate innovation. Paragraph 60 of the National Planning Policy Framework confirms that it is legitimate for policies to seek to promote or reinforce local distinctiveness.
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You Told Us
It was expressed that less prescription delivers better outcomes. It was suggested that improving the appearance of main arterial roads should be considered in the preparation of the plan.
Options
Option A: Do not have a policy on local distinctiveness. There is no requirement for local distinctiveness to have a policy in the Local Plan. The NPPF sets out detailed considerations that should be taken into account when taking decisions on a case-by-case basis.
Option B: Include a policy on local distinctiveness. This would allow the Local Plan to set out high level distinctive features of the city. This would provide guidance for applicants, decision takers and any future neighbourhood plans. It would be based on analysis of the heritage evidence base, the findings from the Urban Panel visit to Hull and the representations received to the Issues and Options consultation.
Preferred Option
9.12 Option B
Draft Policy 33
Local Distinctiveness
Applications will be expected to demonstrate that local distinctiveness will be promoted with particular reference to:
a. the Port, improving and access to and making effective use of the city’s waterfront and maritime assets along the River Hull and the Humber Estuary;
b. creating a network of landmarks in prominent or gateway locations to develop legible local references that distinguish parts of the city;
c. encouraging contemporary architecture that respects the city’s assets, creating positive and distinctive contributions to the rich built fabric;
d. Conservation Areas; and
e. arterial routes
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Justification
9.13 The Heritage Evidence Base demonstrates that there are locally distinct features to the city. This was reinforced by the Urban Panel report which stated that they were extremely impressed with the unique character of Hull. Consideration of these identified features suggests that positive benefits to the appearance of the city could be gained from their promotion through the Local Plan. Heritage
9.14 Section 12 of the NPPF sets out Government policy on the content of Local Plans with regard to the historic environment, along with considerations in the determination of applications which affect the historic environment. The NPPF defines the historic environment as: All aspects of the environment resulting from the interaction between people and places through time, including all surviving physical remains of past human activity, whether visible, buried or submerged, and landscaped and planted or managed flora. It also includes a definition of heritage asset: A building, monument, site, place, area or landscape identified as having a degree of significance meriting consideration in planning decisions, because of its heritage interest. Heritage asset includes designated heritage assets and assets identified by the local planning authority (including local listing).
9.15 Paragraph 126 sets out the principles of what the Local Plan should achieve with regards to the historic environment. Local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance. In developing this strategy, local planning authorities should take into account:
the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring; the desirability of new development making a positive contribution to local character and distinctiveness; and opportunities to draw on the contribution made by the historic environment to the character of a place.
9.16 Further guidance is contained within the Planning Practice Guidance. It develops this paragraph further:
Conservation is not a passive exercise. Specific opportunities for the conservation and enhancement of heritage assets.
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Identify where development could make a positive contribution to or better reveal the significance of a heritage asset. The strategy may result in the need for specific policies.
9.17 The heritage evidence base charts the history and development of Hull. This allows for areas which are likely to be of archaeological interest to be established. It also explores how water has shaped the development of Hull and local styles of building and materials.
9.18 It also sets out the extent of designated heritage assets within the city. There are 26 Conservation Areas, 461 Listed Buildings, 255 Locally Listed Buildings, 1 Scheduled Monument and 2 registered Historic Parks.
9.19 English Heritage's Urban Panel carried out a visit to Hull in July 2014. This report stated that the panel was extremely impressed with the unique character of Hull and its extraordinarily broad range of high quality heritage assets. One of the overall recommendations for the city was to 'make heritage work harder' with particular reference to the Old Town, the museums and to consider what the Council wants heritage assets to achieve. A heritage policy is included within the City Centre chapter in response to this in addition to the policies set out here.
You Told Us
May need policies to address issues which are not fully covered in the NPPF such as archaeological remains of less than national importance It was suggested the following additions could be made:
Benefits derived from the historic environment Issues and challenges facing the historic environment now and anticipated over the plan period. Further development of the range of identified heritage assets within Hull
Suggested areas of policy (these will need evidence base to support)
Areas where development of types of development should be restricted or prohibited Key views and vistas should be safeguarded Historic parks and gardens Local list decision making policies Policies for specific Conservation Areas
Other suggestions
Review of the Local List (linked to City of Culture?) Links to other policy and allocations in the Local Plan
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Impact of wider policies on heritage assets Impact of allocations on heritage assets
Planning Committee agreed that a tall buildings policy should be included in the Local Plan and that particular consideration should be given to not using the imprecise measurement of the number of storeys; that a measurement of a storey should be replaced with the building heights in that any policy should be site specific; the protection of sight lines; the need to ensure any applications submitted for tall buildings included a high quality of design, and whether the land the City of Hull was built on was suitable for the construction of tall buildings.
Options
Option A: This option would rely on using the NPPF to determine applications which would have an impact on heritage assets. The NPPF has detailed policies and guidance on the determination of applications which would affect a historic asset.
Option B: This option would take the available evidence about the heritage assets of the city, and set out the most significant heritage assets in the city to be taken into account in development proposals.
Option C: This option would build on Option B by including additional policy criteria relating to topics where the NPPF does not provide the necessary level of detail or which respond to the specific issues which may face Hull's heritage assets over the lifetime of the plan.
Option D: This option would build on Option C by including additional policy criteria which highlight the special interest in Hull's heritage assets.
Preferred Option
9.20 Option C is the preferred option.
Draft Policy 34
Heritage Assets
1. Proposals and initiatives will be supported which preserve and/or enhance the significance and setting of the city's heritage assets, especially those elements which contribute to the distinct identity of Hull. Important heritage assets include:
a. Listed Buildings, Conservation Areas and Registered Historic Parks and Gardens;
b. distinctive historic buildings, wet and dry docks, wharves and ancillary structures and features relating to Hull’s fishing, maritime and industrial heritage;
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c. the City Centre, with particular reference to the surviving medieval and early post-medieval settlement, the Georgian townscape, and Victorian and Edwardian public buildings, especially within the Old and New Towns, and in the Charterhouse Conservation Areas
d. locations in the wider city which define the historic development of Hull such as the historic cores of medieval villages and settlements, particularly Sutton and Marfleet, the later nineteenth and early twentieth century suburban developments such as the Avenues/Pearson Park and Anlaby Park, and planned garden suburbs at Broadway and Garden Village;
e. locally listed buildings; and
f. archaeological remains and deposits including the nationally significant military defences dating from the mid-sixteenth to the mid-nineteenth centuries on the east bank of the River Hull and the Romano-British riverside settlements lining the banks of the River Hull from Kingswood to Stoneferry.
2. Where evidence supports, Article 4 Directions removing permitted development rights will be introduced to preserve the character of an area.
Draft Policy 35
Heritage Considerations
1. Development that would cause harm to a heritage asset will only be approved where it has been demonstrated that the harm cannot be avoided there would be significant public benefits that would outweigh the harm caused.
2. Where applications are acceptable in principle but would affect an archaeological deposit of less than national importance, the Council will seek to preserve the remains in situ. If this is not achievable, adequate provision for excavation and recording before and during development will be required.
3. Applications affecting non-designated heritage assets must demonstrate that they have taken account of the particular interest of the asset. Applications which would result in the loss of a non-designated heritage asset must demonstrate that:
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1. it would not be economically viable for the asset to be retained and that harm could not be avoided; or
2. The economic or community benefits of the proposed development outweigh its loss.
4. Applications for tall buildings (above 30m in height) in the City Centre must demonstrate that:
they would not harm the character and appearance of the City Centre Conservation Areas which are characterised by their low rise nature;
there would be an acceptable impact on views and vistas across and within the City Centre;
they are providing a positive contribution to the skyline; and
they are of a high design standard.
Justification
9.21 Hull’s heritage assets are truly unique and reflect the City’s particular evolution. It is important that the Local Plan recognise this, and make clear what these are, especially given the identified importance of the historic environment in delivering the City Plan and in making City of Culture a success. While the NPPF sets out important principles to be applied when considering applications for development, by its very nature it cannot provide a local dimension which would add value for developers and decision takers. This discounts Option A.
9.22 While Option D has much to recommend it as it would allow for a deep understanding of places, it is considered policy at that level of depth should be delivered through neighbourhood plans. The Council will continue to support the improvement of heritage assets through its work on Buildings at Risk, Conservation Area Character Appraisals and the use of additional Article 4 directions where this is necessary.
9.23 Option B would allow for more locally nuanced aspects of heritage to be articulated, providing more useful advice both to applicants and decision takers. This Policy approach would reflect the comments of Historic England (English Heritage as they were then) in the response to the Issues and Options consultation. However, it would not provide a policy framework for non-designated assets such as buildings on the Local List and archaeological deposits of less than national importance, which can add value, particularly in areas which have limited heritage assets to act as touchstones to the past.
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9.24 It is therefore considered that Option C is the most appropriate. For clarity, it is proposed to split Option C into two policies: one which sets out the historic assets to be considered and the other to set out more specific detail on how applications will be considered. Energy efficient design
9.25 Efficient use of natural resources is listed in the National Planning Practice Guidance as one of the design issues that planning should consider. Policy BE2 of the saved Local Plan (2000) sets out the current requirements for energy efficient design. It states:
a. High standards of energy efficiency in development will be promoted.
b. Development will be encouraged which takes energy efficiency into account in its design, if appropriate, including the following:
i. the appropriate siting, form, orientation and layout of buildings; ii. the appropriate location and size of windows; iii. the internal layout of rooms within buildings; iv. using soft landscaping, including tree planting; v. using energy efficient technology for heating and lighting including the introduction of combined heat and power schemes and solar collectors, if appropriate; and vi. using sustainable materials.
9.26 In 2006 the Government set a pledge that by 2016 all new homes should be ‘zero carbon’. This is now anticipated to happen towards the end of 2016. The definition of what is meant by zero carbon has been refined over time. Even now, many of the details have still to be agreed. We know that there will be three core requirements, all of which must be met for a home to qualify as zero carbon. These are:
1. The fabric performance must meet a minimum standard – in other words, the building will need to be well insulated.
2. Regulated CO2 emissions (i.e. those created by heating, cooling, fixed lighting and ventilation) must be below a set limit. This can be achieved through good insulation and the use of on-site renewable energy.
3. Any remaining regulated CO2 emissions (after requirements 1 and 2 have been met) must be reduced to zero. This can be achieved either by exceeding the requirements for 1 and 2 or by paying into an “allowable solutions” fund.
9.27 A key part of the system will be the allowable solutions fund, which developers will pay into for each tonne of carbon dioxide that the development is likely to produce over its lifetime. The money is then invested into schemes that offset those emissions. Because of concerns over viability, the government have decided that small housing sites of 10 units or fewer will not have to pay towards allowable solutions.
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9.28 Until recently, the Code for Sustainable Homes has been a Government-sponsored scheme that summarised the overall sustainability of new homes into an easy-to-understand score. It was intended to be market-led, with purchasers willing to pay a premium for more sustainable homes, and the development industry meeting the demand. In reality, few people outside of the industry were aware of the Code. Some local authorities made it a mandatory standard for new homes in their area, with Hull including it in the Newington and St Andrews and Holderness Road Corridor area action plans.
9.29 Last year the Government undertook a review of housing standards. It resulted in a Ministerial statement being issued in April 2015 instructing local authorities not to set any local requirements relating to the construction, internal layout or performance of new buildings – including any requirement for Code for Sustainable Homes. Although we considered making the Code for Sustainable Homes a requirement for new housing, this appears to be not an option now.
9.30 The other prominent rating system is known as BREEAM. In a recent study of development viability for the city, non-residential developments were generally found to be not financially viable, and often only go ahead with subsidy funding. However it is also hoped that if the zero carbon requirement for new homes is a success then the government will extend it to other types of building in due course.
9.31 The Government’s guidance states Local Plans should promote low carbon design approaches to reduce energy consumption in buildings, such as passive solar design. Passive solar design takes into account the position of the sun throughout the year and the thermal properties of the building materials. This knowledge is used to maximise the heating of the building using the sun during the winter and to keep the building cool through shading and ventilation during the summer. By doing this, the need to use mechanical heating and cooling is kept to a minimum. The correct choice in orientation, layout and materials of each building is obviously crucial to making this strategy successful. Specialist design skills and the use of software at the design stage are required to test models to find the optimum design.
9.32 The Government guidance tells us that it is important that passive solar design considers the potential for overheating in the summer, as well as reducing the need for heating in the winter. This is important in Hull where 11% of households experience fuel poverty. A range of design solutions can be considered to help avoid overheating and the need for air conditioning. For example, high levels of thermal mass, maximising natural ventilation, passive cooling using planting for shade, roof overhangs to provide shade for high-sun angles, and smart glazing materials. The urban heat island effect can be reduced by, for example, allowing sufficient space between buildings, tree planting, shading and street layouts which encourage air flow and using light and reflective surfaces or vegetation on buildings. A summary of these principles is illustrated in the diagram below.
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Figure 9.1 Summary of sustainable design and passive solar design principles
You Told Us
9.33 With regards to sustainable building standards:
Be careful not to kill off development with too high standards. HCC should provide additional support to development that reduces carbon emissions over and above national standards. Much of the city has significant viability issues and therefore inclusion of additional standards is likely to compromise plan delivery. The Government’s zero carbon standard to new homes will have a significant cost for development. Good security is a basic requirement for our future City – we should impose the security requirements of schemes such as BREEAM or Code for sustainable homes as mandatory minimum standard Need to think of strategy to encourage occupiers of existing buildings to improve energy efficiency in existing buildings. Support a policy on passive solar design. Passive solar design should be encouraged in all new builds or refurbishments.
Options
Option A: Adopt a policy similar to the saved Local Plan (2000) policy BE2 which promotes high standards of energy efficiency in design. This could be brought up-to-date by incorporating wording from the National Planning Practice Guidance with regards to passive solar design. Further explanation of the principles of passive solar design could be provided in the accompanying text or in an SPD.
Option B: Adopt a policy requiring a minimum BREEAM rating for non-residential buildings unless it is demonstrated not to be viable. Our evidence base suggests that such a requirement is unlikely to be viable over the city but a 'very good' standard has been met on some new build schemes.
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Option C: Do not adopt any policies that require sustainable design over and above minimum statutory building regulation standards.
Preferred option
9.34 Options A and B.
Draft Policy 36
Energy efficient design
1. Development proposals should demonstrate how the design will reduce energy and water use and mitigate against flooding, pollution and over-heating. This should include consideration of the siting, form, orientation, layout and construction materials of buildings. The principles of passive solar design should be followed to minimise the need for mechanical heating and cooling. 2. Non-residential development should seek to achieve BREEAM 'very good' or better unless it is agreed that it is not viable to do so.
Justification
9.35 It is highly desirable to make new buildings as energy efficient as possible. New government rules mean that we can no longer specify Code for Sustainable Homes. Instead, changes to Building Regulations will mean that new homes will have to become more energy efficient. We can still specify a BREEAM rating for non-residential development, but we have to be mindful that it does not to have an undue impact on development viability in the city. We have therefore chosen Option A which promotes energy efficient design and in particular, passive solar design, and Option B which requires BREEAM 'very good' when it is viable. Further guidance could be given to how the principles of passive solar design should apply in Hull. This could be published an a Supplementary Planning Document (SPD). Shop Fronts
9.36 Hull has a number of local centres, many of which are linear along major routes through the city. Changing shopping patterns have created challenges for these centres. When consumers have extensive choice as to where to shop, an attractive environment will be important in encouraging people to use local facilities.
You Told Us
Concerns were raised about over-prescriptive policy requirements.
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Options
Option A: Do not have a policy on shop fronts. A supplementary planning document could be developed which could be aligned with the key design policy.
Option B: A policy could set out key considerations for shop front design, with the potential for more detailed guidance through a supplementary planning document.
Preferred Option
9.37 Option B is the preferred option.
Draft Policy 37
Shop Fronts
1. Shop fronts should be designed with regard to the character of the building on which it is to be sited and the character of the surrounding area. Particular care should be given to the proportions and alignment of the shopfront relative to the building, to the size of the fascia and any projecting signs, particularly within Conservation Area.
2. The installation of permanent security features must show why less intrusive security measures would not be appropriate. Security features must be designed as integral features of the shopfront and must be treated in such a way as to provide an active frontage when lowered. Applications for solid, untreated shutters will be refused.
Justification
9.38 The appearance of a shopping area can be important for a number of reasons. It is less likely that people will chose to visit centres or to spend leisure time in centres which are unattractive. The external appearance of a building is an important factor in this and it is therefore considered that a policy should be included in the Local Plan which makes clear that shop fronts should be well designed. Advertisements
9.39 NPPF advises that control over outdoor advertisements should be efficient, effective and simple in concept and operation. However, it does recognise that poorly placed advertisements can have a negative impact.
You Told Us
Concerns were raised about the risk with over-prescriptive policy requirements.
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Options
Option A: Do not have a policy on advertisements. A supplementary planning document could be developed which could be aligned with the key design policy.
Option B: A policy could set out key considerations about advertisements, with the potential for more detailed guidance through a supplementary planning document.
Preferred Option
9.40 Option B is the preferred option.
Draft Policy 38
Advertisements
1. Applications for advertisement consent will be approved where they have an acceptable impact on public safety and amenity. Assessment of these impacts will have particular regard to:
1. the impact of the advertisement on the safe movement of vehicles and pedestrians;
2. the impact of the advertisement on CCTV coverage;
3. the character of the surrounding area, particularly in Conservation Areas and in proximity to heritage assets;
4. the relationship of the advertisement to the features of the building it is placed on; and
5. advertisement clutter.
2. Advertisements which have a seriously detrimental impact on amenity or public safety will be removed.
Justification
9.41 Advertisements are most commonly found in commercial locations, and it has been set out through the Local Plan the importance of improving the public realm of the city as part of City of Culture and supporting the development of the city as a tourist destination. Advertisements can have a particular impact on perception of place. Including a policy highlighting the issues to be taken into account when designing an advertisement will be of use to applicants and makes clear the importance being placed on the wider amenity of the city.
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Designing Employment Development
9.42 The quality of the environment is important everywhere. The principles of good design should apply to all developments and locations and this includes employment areas.
You Told Us
No comments were received specific to this issue.
Options
Option A: Do not have a policy about designing employment development.
Option B: Include a policy about designing employment development.
Preferred Option
9.43 Option B.
Draft Policy 39
Designing Employment Development
Employment development should be designed to:
1. Have regard to the surrounding context ; 2. Minimise impacts such as noise, disturbance and overlooking, particularly where the site is adjacent to residential properties; 3. Provide a sense of identity and variety, particularly in a prominent locations; 4. Use appropriate soft and hard landscaping to integrate the development into the surrounding area.
Justification
9.44 Economic growth is fundamental to Hull's aspirations to grow and develop as a city. It is of key importance that every potential barrier to investment is tackled, and a poor quality environment could be perceived as a barrier to investment. It also must be recognised that Hull's employment land is located in close proximity to other uses, including residential: it is important that clear standards for what will be expected are in place to provide certainty to developers and neighbouring occupiers.
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Supporting Evidence
Sustainability Appraisal Objectives
2. Maintain and enhance water quality and limit water consumption to levels supportable by natural processes and storage systems, taking into account the impact of climate change;
3. Ensure that new development does not increase flood risk and protects or enhances the capacity & integrity of flood storage areas;
5. Reduce the factors causing climate change, with a particular focus on reducing
the consumption of fossil fuels and levels of CO2;
6. Ensure that development is capable of withstanding the effects of climate change;
7. Achieve good air quality;
9. Use natural resources, both finite and renewable, as efficiently as possible, and re-use finite resources (including waste) or recycled alternatives wherever possible;
11. Conserve and enhance the landscape and townscape, encouraging local distinctiveness
12. Encourage healthy lifestyles and reduce the health impacts of new developments;
13. Deliver more sustainable patterns of development by ensuring links to a range modes of transport.10. To maintain and enhance historic and cultural assets
16. Enhance community identity and participation
17. Reduce both crime and fear of crime
Sustainability Appraisal Working Paper Comments
The Sustainability Appraisal Working Paper made a specific comment about using design in the Local Plan to address crime prevention: The Local Plan options do not discuss spatial intervention to the prevention of crime (actual and perceived). This is considered as a major gap, therefore key recommendation from the assessment is for the Plan to consider how architectural and urban design can help reduce the possibility of crime spots for example through street lighting or by adopting Secured by Design Standards in residential and commercial buildings. Local Plan policies could encourage new education and health care premises to include water efficiency measures; The Sustainable Building Standard Issue could elaborate on the requirement of BREEAM or Code for Sustainable Homes (CfSH)
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standards by seeking suggestion on the level of standard to set as a minimum, for example Good, Very Good or Excellent; In order to progress the water resources, resources efficiency and waste minimisation objectives, within the Climate change chapter, consider discussing on setting a higher standard – such as Good or Very Good, or CfSH Level 4 or 5, rather than opting for minimum standards; Within the Air quality chapter, discuss and consider the provision of electric charging points within Hull, including at the travellers sites; Consider discussing material efficiency (construction materials) and waste management within the operations and construction stages. For example, some policy requirement to determine planning applications on the need to demonstrate that the waste hierarchy was applied, or to encourage use of alternative materials in construction that will reduce embodied carbon. See criteria list under SA 9 of the SEA/SA Framework (Appendix 1) for guidance;
Main Evidence Base Sources
Community Infrastructure Levy and Development Standards – Area Wide Economic Viability Assessment (HCC, November 2012) Renewable Energy and Energy Efficiency Study (HCC, July 2010) Hull Environment and Climate Change Strategy (HCC, 2010) The National Adaptation Programme (Defra, July 2013) Hull Local Plan 2000 Heritage Evidence Base Urban Panel Review
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10. Transport Introduction
10.1 The National Planning Policy Framework states that local plans should encourage the use of sustainable travel by identifying, protecting, and improving key transport routes and exploiting opportunities to widen transport choice. New developments need to be accessible as possible by a wide variety of travel modes. The NPPF also expects local plans to support schemes that lead to carbon reduction and reduce air pollution caused by traffic congestion. Planning Practice Guidance which supports the NPPF states that it is important for local planning authorities to have a robust transport evidence base to support the preparation of their local plans.
10.2 The Council produces a Local Transport Plan that sets out the vision and aims for transport in Hull. The current Local Transport Plan (LTP) sets the transport priorities for the emerging Local Plan. The LTP’s vision is “to provide and develop a safe and efficient transport system that contributes to the social, environmental and economic well being of the residents, businesses and visitors to the city.” The LTP aims to have a city committed to a low carbon future, which has a transport network and mobility culture that positively contributes to a thriving economy and the health and wellbeing of its citizens and where sustainable travel is the option of choice. The LTP seeks to deliver a transport system to meet the needs of a growing and successful city. The LTP's transport improvement schemes need to be embedded in the Local Plan.
10.3 The continued dominance of the car, often at the expense of other transport modes, presents a major challenge to transport planning in Hull. Although the road system in and around Hull has greatly improved in recent years, the city has also experienced a rise in traffic levels. Traffic and congestion continue to be a problem, but the scope for increasing road capacity further is limited, in most cases, by physical and environmental constraints. Levels of pollution from vehicle emissions have led to an air quality management area being declared for much of the city centre. However, the city is fortunate in having many advantages, such as a compact urban area and flat terrain, for enabling sustainable travel to be a realistic option for a large proportion of its residents. Sustainable transport
10.4 Sustainable transport is a key component of sustainable development. Sustainable transport refers to any means of transport with a low impact on the environment, and includes walking, cycling and public transport. It aims to ensure that new development reduces the need to travel, gives priority to pedestrians and cyclists and convenient access to jobs, homes, shops, public transport and services, such as education, healthcare, recreational facilities and open space. Moving people and goods is essential
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to the everyday life of the city. People need to reach places for work, education, health care, shopping, recreation and entertainment, and goods must be moved between docks, factories, warehouses and shops. An efficient transport system widens access to opportunities for local people and assists regeneration of the local economy. However, the growing demand for mobility is taking its toll on the environment. Traffic congestion is increasing and, more seriously, so is pollution. A more sustainable transport system must be developed, balancing the needs of the economy with the environment, as well as meeting the needs of the whole community.
10.5 Emissions from road vehicles are a major source of greenhouse gases. National and local policies are now seeking to reduce the need to travel, particularly by car, by encouraging development to locate in existing urban areas where facilities can more easily be reached by public transport, cycle, or on foot. The aim is to increase accessibility for all rather than mobility for some. Proposals should be supported that restrict private motor-vehicular access to improve air quality. The Council aims to tackle the ongoing air quality issues in the city and help deliver carbon reduction targets. A main focus is reducing emissions from transport to maximise sustainable transport and improve local air quality breaches. In particular to deliver a series of measures targeted specifically at reducing emissions within the city centre’s existing AQMA where air quality is of particular concern.
10.6 There is expected to be a growing need to provide electric charging vehicle infrastructure in public places (on street/ car parks) as well as at commercial and industrial premises and residential dwellings. The existing electric vehicle infrastructure in the city has less than ten available points in public spaces. The development of hydrogen as a fuel source in vehicles is still at an early stage and a national network of charging stations as well as affordable vehicles are a number of years off. Despite this, the Local Plan is likely to see the development of such a network grow and therefore the space required for this infrastructure will need to be considered as both of these emerging energy markets grow. The Council is currently developing a climate change risk assessment for highways in the city and this will identify future actions. Smart transport solutions put forward by the Department for Business, Innovation and Skills are seen as a means of enabling authorities to reduce congestion, by integrating information from different modes of transport. Whilst there are fundamental gaps in the provision of smart cities infrastructure, for example gaps in information to manage traffic flow and availability of funding, there are strong opportunities available in existing infrastructure and the experience of design services available.
You Told Us
Ideally the strategy of the plan should not be to simply “balance” the needs of transport with those of the environment and public health but, rather, to positively reduce the potential adverse effects which transport can have upon these two areas.
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The plan could assist the City in becoming greener and healthier, for example as in Stockholm. Support for the approach to balancing the needs of transport with those of the environment. Transport schemes can deliver environmental ‘wins’ e.g. through maximising the delivery of green infrastructure, ecosystems services and new habitat through scheme design, mitigation and management. A balanced approach is essential. Needs of the environment, public health and human wellbeing should equal those of transport. Support for the proposed approach to ensure that the environment is considered in relation to transport.
Options
Option A: The transport chapter to include an introductory policy setting out the Plan's commitment to achieving sustainable transport objectives within developments.
Option B: Option A with the addition of specific objectives for achieving sustainable transport in Hull such as: improving air quality; provision of electric vehicle infrastructure provision; and support for the introduction smart transport solutions.
Preferred Option
10.7 Option B
Draft Policy 40
Sustainable transport
Transport improvement schemes and individual developments which promote sustainable transport objectives will be supported. Such developments will have minimal impact on the environment and public health and should, where possible: include provision for walking, cycling and public transport; reduce the need to travel; reduce congestion; give priority to pedestrians and cyclists; provide convenient access to jobs, homes, shops, public transport and services, education, health care, open space and recreation facilities; and improve the journey time reliability of public transport.
Developments which do not promote sustainable transport objectives will be discouraged.
Developments which promote sustainable transport objectives by seeking to: improve air quality; provide alternative fuel sources; and use smart transport solutions will be welcomed.
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Justification
10.8 As well as identifying general sustainable transport objectives that need to be met by developments, Option B draws out those of particular relevance to the city. Location and layout of development
10.9 NPPF states that local plans should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised. More sustainable development can be achieved by fully considering the travel implications of development and locating it where the need for transport, particularly by car and lorry, can be minimised. The need to travel can be reduced by encouraging the provision of local facilities close to where people live, which can easily be reached on foot or by cycle. The demand for travel by private car can be minimised by locating major development attracting journeys by people, such as office, shopping and leisure uses, along public transport corridors, such as radial roads, or in the city centre, which is the focus of the public transport system. Housing generates journeys and should be located where it can be well served by public transport.
10.10 Development should provide satisfactory road access and adequate servicing and parking to minimise traffic and parking problems. This should provide for access by public transport, cycling, walking and the mobility impaired, to maximise accessibility and encourage the use of alternatives to the car. This provision should be appropriate to the scale, type and location of the development. Development should also be acceptable in terms of traffic generation and road safety.
10.11 Careful choice of location and layout of new development, combined with appropriate, design and management measures including adequate provision for pedestrians, cyclists and users of public transport in all new development can help to reduce the dependence upon cars, providing a safer, and more sustainable (and in the case of walking and cycling, a more healthy) alternative means of travel for most members of the community either for leisure or more functional purposes. Development involving significant movements of freight, such as warehousing and manufacturing, should generally be located away from housing areas, in places with good access to rail or water transport, if possible, or the Classified Road Network (see later section).
Options
Option A: Have a general policy guiding the location and layout of development to ensure sustainable transport objectives are met. The policy to be criteria based mainly setting down accessibility requirements.
Option B: Same as Option A but for guidance purposes stipulate minimum accessibility distances.
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Preferred Option
10.12 Option B
Draft Policy 41
Location and layout of development
Development will be supported if it:
a. provides all user modes of transport with safe,convenient, and direct access,where appropriate, to:
the road network;
public transport (eg bus stops) (minimum walking distance 400m); pedestrian routes; cycle routes; public rights of way; local services and facilities (minimum walking distance 400m); rail or water transport for heavy freight movement; and
b. provides within the site, where appropriate :
public transport facilities; cycle and walking facilities; initiatives to reduce congestion and air pollution; layouts to assist accessibility for mobility impaired; adequate parking provision; a choice of travel, encouraging modes of transport which conserve energy and reduce pollution; and
c. Delivers,where appropriate:
proposals that are acceptable in terms of traffic generation and road safety; new cycle, pedestrian routes,public transport and facilities which serve the site.
Justification
10.13 Having minimum accessibility distance standards included in the policy will be helpful to developers and lead to more consistent decision-making.
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Transport assessments
10.14 NPPF requires that developments that generate significant amounts of movement should be supported by a transport statement or transport assessment and required to provide a travel plan. A transport assessment (TA) is a comprehensive and systematic process that sets out transport issues relating to a proposed major development. It identifies what measures will be taken to deal with the anticipated transport impacts of the scheme and to improve accessibility and safety for all modes of travel. All development proposals that can be reasonably expected to have an impact on the transport network must be supported by a transport statement (TS) or by a transport assessment (TA) and travel plan (TP), as appropriate, depending on the scope and scale of the development.
10.15 TPs can help reduce the number of car trips to a development. They aim to reduce the number of journeys needed, where possible, and to encourage choice and use of sustainable means of transport to development sites. This can include walking, cycling, car-sharing, working from home, awareness-raising campaigns or subsidised public transport season tickets for employees. Currently the Council assesses the need for TS/TA/TPs on an individual basis with reference to the Department for Transport’s guidance on transport assessments. It would be helpful and more consistent if the Local Plan could give further guidance as to the scale and types of development that require such assessments and what they should contain.
You Told Us
Guidance should cover the scope of transport assessments, transport statements and travel plans and Highways England would be interested in liaising with the Council over the development of this guidance.
Options
Option A: As currently undertaken, to decide the need for TS/TA/ TPs on an individual basis with reference to Department of Transport guidance.
Option B: The Local Plan provides further guidance as to the scale and type of development that would require TS/TA/TPs.
Preferred Option
10.16 Option B
Draft Policy 42
Transport assessments
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Developments that generate significant amounts of movement should be supported by a transport assessment. Proposed guidance on the scope/type of transport assessment required is provided in Table 10.1 and is included in the Council's Highways Design Guide for New Development. Requirements are largely dependent on the scale and nature of the proposed development.
Justification
10.17 Option B would provide clarity as to which developments require TS/TA/TPs. This will be of benefit to both developers and decision makers and lead to more consistent decisions in this respect.
Classified Road Network
10.18 The city's Classified Road Network (CRN) consists of routes between places of traffic importance - see Map 10.1. The main purpose of the CRN is to carry long distance and through traffic. It is therefore important that development along these roads does not compromise their main function by adding significant local traffic movements and ensures efficient intra-urban motor vehicle access between key locations. Such development includes proposals requiring planning permission for vehicle crossovers (drop kerbs) on classified roads. It is important that the ability of the CRN to meet expected demand arising from development is protected. Direct access onto a classified route should be avoided if possible; access should be to a secondary road. If development is adjacent to a CRN road, the need for any road improvements is likely to be required. Direct access onto the CRN would reduce its effectiveness, thereby increasing congestion and, consequently, journey time and pollution.
10.19 The A63 Castle Street / A1033 forms the main access artery for Hull and serves the city centre, the port and key development sites. Castle Street is one of the busiest stretches of road in East Yorkshire. It is the responsibility of Highways England to maintain this road and it forms part of the country's strategic road network . Other radial routes suffer local congestion at peak times, but do not have the same strategic significance. There is a general presumption that no new accesses onto this strategic road will be made. The A63 Clive Sullivan Way provides a direct link to the national motorway network, the A15 across the Humber Bridge provides a fast link to eastern England, and the A1079 has been progressively upgraded providing better links to the north. In addition, three sides of an orbital box of roads have been constructed around the city centre, enabling improved traffic circulation around the city centre and facilitating extensive pedestrianisation in the main shopping areas. The city’s CRN roads have a pivotal role in helping to bring forward the city's economic regeneration.
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Picture 10.1 Classified Road Network
You Told Us
Concerns over the city’s north-south links.
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Transport network is key to national and international success.
Complete the orbital box.
Rawlings Way and Mount Pleasant should be dualled in each direction to help movement around the city to major venues and sites.
City does have a very immature road network for its size- lacked vision and investment over the years.
Remove roundabouts and traffic lights on A63/A1033 route to docks by fly overs and grade separated junctions.
Improve gateways to Hull.
Options
Option A: Policy to include appropriate safeguards to ensure development which feeds into the Classified Road Network does not compromise its function and capacity. The Classified Road Network comprises those key roads as identified on Map 10.1 .
Option B: Do not have a policy safeguarding traffic flows into the Classified Road Network.
Preferred Option
10.20 Option A
Draft Policy 43
Classified Road Network
Development adjacent to the Classified Road Network will: -
take into account the main function of the road as a route for through traffic and the capacity of the road to meet predicted traffic resulting from the development;
include provision of safe and adequate vehicular, cycle and pedestrian access to and from the site;
only allow direct access onto the Classified Road Network as shown on Map 10.1 where it does not restrict the capacity of the road or its intended purpose. Where a reasonable alternative exists, direct access will not be permitted.
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any junction or capacity improvements shall be completed before the occupation of the development; and
avoid direct access with the A63/A1033 strategic road, unless a workable solution can be found.
Justification
10.21 The Classified Road Network in the current Local Plan no longer reflects the latest functions and capacities of main roads within the city and therefore needs updating.
New roads and road improvements
10.22 Building new roads or widening existing roads to cater for more traffic is not always a realistic solution to transport problems. Schemes increasing road capacity for traffic in general often lead to an increase in traffic and pollution. In addition, they sometimes disrupt communities and damage the local environment. However, some road schemes are necessary in order to bring wider benefits to the community. For example, schemes removing through traffic from congested roads, will improve conditions for local users and possibly enable the introduction of priority measures for public transport and cyclists. However this needs to be balanced with the need to effectively connect people and places.
10.23 The impact of road schemes on people and the built and natural environment can be minimised by careful routing and good design, including appropriate landscaping. Road safety and the needs of public transport, cyclists and pedestrians should be major consideration in road scheme design. This is particularly important in Hull as evidence shows that in England, children living in the 10% most deprived wards are four times more likely to be hit by a car than children in the 10% least deprived wards.
10.24 NPPF states that local planning authorities should identify and protect, where there is robust evidence, sites and routes which could be critical in developing infrastructure to widen transport choice. The A63 Castle Street Road Improvement Scheme will help to reduce congestion as well as improve access to the port and connectivity between the city centre and waterfront area. In fact transport schemes can have a potentially positive impact in sustainable terms. The A63 improvement scheme is expected in the long term to reduce air pollution, and the provision of any footbridge, new walkways and cycleways should help promote healthier lifestyles.
10.25 The A63 improvement scheme is being promoted by Highways England. The scheme includes plans for the grade separation of Mytongate junction (A63/ A1079). It seeks to improve access to the docks, relieve congestion,
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improve safety and reduce severance between the city centre and the waterfront area. The Department of Transport has stated that they will fund the A63 Castle Street Improvement Scheme subject to the development consent order being approved and the scheme still being ‘value for money’. Highways England is working to finalise the development consent order application and will submit it as soon as further necessary traffic and environmental assessments have been completed. It expects to start construction in 2016/2017 and complete in approximately 4 years. Garrison Road roundabout is currently operating close to capacity, and that the capacity of this roundabout is to be upgraded by Highways England as a complementary scheme to the major A63 scheme.
10.26 Until the A63/A1033 scheme is complete, there remains the challenge to manage the heavily congested A63/A1033. In particular, new port-related developments will generate traffic movements along this corridor. The Council and Highways England are monitoring the amount of development that can come forward before highway mitigations/improvements are required.
10.27 Within the city centre, three sides of a dual carriageway orbital box of roads (Castle Street, Ferensway, and Freetown Way) have been constructed which enables the city centre core to be set aside for a pedestrian friendly environment. The current Local Plan (2000) identifies the Great Union Street road improvement scheme to the east of the city centre to complete the orbital box. This is a scheme to complete the eastern leg of the city centre orbital box to help improve vehicular circulation around the city centre. The scheme is identified in the Council's Transport Improvement Programme but has no committed funding and no detailed design has yet been undertaken. In the current funding climate this improvement scheme is unlikely to be progressed in the early plan period although all funding opportunities will be investigated. This improvement scheme is not required to deliver the growth set out in the Local Plan but it would be sensible to identify it within the plan.
10.28 The current Local Plan 2000 also protects the route of the proposed Eastern Relief Road which would help serve as an East Hull bypass. Much of the route lies in the East Riding but a short section linking with Hedon Road runs through open land in East Hull. The East Riding of Yorkshire Local Plan does not protect the Eastern Relief Road route.
10.29 The large investment in off-shore wind technologies by Siemens at Alexandra Dock will have a positive impact on the city, but have implications for transport systems. With regards to the movement of components, it is possible that an internal freight route (either road or rail) could be developed sometime during the plan period via an internal supply chain corridor between the proposed Alexandra Dock and Hedon Haven employment site (East Riding of Yorkshire). Nevertheless, the Council has still identified that improvements will be required at the Northern Gateway roundabout in the city. The Council has also identified the need for road improvement schemes along Stoneferry and Anlaby Roads. An assessment of the impact of East
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Riding Local Plan development raised concerns about the capacity of Southcoates Avenue, Northern Gateway, Marfleet Avenue and Somerden Road junctions with the A1033.
You Told Us
A63 improvement may lead to further pollution.
Support for the A63 Castle Street improvement. However, development should be managed to ensure that non-port related development brought forward in Hull is managed to ensure future developments proposed at the Port of Hull are not held back as a result of existing highway capacity being absorbed.
A63 Castle Street/Siemens development/City of Culture require careful transport management to mitigate disruption to local business.
Improvement of A63 and the building of the footbridge should be top priority.
Develop alternate solution to A63/Castle Street.
A63/Castle Street concerned that cutting could be at risk of flooding.
Extend flyover from Daltry Street to Myton Bridge.
The land required for the Great Union Street improvement scheme should be protected by the Local Plan.
Remove the Great Union Street proposal. The current single lane road is adequate most of time. The widening of the Street would involve the loss of historic features/buildings which would not be not acceptable.
East Riding of Yorkshire Council said the Eastern Relief Road Scheme in its area is not currently being actively pursued. Funding is unlikely to be available. Scheme not identified in ERYC Local Plan and is shown as is in open countryside.
Support protection for Eastern Relief Road, but how realistic?
Support the building of an alternative fast ring road connecting existing roads from Humber Bridge/ A1079/ Kingswood and then a new route through to eastern docks.
Highways England said it will work closely with the Council to understand traffic implications of development options for the city centre. This will include an assessment of the ability of the road links and junctions to take the forecast traffic flows in terms of both safety and capacity.
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Options
Option A: The Local Plan to have a new road schemes policy to provide design guidance and to protect new road or road improvement schemes such as the A63 Castle Street scheme from other development. This policy would be NPPF compliant.
New roads and road widening:
A63/A1033 Castle Street Improvement Scheme;
Great Union Street (Eastern Orbital);
Eastern Relief Road (majority outside city);
Eastern Corridor (internal road/rail scheme);
Anlaby Road (near hospital);
Junction improvements:
Garrison Road;
Southcoates Avenue;
Northern Gateway;
Stoneferry Road;
Spring Bank West/Calvert Lane;
Marfleet Avenue; and
Somerden Road.
Option B: Option A but to exclude any new road or road improvement schemes where delivery may be uncertain.
Preferred Option
10.30 Option B
Draft Policy 44
New roads and road improvements
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New road schemes will be generally supported if they:
improve road safety; improve the environment; assist public transport or cyclists; improve accessibility including to employment areas; open up land for agreed development; and reduce congestion/pollution and improve air quality.
Designing road schemes will take into account the :
safe and efficient movement of vehicles; impact on the built environment, in particular listed buildings and conservation areas; impact on the natural environment, in particular on local designated areas; impact on housing amenity; needs of businesses; needs of public transport, cyclists and pedestrians; and need for landscaping.
Protected major new roads and road widening schemes are shown on the Policies Map and are:
A63/A1033 Castle Street Improvement Scheme; Great Union Street (Eastern Orbital)
Eastern Corridor (internal road/rail scheme)
Other road improvement schemes (eg junctions) are:
Garrison Road; Southcoates Avenue;
Northern Gateway;
Stoneferry Road;
Spring Bank West/Calvert Lane;
Marfleet Avenue; and
Somerden Road.
Land required for these schemes will be protected from other development.
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Justification
10.31 Although their delivery is currently uncertain there is justification to protect the proposed routes of The Great Union Street and Eastern Corridor new road schemes in the Local Plan until such time as their future can be confirmed. Given that East Riding has not allocated the Eastern Relief Road in its local plan this should be removed as incapable of delivery.
New parking sites
Park and Ride sites
10.32 Park and ride is a means of overcoming city centre and possibly port parking and traffic flow problems and relieving traffic congestion with associated air pollution problems. The Local Transport Plan aims to provide secure public car parking on further park and ride sites around the city, with connecting public transport services into the city centre assisted by bus priority measures. In particular, this offers an alternative to long-stay parking in the city centre.
10.33 The current Hull Local Plan adopted in 2000 protected an existing park and ride site off Walton Street (west Hull) and proposed new sites off Thomas Clarkson Way (north Hull), Priory Park (west Hull), and Brighton Street. There is now a park and ride interchange at Priory Park to the west of the city. It is a purpose built site with 581 spaces and 120 overflow spaces available on an unused lorry park area. Priory Park is commercially operated by Stagecoach and is well used but still only generates a relatively small intercept rate from the high volumes of traffic entering Hull. The Walton Street park and ride facility has closed and Brighton Street has been redeveloped.
10.34 The Council has strong aspirations for new park and ride sites to be provided to the north and east of the city. Current attention is on sites just outside the Hull boundary within neighbouring East Riding of Yorkshire at Dunswell roundabout and on Hedon Road. Favourable consideration would also be given to alternative sites within Hull should they emerge during the plan period. To the east of the city a new facility is proposed on Associated British Ports land(Saltend) and is included as part of the East Riding Local Plan allocation HAV-A to cater for the expansion of the Port of Hull at Hedon Haven and to mitigate the impact of additional traffic generated by the development. This park and ride site is likely to provide around 300 to 400 car parking spaces and is included in this Council's LTP.
10.35 The provision of a park and ride site to the north of the City is also included in the current LTP. However the size and location of the site is not specifically mentioned. There is now an aspiration between Hull and East Riding Councils to create a new park and ride facility to the north of the City on land just outside the city in between the A1079 and A1033 at Dunswell
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Roundabout. This scheme is currently scheduled to be progressed after the delivery of the eastern park and ride site and replaces the previous Thomas Clarkson Way proposal.
You Told Us
The East Riding Local Plan identifies sites to the north and east of Hull for park and ride facilities. East Hull park and ride should not have impact upon existing services to Hedon and nearby area and must be convenient. Should have East Hull park and ride sites at Preston Lane crossing on an extended rail line and also one one at Saltend to utilise the existing rail link. One may be enough at least to begin with but eventually both may be necessary. Support for proposed eastern and northern park and ride sites. Also support for a park and ride site between Cottingham and Willerby and other sites within Hull.
Options
Option A: The favoured locations for new park and ride sites in north and east Hull are outside the city and therefore fall outside the scope of the new Hull Local Plan. So therefore just have a policy supporting provision of park and ride sites and safeguarding of the Priory Park site.
Option B: During the Local Plan period other/alternative park and ride sites may be identified and which could possibly be located within the city. It would therefore be helpful to include guidance on the design of such facilities as well as safeguarding the Priory Park site.
Option C: Identify on the Policies Map park and ride facilities to the north and east of the city and confirming these will be provided in the East Riding of Yorkshire Council area.
Preferred Option
10.36 Option B
Draft Policy 45
Park and Ride
In the event that a park and ride site is proposed within the city then it will be expected for the site to be:
sustainably located to ensure its effective operation;
adjacent to a major radial approach route;
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safe and easy to access and include a sustainable drainage system;
include sufficient car parking for persons with disabilities, cycle parking and facilities for buses, taxis and coaches, where appropriate;
supported by a transport assessment; and
incorporate suitable signage and traffic management measures to reduce potential conflicts.
The provision of park and side sites to serve the east and north of Hull will be supported.
The existing Priory Park Park and Ride site serving west Hull will be safeguarded in order to protect it from inappropriate development.
Justification
10.37 Option B covers all eventualities as to the future provision of park and ride sites in and around Hull. Option C is not appropriate as delivery of these schemes cannot be enabled through the Hull Local Plan.
Lorry and coach parks
10.38 Hull’s economic role, particularly as a port, means that lorries sometimes need to stop overnight in the city. A lorry park was designated in the current Local Plan 2000 on a main traffic route in an employment area at Brighton Street (Hessle Road), to avoid undesirable long-stay parking in housing areas. An alternative site for a lorry park was later found as part of the Priory Park park and ride facility but had to close for commercial reasons. There may possibly be a need for a lorry park in east Hull near to the docks but further investigation is required.
10.39 The City Centre is an increasingly popular destination for coaches bringing visitors for shopping and leisure trips. Many visitors are expected to come to the city centre when the city becomes UK City of Culture in 2017. The City Centre coach park at Waterhouse Lane is well placed for the main tourist attractions and was identified by the current Hull Local Plan. Should this site be affected by redevelopment proposals then a suitable replacement facility for coaches needs to be considered. A suitable long-term replacement coach park site has been identified at Tower Street.
You Told Us
Highways England would like to be kept informed of any proposals for a new lorry parking site to ensure that the impact on the strategic road network (A63) is taken into account. There is a need for a coach park in the city centre.
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Support for new lorry and coach parks provided they have appropriate facilities. Priory Park lorry park should be reopened. Coach park needed in city centre. A very attractive coach park drop off point should be provided. Against a lorry park but a coach park could potentially be provided on Kingston Retail Park or in the Fruit Market.
Options
Option A: Include a policy encouraging the provision of lorry and coach parking at suitable locations but do not safeguard sites.
Option B: Same as option A but also safeguard existing lorry and coach parking sites.
Preferred Option
10.40 Option B
Draft Policy 46
Lorry and coach parks
The provision of lorry and coach park sites will be supported.
The designated lorry park area within the Priory Park Park and Ride site will be protected from other development, unless a replacement facility is provided in a location of at least equal benefit.
The City Centre coach park at Waterhouse Lane will be protected from other development, unless a replacement facility is provided in a location of at least equal benefit. A suitable long-term replacement coach park site has been identified at Tower Street.
Justification
10.41 There is evidence supporting the safeguarding of lorry and coach parking sites. A site at Tower Street offers a suitable replacement for the existing Waterhouse Lane coach park site should this site be redeveloped during the Local Plan period.
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City Centre Car Parking
10.42 City centre car parks have changed considerably since they were identified in the current Local Plan (2000). Some sites have been built on and there are now more privately operated car parks. The Local Plan needs to ensure that enough car parking spaces of the right type are provided in the city centre and if there should be replacement provision where spaces are lost to development.
10.43 Car parking in suitable amounts and locations is vital for the city centre to function properly. A balance is necessary between car parking and other transport modes and between the needs of short-stay and long-stay parking users. This is important so that different types of visitor can gain access to the city centre. The Council provides a large amount of public parking. The City Council therefore has some influence over the supply of car parking in the city centre. There are also car parks provided by private operators. The number of public long-stay spaces here includes publicly and privately owned long-stay surface car parks and multi-storey car parks.
10.44 There are concerns over air quality in the city. A large part of the city centre is designated an Air Quality Management Area. The most significant cause of air pollution locally is vehicle exhaust emissions. Scientific research has indicated that poor air quality is a major cause of serious health problems and fatalities. There are also implications for new road schemes. There is concern over the potential increase in air pollution that a new road scheme might generate.
10.45 Reducing vehicle numbers and congestion can contribute to reducing exhaust emissions or the effects thereof. Measures to disincentivise car usage have to be carefully considered and need to take account of the differing needs of both motorists, workers and businesses. Some workers need their cars to travel between different work locations during the working day. Shoppers sometimes need their cars to transport their shopping, particularly bulky items.
10.46 Of all car users it is the daily commuters who drive into the city centre in the morning peak, park all day and then drive home in the evening peak, causing traffic congestion and significant emissions, who the Council considers should be persuaded to find alternative means of travel. The city centre is well served by public transport as an alternative. It is felt that discouraging car commuter travel can best be achieved by reducing the number of long stay car parking spaces in the city centre (both Council and privately operated) and through controlling new car park developments to short stay spaces provision only. The current Local Plan identifies 4,000 long-stay off street public car parking spaces in the city centre.
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10.47 Hull must compete as a shopping and leisure attraction with other towns and cities, and with out-of town retail developments. An appropriate supply of short-stay car parking spaces for shoppers in the city centre is therefore needed to assist its vitality and viability by attracting customers.
10.48 Permanent short stay car parks need to be protected from development to provide an adequate supply of public car parking and to assist the prosperity of the City Centre. If any of these car parks are considered for development it is important that they are replaced either on site, or in a location of at least equal benefit to users, and that the provision of short stay spaces remains at the current level.
10.49 Undercroft car parking can be an efficient use of space in a city centre and can help to reduce the demand for on-street car parking spaces. However its provision can affect the viability of a development as it is expensive to provide and undercroft car parking can also prevent the ground floor from having uses that provide for a lively frontage.
You Told Us
City has plenty of cheap and underutilised car parking. Support for a review of city centre car parks to be undertaken.
Development of city centre will require additional surface and potentially multi-storey car parks. Encourage greater use by cheap fees on less popular car parks. Multi-storey car parks unattractive, outdated. New generation of multi-storey car parks required. Monitor car parking provision during plan period.
Car parking review needed if new venues arrive i.e. Arena and Fruit Market . Visitors can feel unwelcome in the city mainly because of the heavy volumes of traffic which makes barriers for pedestrians. The city needs to be people friendly.
Options
Option A: This would protect the Council’s city centre car parks and would retain the mix of long-term and short term car park spaces as currently provided.
Option B: To encourage more environmentally friendly forms of sustainable transport in the city centre and thereby lessen air pollution by reducing the number of long-term car park spaces as currently provided. Proposed that maximum level of 4000 protected long stay spaces be reduced to 3500 and that the policy includes design standards for new car parks and supports the provision of short stay car parks.
Option C: To support short stay car parking to assist shopping and leisure needs.
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Preferred Option
10.50 Option B
Draft Policy 47
City Centre car parking
Long-stay off-street public car parking in the City Centre, as identified on the Policies Map, will be restricted to a maximum of 3500 spaces. Such car parking spaces will be protected from other development where it would result in the total number of long-term spaces falling below the level of 2750 spaces.
The provision of new short-stay off-street public car parking within the City Centre or in edge of City Centre locations will be supported subject to condition that they remain available for short stay parking only. Proposals for new long stay car parks in the City Centre or in edge of City Centre locations will be discouraged.
Development on a permanent short stay public car park in the City Centre will only be allowed if the same number of short stay public car parking spaces are provided either on site, or in a location or form of at least equal benefit to users of the City Centre. Parking for the development itself must comply with parking standards as appropriate.
All new car parks, including undercrofts, should ,where possible, meet these criteria :
the perimeter should have a clearly defined boundary;
vehicular and pedestrian accesses and exit routes should be kept to a minimum;
cycle/motorcycle parking should be provided;
respect the scale of buildings around them; give careful consideration to layout and pedestrian access; be naturally well lit; have good artificial lighting levels when required; incorporate a sustainable drainage system; provide wider spaces for people with restricted mobility; have good quality surface treatment (eg tarmacked); demonstrate that the facilities will be well managed and maintained; signage within the parking facility must be clearly visible; and design must aid surveillance and the smooth passage of traffic and ensure customer and staff safety.
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The incorporation of measures in new car parks to help reduce air pollution will be supported. These could include tree planting and the use of pollution absorbent materials.
Justification
10.51 Providing long-stay parking for commuters in the City Centre encourages travel to work by car, causing peak-hour congestion, and environmental problems such as air pollution. Reducing long-stay provision as supported by Option B would help to resolve these problems and contribute towards improving pollution levels within the Air Quality Management Area.
Car parking standards
10.52 Previous national planning policy guidance (PPG13) advocated the use of policies in development plans to set levels of parking for broad classes of development. The National Planning Policy Framework(NPPF) does not have such a direction. Instead it sets out a range of issues that should be taken into account for setting local parking standards. NPPF states that setting local parking standards for residential and non-residential development, local planning authorities should take into account:
the accessibility of the development; the type, mix and use of development; the availability of and opportunities for public transport; local car ownership levels; and an overall need to reduce the use of high-emission vehicles.
10.53 With regard to setting maximum parking standards, Planning Policy Guidance which supports the NPPF, states that these can lead to poor quality development and congested streets. Local planning authorities should seek to ensure parking provision is appropriate to the needs of the development. A recent ministerial written statement says that local planning authorities should only impose local parking standards for residential and non-residential development where there is clear and compelling justification that they are necessary to manage their local road network. The Minister's justification for this policy is that maximum parking standards " lead to blocked and congested streets and pavement blocking" and "too many local authorities are continuing to impose maximum standards for parking provision on new developments,despite these being abolished in 2011".
10.54 Parking standards for development in Hull are set down in Table M1 of the current Hull Local Plan adopted in 2000 and primarily supported by policies M30 to M33 and CC18 and CC19. They include car and other motor vehicle, disabled and cycle parking standards, and are minimum ones only, and are intended as general guidance for new development and changes of use. The amount of parking to be provided depends on the:
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type of development, redevelopment, or change of use proposed; availability of land for parking within the site and in the general locality; traffic generated by the proposed use, road capacity for parked vehicles and moving traffic, and road safety; availability of existing parking and public transport; and local transport plan policy; proximity to local services.
10.55 The standards are therefore applied with some flexibility to take account of various factors as now required by the NPPF. The motor vehicle parking standards apply citywide except for non-housing development in the city centre where policy M31(a) applies. The standards do not include provision for the servicing of development and have been modified to reflect current use classes. Developers should provide sufficient space for service vehicles off-street, in addition to car parking. The standards also apply in the city's area action plan areas and appear in the Council's Highway Design Guide for New Developments. In May 2008 the Yorkshire and Humber Regional Spatial Strategy introduced some new maximum parking standards for non-residential developments in the region. However these were withdrawn in September 2013 when the RSS was revoked.
10.56 The main principles behind the current Local Plan's parking standards are as follows:
it is important that appropriate parking standards are applied at all developments. the standards are minimum ones. development should provide adequate parking and servicing off-street to prevent on-street new parking and loading problems from arising on-street. for residential uses, a minimum of one car parking space should be provided for each 1-bedroom dwelling or two car parking spaces for each dwelling of 2 or more bedrooms, in addition to 0.25 spaces per dwelling for visitors. Changing the use of older property, for example to housing in inner areas or to shops, pubs or offices on radial roads, may have difficulty meeting these standards owing to lack of access or insufficient space within the curtilage. Some flexibility may be allowed in parking requirements if there are strong reasons for allowing development.
development of employment premises and places with public access, including shopping, recreation, health and education uses, should provide parking for the disabled as set in the standards schedule. cycle parking will be required for all developments. Providing parking facilities for cyclists increases the accessibility of development and reduces the need for car use. Development should provide cycle parking meeting the standards set out in the schedule. Journeys by cycle as an alternative means of transport to the car can be encouraged by providing cycle parking. The availability of more parking facilities for
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cyclists, in shopping centres and community facilities for instance, can encourage the use of cycles instead of cars for local journeys. It is important that cycle parking is safe, secure and convenient for cyclists. motorcycles, mopeds and scooters instead of cars can assist in reducing traffic congestion, as they need little road space or parking space. Although there may be some noise problems, the environmental impact of motorcycles is generally less than private cars. The safe and responsible use of motorcycles can be encouraged by providing secure and convenient parking for users. City Centre - commercial use - is often not practical for this development to provide on-site car parking as required because of insufficient space. Furthermore, providing additional spaces for employees encourages travel to work by car which increases peak-hour congestion in the City. In general, commuter parking is best concentrated in nearby car parks or park and ride sites. However, a minimum level of operational parking to meet the working needs of businesses should be provided. City Centre - residential - it is sometimes difficult to provide the same amount of parking for housing in the city centre as elsewhere in the City. In order to encourage housing development in the city centre these standards are applied flexibly because of space constraints in the area and where there is a high level of access to services. Housing development in the city centre should provide off-street parking. However, this may be difficult to achieve in converting older property to housing use, and some flexibility may be allowed in such cases.
10.57 The current Local Plan parking standards have provided a useful basis for guiding parking space provision in new developments. However they are considered to be not fully compliant with NPPF guidance. The NPPF requires full consideration of factors such as: accessibility of development; local car ownership levels; and the need to reduce the use of high-emission vehicles. The NPPF advises authorities to consider parking provision on an individual development basis mindful of local circumstances and traffic generation. The current Local Plan's approach is to apply citywide standards to all developments and then consider if flexibility should be applied on the basis of local circumstances . It is also evident that the current car parking standards and guidance used are no longer applicable in certain contexts and therefore need reviewing and updating.
10.58 Business type standards appear to be no longer appropriate. They are based on floorspace areas rather than individual traffic levels generated by individual businesses. In some instances, it has been found that the issue of parking provision is more to do with location of spaces rather than the number provided where for example there is a preference to park outside homes rather than in designated spaces often found at the rear of property. Parking in this way is considered to be more convenient and offers passive surveillance but can lead to traffic flow problems and the need for traffic regulation orders. Problems have arisen where parking standards are initially applied too flexibly for retail and business park developments leading
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later to on-street parking issues. Including a garage as a space has also caused congestion in housing areas where typically the garage is used for storage meaning external space does not often meet the 1 or 2 space requirement. The calculation behind the parking standard for houses in multiple occupation has led to the need for half spaces which is unworkable and really needs rounding off to the nearest higher whole figure (ie1.5 rounded off to 2). In addition to the city centre there are possibly other areas of the city that because of their physical constraints could benefit from a more flexible application of parking standards.
You Told U
Parking both in terms of affordability and availability are along with good public transport a factor in making an area attractive.
Options
Option A: Have no local parking standards/guidelines. Proposals would be dealt with on an individual basis based on development type and local circumstances.
Option B: Have local standards and apply them rigidly. Both decision-makers and applicants would be clear as to what would be required. But this option would be contrary to NPPF.
Option C: Include advisory local guidance only but have no local specific parking standards. This option would be in line with NPPF but the lack of any sort of standard to work with would be unhelpful to both decision-makers and applicants.
Option D: Have revised local parking standards with guidelines as proposed in Table 10.2. In accordance with the NPPF, a flexible approach would be applied and would encourage the use of more sustainable modes of transport.
Preferred Option
10.59 Option D
Draft Policy 48
Car parking standards
The Council will refer developers to the revised parking standards and guidelines as proposed in Table 10.2. Where possible, schemes should comply with the standards for uses and transport modes specified. The standards will be applied with some flexibility to take account of these factors:
the accessibility of the development; the type, mix and use of development; the availability of and opportunities for public transport;
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local car ownership levels; and an overall need to reduce the use of high-emission vehicles.
Justification
10.60 Option D aligns with NPPF and by including standards and guidance would be helpful to decision-makers and applicants in consideration of parking provision for new developments. Option A would likely lead to inconsistent decisions. Both decision-makers and applicants would prefer having standards and guidance available. Option B would be unrealistic as there are many areas where physical site constraints prevent developments meeting a citywide standard and this would be contrary to NPPF.
Bus transport
10.61 Hull’s bus infrastructure is generally fit for purpose particularly with the Paragon Interchange in operation, which opened in September 2007. The majority of bus services which operate in the City are provided by Stagecoach and East Yorkshire Motor Services. There are bus lanes on sections of the radial routes into the city centre and a real time system is being installed (it is already operational on several routes). There are very frequent daytime services along radial road corridors to and from the city centre. However, buses are delayed by traffic congestion on radial roads and they are often hindered by indiscriminate parking. The problem has been alleviated to some extent by providing bus lanes. The Council intends to take enforcement action against drivers who wrongly drive in bus lanes.
10.62 Public transport by bus is generally the most efficient way of moving large numbers of people in built-up areas, particularly along transport corridors and into central areas. It is accessible to most people and essential for the majority who do not have a car available. Buses give local people access to work, education, shopping, health, community, recreation and leisure facilities.
10.63 Buses are more efficient users of road space than cars. If car users can be persuaded to travel by public transport, then both congestion and pollution would be reduced. In addition, the Priory Park park and ride facility offers secure parking for motorists and a rapid journey into the city centre. The design of public transport facilities should consider the safety and needs of both users and non-users.
10.64 The Paragon Interchange is operating close to capacity during peak hours (in terms of passengers queuing), and space at the bus station may need to be reconfigured to meet extra demand. A number of improvements to
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bus operations across the city are being considered, including the creation of mini-district interchanges at district centres around the city such as at North Point and Kingswood district centres.
You Told Us
East Riding of Yorkshire Council said that the City’s road infrastructure is linked to the East Riding road network. There are also significant cross-boundary bus and rail links, and to a lesser extent links by water. It is important the role of key bus corridors connecting the East Riding and Hull, such as routes to Beverley, Withernsea, Cottingham, and Hessle are recognised as well as the potential role of public transport in serving large new developments such Green Port. Councils to continue partnership working with bus companies. Smaller low emissions buses should be introduced for some routes. We should support our local bus, rail and taxi operators. Invest and plan for an integrated public transport system to match other European cities i.e Nice.
Options
Option A: Include a broad policy supporting the provision of new and improved bus facilities and measures to give priority to bus transport provision.
Option B: Provide a more specific policy than suggested by Option A focusing on: park and ride facilities; bus lanes; Paragon Interchange; the need to safeguard potential new mini bus station sites; and providing more real time bus information facilities.
Preferred Option
10.65 Option B
Draft Policy 49
Bus transport
Improving bus services and facilities will be encouraged including:
providing public transport priority schemes, such as bus lanes; improving bus passenger facilities including realtime information, for example at bus stops and park and ride sites; ensuring that bus transport schemes are designed to take into account road safety and the needs of the mobility impaired, pedestrians, cyclists, residents and businesses; and further improvements to the city centre Paragon public transport interchange.
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Proposed bus transport schemes will be identified on the Policies Map and potentially are:
new mini bus station interchanges (possibly at North Point and/or Kingswood district centres).
Land required for these proposals will be protected from other development.
Justification
10.66 Bus transport is one of the most sustainable modes of transport. Every effort should be made by the Local Plan to improve the bus transport provision in the city. Option B seeks to achieve this by detailing what should be supported.
Rail transport
Main passenger train line
10.67 Passenger rail services link Hull to the East Coast mainline at Doncaster and York, the major northern cities of Sheffield, Leeds and Manchester, and the coastal resorts of Bridlington and Scarborough. The Hull Paragon Interchange is well located in the City Centre to its main shopping and commercial areas. The main passenger rail route into the City Centre runs east-west providing links to Leeds, Manchester, Doncaster, Sheffield, and York. There are a number of constraints associated with this line including slow journey times, infrequent services and poor reliability. Whilst being the longest straight line track in the country, the speeds achieved are relatively slow due to the out of date track, rolling stock and signals.
10.68 The Council is supportive of electrification of this passenger train line between the East Coast Mainline and Hull (via Selby). This would offer journey time savings, allow use of newer rolling stock to be used, create environmental benefits and enhance the number of services along the line, due to the removal of the current requirement for manually operated crossings and signals along the route. The scheme also links well with wider planned North Transpennine electrification between Liverpool and Selby and would allow electrified trains to travel along the network without the need to change between electric and diesel trains.
Railway stations (halts)
10.69 The current Local Plan 2000 safeguards proposed railway stations (halts) in the Bricknell Avenue area between Hull and Cottingham on the line into Hull from the north and at Priory Park on the main line into the City from the west. The Local Transport Plan selects these two locations and recently
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a further potential rail station site has emerged on the main line near KC Stadium replacing an earlier proposal for reopening of the former halt at Boothferry Park.
10.70 A preliminary feasibility study informing the LTP concluded that there were no show-stopping technical reasons why halts could not be provided but it found no strong business case at the time. The LTP concluded that the business case may be reviewed in the longer term as the economic situation changes. Currently there is no committed funding for these schemes and they are unlikely to be progressed up to 2030 but they may be considered in the longer term.
You Told Us
Support in principle for the proposed new stations subject to journey times. Concerned protection would not hold. Bricknell halt must be built now, plus halts at Priory Park and Boothferry Park. KC Stadium halt may not be necessary as good bus service in area. Concerned of a lack of East Hull halts identified, using high level line. Intermediate halts needed at Chanterlands Ave, Newland Ave, Beverley Rd/Fitzroy St, James Reckitt Ave, Holderness Road and Southcoates Fields plus a ferry stop at the dock plus a junction at Littlefair Road extending the line eastwards through re-opened Marfleet and on towards Hedon. Proposed railway stations might be desirable. Much support for protection of Priory Park/KC Stadium/Bricknell Avenue sites as could lead to provision of useful transport facilities. Delete Boothferry Park proposal as bus service adequate. Support for KC Stadium and Priory Park halts. Not sure of value of Bricknell Avenue site. Electrification of the rail line to Hull must materialise. Investigate Hull light rail/metro system. The introduction of cost effective cross city trams using old rail line beds and the existing wide boulevard arterial roads would bring a European distinctive feel and sophistication.
Rail Freight
10.71 Freight movements are significant in Hull, as the city is a major UK port and an important industrial area.
10.72 The impact of lorries on the environment can be reduced by encouraging more freight, particularly bulky goods, to be carried by rail. The City’s industrial areas are mostly located along railway corridors and there is some potential for greater use of this mode of transport.
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10.73 In particular, the role of the high level railway (Hull Docks Branch) as a freight route for port traffic could possibly be expanded to help relieve congestion on the city’s main roads. King George Dock is served by the freight-only high level railway, which continues to the Saltend complex but its elevated nature limits its opportunities to access additional industrial sites. However, there is an existing corridor available within the Port of Hull estate to give freight rail access to development on land east of Saltend beyond the city boundary. The current Hull Local Plan safeguards this potential freight rail route from Hedon Haven / Paull to Alexandra Dock. In addition, there is potential to provide another internal freight route (either road or rail) via an alternative corridor which would link the Port of Hull and Hedon Haven employment sites. Both potential freight routes are shown on the Policies Map.
10.74 The rail freight line loops around the north of the city centre and then terminates in the port, and is predominately used for transporting coal and biomass. There is capacity on this line for 22 freight trains per day in each direction. The actual level of use does not currently reach 22 and there is the opportunity to increase the number of freight services using this section of track. The potential for the rail freight network in Hull and capability at the Port of Hull to accommodate the high cube containers that predominate in the world market represents a key opportunity. Further work is required to determine the accurate costs of upgrading the network to resolve any issues in terms of gauge clearance. The requirement to upgrade rail freight services, including full gauge clearance is a long term Council aspiration which could be delivered within the plan period.
10.75 In order to deliver capacity improvements and electrification through to the Port it would be necessary to replace/repair/strengthen the moving bridge over the River Hull (currently only used by freight). However, this scheme is not currently required in the plan period.
You Told Us
ABP requested that the potential freight line at Queen Elizabeth Dock is deleted from evidence map and replaced with policy wording to support proposed road (and potentially rail) link – for flexibility. The East Riding Local Plan identifies extension for potential road and/or rail frieght route. Given the potential increase in road traffic as a result of the proposed new development at Saltend, Historic England says the Plan should safeguard the potential route of the freight line to Hedon Havento reduce the number of vehicle movements on the A63. Support to protect route of proposed rail freight line to ensure growth of local economy and docks. Rail link should extend to the other plants at Paull so that the large items made there are transported by rail, not road to Siemens site. The freight line is ground level from Belmont Street so could serve businesses from there. The line needs to be doubled for its full length.
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Retain all transport options to allow expanding development. There is an urgent need to review how goods within the docks are transported to the rail service and to assess the potential for the freight network to be upgraded so as to accommodate the high cube containers that predominate in the world markets. In view of the likely increase in traffic along the A63 that is likely to result from the Green Port Hull development at Alexandra Dock and, potentially, the 205 hectares of additional employment land at Hedon Haven in the East Riding, the plan needs to consider how it can facilitate increasing the amount of freight that is transported to and from the port by rail.
Options
Option A: Include a broad policy supporting development proposals which promote rail transport as a sustainable mode of travel.
Option B: Same as Option A but include mention of all rail transport schemes and to safeguard them from other development where necessary.
Option C: To have no policy on rail transport.
Preferred Option
10.76 Option B
Draft Policy 50
Rail transport
Developments in Hull associated with the electrification of the main passenger train line between the East Coast mainline and Hull will be supported.
Development proposals will be welcomed which bring about the improvement of the existing railway station and facilities or bring about some other improvement which will be beneficial to the operation of the line.
Retaining and improving Hull’s rail services and facilities will be encouraged. Development detrimental to the future of the rail system will be resisted.
Rail station improvements must provide in accordance with Department of Transport best practice guidance:
safe and convenient movement to and between platforms; and include other facilities, such as sheltered waiting and ticketing facilities, cycle parking, appropriate car parking, public transport information and sensitive lighting and landscaping.
Moving freight by rail will be supported, in particular by encouraging:
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potential users to locate at suitable sites; and the provision of rail freight handling facilities.
Existing rail freight facilities will be protected from other development unless a suitable replacement facility can be identified.
The potential freight lines from Hedon Haven/ Paull to the Port of Hull and as shown on the Policies Map will be protected for freight transport purposes.
Justification
10.77 Rail transport should be supported as it is a sustainable mode of transport. However the means of delivering the rail stations remains extremely uncertain. The preferred option is therefore A.
Water transport
Port of Hull
10.78 Hull is a major European port and there is potential to increase shipping traffic over the plan period. Passenger traffic is likely to increase in the next few years due to the continued growth in the cruise ship market.
10.79 The Port of Hull is based around three dock systems: the Albert/ William Wright; Alexandra; and King George/ Queen Elizabeth Docks which are owned by the Associated British Ports (ABP). Currently these docks cover approximately 3,000 acres of land and handle approximately 10 million tonnes of goods each year. The port contains the facilities and infrastructure to accommodate a range of products including:containers, dry bulks (eg agribulks, animal feed, cement, chemicals, coal, biomass, cocoa, salt, and grain);paper and forest products; fresh produce and perishables, general cargo; liquid bulks (eg edible oils, petroleum-based and chemical products); RoRo, passengers and cruises; and offshore wind turbines assembly, manufacture, and shipment.
You Told Us
The Local Plan should identify proposals for: cruise terminal/Albert Dock; bulk terminals/Queen Elizabeth Dock; river terminal/King George Dock; and river terminal/Queen Elizabeth Dock. Any new berthing proposals should be subject to environmental and operational safeguards. An imaginatively designed cruise liner terminal would be attractive to operators and tourists. Retention of P&O ferries to Rotterdam and Zeebrugge are vital. Ferry terminal dependent upon increased local offer.
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River Hull
10.80 The impact of lorries on the environment can be reduced by encouraging more freight, particularly bulky goods, to be carried by rail and also water. The city’s industrial areas are mostly located along railway and waterway corridors.
10.81 The River Hull has potential for greater use as a transport corridor, providing new freight facilities and possibly passenger services. It is well placed to take advantage of the wider network of navigable inland waterways. A joint masterplan for the River Hull is being developed with the Environment Agency, balancing the River’s development opportunities with managing its flood risk.
You Told Us
East Riding of Yorkshire Council supports in principle the greater use of the River hull as a transport corridor but requires assurances over potential impact on existing uses not being compromised. Environment Agency commented that any increased transport flow needs to work harmoniously with the necessary operation of the Hull tidal surge barrier. We need to ensure that any increase in transportation along the River Hull does not impact upon the ability to raise flood defences. Therefore, any associated businesses setting up in this location to link in with the transport must be aware of the impact the defence height could have upon their operational requirements. Support greater use of River Hull if demand and diversification is commercially viable. River may require dredging. There are potential renewables maintenance opportunities. The Plan must protect the banks from inappropriate development i.e. that which will not utilise the River for commercial benefit. The Seimens development may lead to the revival of dry docks, maritime support and other related businesses both during the construction phase and after commencement of operations because of the vessels that will be needed and which will need support and maintenance. Dredge River Hull effectively. Landowners should be encouraged by the Council to repair banks to River. Scott Street Bridge – renovate for cycle/pedestrian use. Potential for impoundment/constant River level including locks. River taxis from the north of the City should be introduced.
Options
Option A: Include a broad policy encouraging development proposals in connection with water transport as a sustainable mode of transport.
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Option B: Provide a more specific policy to Option A encouraging greater water transport usage and the identification of water-related development sites.
Option C: Have no policy regarding water transport.
Preferred Option
10.82 Option B
Draft Policy 51
Water transport
Moving freight and people by water using the Port of Hull and the River Hull will be supported, in particular by encouraging:
potential users to locate at suitable sites; provision of water freight handling facilities; and provision of a new cruise terminal at The Deep or Albert Dock
Proposals for major employment development within the Port of Hull and the cruise terminal are shown on the Policies Map.
Justification
10.83 The Port of Hull has a pivotal role to play in Hull’s future economic growth. It would therefore be beneficial if major future employment proposals such as at the Port of Hull can be promoted and safeguarded by the Local Plan.
Walking and Cycling
10.84 To create healthier lifestyles, residents are being encouraged to walk and cycle more. Walking is an important mode of transport in Hull due largely to the flat topography, low car ownership and the compact nature of the city. The LTP recognises that to increase the proportion of people walking a number of improvements need to be addressed, including more facilities and walking infrastructure. Hull has one of the highest levels of cycling in the UK. The cycle infrastructure is good and the LTP notes that the apparent success in holding up usage levels is largely as a result of the ongoing development of a usable cycle network.
10.85 Cycling and walking are non-polluting and healthier and often quicker and more convenient for short journeys than travel by car. They are the only means of transport available for many people, and everyone is a pedestrian at some point in their journey. However, traffic conditions discourage many people from cycling or walking. There is a network of cycle and pedestrian
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routes across the City. It includes cycle tracks and footpaths on green corridors along drains and former railways, which also provide recreational links to the surrounding countryside. The network forms part of long distance routes, such as the Trans-Pennine Trail. In addition, short local links are provided, for example, between housing areas, schools and shops. Existing cycle tracks and footpaths should be protected from other development.
10.86 Studies show that an active city, where its population walks and cycles more, will be healthier, wealthier, greener and more cohesive, and its people will be happier. Planning cities to be active by encouraging more walking and cycling can has economic benefits. Everyone does better when people move more. Making places better for walking can boost footfall and increase trading and the number of visitors . It has been found that the economic impact of cyclists is almost nine times as much as the one-time expenditure of public funds used to construct special cycle facilities.
10.87 The Council has and is continuing to develop a network of safe and accessible cycle and pedestrian routes, principally to connect residential areas with employment areas and retail areas as well as other facilities and services. The use of cycle and pedestrian routes and pedestrian areas can be encouraged by careful consideration of access, safety and landscaping in their design. Footways can incorporate such features as dropped kerbs to assist the mobility impaired, and tactile paving to assist the visually impaired. Where routes pass through or near housing areas or into open countryside, issues of housing amenity and the security of dwellings or the impact on wildlife and farmland are also relevant.
10.88 Pedestrianisation in the City Centre has greatly increased its attractiveness to shoppers and visitors. The pedestrianised area is to be revitalised as part of the Council’s transformation plans for the city centre and in time for when the city becomes UK City of Culture in 2017.There may be further scope for extending pedestrianisation in the main shopping areas and for more pedestrian facilities in the Old Town. There may also be opportunities for improving pedestrian areas in district and local centres and housing areas.
10.89 The Council wishes to develop new cycle tracks and footpaths in the City, to encourage more people to walk and use cycles instead of cars. Cycle and pedestrian network links and improvements will encourage a modal shift away from private motor vehicle use to more active and sustainable modes of transport. Provision for cyclists can also be made in some areas which are currently devoted to other modes of transport, and such provision may also be incorporated when new facilities are being planned. More safe and convenient routes are needed, where possible segregated from other traffic. The lack of suitable, secure cycle parking facilities is perceived as a barrier to cycling in Hull and there are still areas where cycling provision could be improved.
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10.90 The proposed A63 Castle Street cycle/footbridge scheme will help to solve pedestrian connectivity issues from the city centre to the waterfront. This bridge will provide both pedestrian and cycle access from the city centre to the waterfront over the busy A63/Castle Street. This will be a high quality iconic pedestrian/cycle bridge and it is intended that it will be delivered as the first stage of the wider A63 Castle Street Improvement. A consultation on the design options for the proposed new footbridge took place early 2014. Highways England is now considering responses as it develops the proposals further.
10.91 The Public Rights of Way network plays an important part in encouraging walking in the City and provides a quieter more pleasant alternative to the network of footways alongside highways. The network length in the city is 37km (23 mile) and provides important traffic free links in conjunction with the wider network of off-road cycle routes and other designated footpaths. The Rights of Way Improvement Plan forms an integral part of LTP and the Public Rights of Way are recognised as a key ingredient of the City’s integrated transport network. It is also important to highlight the strong linkages that exist with Public Rights of Way in the East Riding especially bearing in mind the extent of the travel to work area.
10.92 The Council secured funding from the Local Sustainable Transport Fund to deliver a range of sustainable travel initiatives. Key components of the project include the provision of two off-road shared pedestrian and cyclist routes alongside Holderness Drain from Hedon Road to Saltshouse Road with a link to Wilberforce sixth form college and alongside Ings Road / Sutton Road linking Holderness Road with the Foredyke Stream shared pedestrian / cycle route. These schemes are nearing completion. Lack of sufficient safe storage space for cycles in new development can deter people from owning and using a cycle. To overcome this, convenient, secure, and covered cycle storage need to be provided within the curtilage of new buildings, particularly dwellings.
10.93 Consideration should also to be given to the needs of powered two wheelers (PTWs). These include motorcycles, scooters and mopeds, the latter of which can be ridden at the age of 16. Currently journeys within Hull undertaken on a PTWs comprise just 2% of journeys but which is higher than the national average. On many of the main routes into the City, PTW are allowed to use bus lanes and there is no evidence to suggest they represent a danger to other users of such lanes including cyclists. PTWs are an affordable and sustainable mode of mechanised transport, and generate less pollution than a car in an urban environment and occupy less road space, thereby contributing to a reduction in congestion. PTWs generally suffer from much lower levels of built-in security than cars. They are easy to steal and as such, to encourage their increased use secure parking for PTWs should be considered in the same way as secure parking for cycles, especially in the case of employment developments.
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You Told Us
Walkways and cycleways should be provided alongside watercourses which could also link in with blue/green corridors. This would also help create an easement for inspection and maintenance, as well as opening up the opportunity to reconnect with Hull’s watercourses, the natural environment and biodiversity. City should become more pedestrian and cycle friendly. Also build on public transport offer. Support for the identification of new walkways and cycleways in the Local Plan. Active travel routes should be integrated as part of green infrastructure into new and existing developments. It is recommended that the Local Plan should also make appropriate reference to Hull City Council’s Rights of Way Improvement Plan. New routes should ideally provide access for a range of different user groups. In some locations, the provision of access for horse riders may also be appropriate and should be considered alongside provision for walkers and cyclists. The creation of new walkways and cycleways will improve public access throughout the city and enhance its green infrastructure. New walkways need to be developed. The Local Plan should identify new walkways and cycle ways too. Improve connectivity in the City as per the Council’s Rights of Way Improvement Plan 2009-2019. This identifies priorities as routes which improve access to important public destinations, lead to schools, bus stops or other public transport connection points. Introduce desirable walkway links between adjacent housing areas. Consideration for other leisure users (e.g. horse riders) in appropriate locations. Too much focus on cycling not enough on walking. It would be marvellous if green corridors and spaces could be linked to offer more exercise and family days out. Both cycling and walkways essential for health and retention of residents. Local Plan should lead the way! Most cities are putting in place cycle hubs and networks. Cyclepaths should be off road safe from traffic. Proposed A63 footbridge should be designed to take vehicles. (Concerns over pollution at this bridge) More engagement with local pedestrian/cycling associations at the planning stage is most welcome.
Options
Option A: Include a policy supporting walking and cycling as sustainable modes of transport.
Option B: Provide a more detailed policy than Option A safeguarding proposed cycle track and walkway routes and including design guidance for schemes.
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Preferred Option
10.94 Option B
Draft Policy 52
Walking and Cycling
Improving facilities for cyclists and pedestrians will be encouraged. Designing new cycle and pedestrian routes and pedestrian areas (including Public Rights of Way) will take into account:
cycle and pedestrian access and personal safety;
the needs of the mobility impaired;
the need for appropriate signposting;
appropriate materials and landscaping;
the amenity and security of adjacent areas, in particular housing;
the impact on wildlife and adjacent agricultural land.
Extending or improving pedestrian areas in shopping centres and housing areas will be encouraged. The provision of secure cycle and powered two wheeler (PTW) parking facilities will be supported, especially in the case of employment developments. Cycle tracks and footpaths routes will be safeguarded to protect them from other development that would otherwise prevent their delivery. The A63 Castle Street foot/cycle bridge is identified on the Policies Map.
Justification
10.95 The Local Plan guides development over the next fifteen years. It would be sensible to have a policy as proposed by Option B to cater for and also protect the future needs of walking and cycling.
Supporting Evidence
Sustainability Appraisal Objectives
5. Reduce the factors causing climate change, with a particular focus on reducing the consumption of fossil fuels and levels of CO2;
7. Achieve good air quality;
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12. Encourage healthy lifestyles and reduce the health impacts of new developments;
13. Deliver more sustainable patterns of development by ensuring links to a range modes of transport.
19. Ensure that people have equitable and easy access to shopping, community and other services and facilities;
20. Create conditions which support sustainable economic growth, encourage investment, innovation, entrepreneurship and business diversity;
Sustainability Appraisal Working Paper Comments
Improvements to transport linkages, pollution prevention policies and promoting sustainable transport policies will indirectly support creation of good quality housing, Once operational, the new A63 footbridge may help reduce the congestion at Castle Street, and therefore potentially reducing carbon emissions (although not reducing the need to travel with a car). The potential extended rail freight line to Saltend will help continue the service to support Port operations and other manufacturing units, and potentially support future manufacturing sectors. Rail related travel, due to the mass transport method, is typically favoured over car transport. Although the proposed railway station projects are unlikely to have massive local positive effect on emissions reduction (except possibly near KC Stadium during match days), or air quality, regional or national level impact may occur. Environmental impacts may occur as a result of Port expansion, and it requires implementation of appropriate safeguards, thus will help protect biodiversity or mitigate any negative effect as a result of the development proposal. Increased berthing opportunity could imply increased transport (for cargo movement) and thus add to transport emissions. The Port is a major contributor to economic growth in the City. The option will help its expansion and potential increase in service offering. Proposals to use River Hull for new freight and passenger services may affect aquatic and related terrestrial habitat within and in the vicinity of River Hull. Unless the policy clearly requires implementation of environmental safeguards, the predicted effect will remain as minor negative. Option will support sustainable modes of transport, and thus reduce travel related emissions, both at a local level and potentially at a regional level. River transport presents a good opportunity to move waste (for example for recycling to the recycling plant) in an energy efficient way. Dependent on the location of relevant industries along the river and the connectivity to river transport facilities, the option may support the SEA/SA objective. Park and Ride sites are considered to limit longer car travel, thus partially reduce transport emissions, at a local and regional level.
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The lorry and coach park east of Hull will reintroduce transport emissions within the City, but unless the capacity is increased, it is equivalent to a business as usual scenario. At this stage, the car park sites are not known, implying it is not clear whether spaces with biodiversity value could be considered for car park provision. Appropriate guidance/ criteria to protect species and habitats whilst conducting the review is recommended. Increased car parking implies increased transport emissions concentrated in an area. Dependent on the outcome of the review the effect could be positive or negative- to be determined at a later stage with more details. Large car park spaces, particularly set within a City Centre which houses significant area of conservation, has potential to create uninspiring spaces and could devalue heritage settings. Dependent on the outcome of the review and location of the car park spaces, the effect on the objective could be negative or neutral. If more car park spaces are provided, it in turn could provide counter productive to the effort to promote a compact city- thus potentially encouraging residents and visitors to use car travel. It is unclear whether crime prevention will be considered both as areview criterion and as a design principle, in car park options Provision of new cycleways and walkways in the City will support sustainable modes of transport, and thus reduce travel related emissions. Ensuring a balance of land uses with sustainable transport links will support sustainable modes of transport as well as presenting a development management option to help address potential increase in traffic from new developments (through the transport assessment).
Main Evidence Base Sources
Hull Local Transport Plan 2011–2026 (January 2011)
Table 10.1: Transport Assessments
Table 10.1 Transport Assessments - Required Details
Land Use and No Transport Transport Concept use(b) description of assessment statement(c) assessment proposal and development and travel supporting plan(c)(d)(e) information(f)(g)
A1 Retail sale of GFA GFA GFA Up to 800 m2 - food goods to between not normally 2 2 the public up to 250 m 250 and 800 over 800 m required m2
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Land Use and No Transport Transport Concept use(b) description of assessment statement(c) assessment proposal and development and travel supporting plan(c)(d)(e) information(f)(g)
Over 800 m2 - to be agreed (h)
A1 Retail sale of GFA GFA GFA Up to 1500 m2 non-food goods between - not normally 2 2 to the public up to 800 m 800 and over1500 m required 1500 m2 Over 1500 m2 - to be agreed(h)
A2 Financial and GFA GFA GFA Up to 2500 m2 professional between - not normally 2 services up to 1000 1000 and over 2500 m required 2 m 2500 m2 Over 2500 m2 - to be agreed(h)
A3 Restaurants GFA up to GFA GFA Up to 2500 m2 and cafés 300 m2 between - not normally 2 300 - 2500 over 2500 m required m2 Over 2500 m2 - to be agreed
A4 Drinking GFA GFA GFA Up to 600 m2 - establishments between not normally 2 2 up to 300 m 300 - 600 over 600 m required m2 Over 600 m2 - to be agreed
A5 Hot food GFA GFA GFA Up to 500 m2 - takeaway between not normally 2 2 up to 250 m 250 - 500 over 500 m required m2 Over 500 m2 - to be agreed
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Land Use and No Transport Transport Concept use(b) description of assessment statement(c) assessment proposal and development and travel supporting plan(c)(d)(e) information(f)(g)
B1 Business: GFA GFA GFA Up to 2500 m2 between – not normally (a) Offices not up to 1500 1500 - 2500 over 2,500 required 2 2 included in m m2 m Class A2 Over 2500 m2 (financial and – to be professional agreed(h) services)
(b) Research and development
(c) Light industry.
B2 General GFA GFA GFA Up to 2500 m2 industry not between - not normally 2 included in B1). up to 2500 2500 - 4000 over 4000 m required 2 The former m m2 2 ‘special Over 2500 m - (h) industrial‘ use to be agreed classes (B3 to B7), are now all included in B2.
B8 Storage or GFA GFA GFA Up to 5000 m2 distribution between - not normally 2 centres up to 3000 3000 - 5000 over 5000 m required 2 m m2 Over 5000 m2 - to be agreed(h)
C1 Hotels as long Up to 75 Between 75 Over 100 Up to 100 as ‘no bedrooms - 100 bedrooms bedrooms - not significant bedrooms normally element of care required is provided‘. Over 100 bedrooms - to be agreed
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Land Use and No Transport Transport Concept use(b) description of assessment statement(c) assessment proposal and development and travel supporting plan(c)(d)(e) information(f)(g)
C2 Residential Up to 30 Between 30 Over 50 beds Up to 50 beds institutions - beds - 50 beds - not normally hospitals, required nursing homes Over 50 bed - to be agreed
C2 Residential Up to 50 Between 50 Over 150 Up to 50 institutions students - 150 students students - not education students normally boarding required schools and training Over 50 centres. students - to be agreed
C2 Residential Up to 250 Between Over 400 To be agreed institutions – residents 250 - 400 residents hostels residents
C3 Dwelling Up to 50 Between 50 Over 80 For any houses for not dwellings - 80 dwellings development more than six dwellings exceeding 25 people living dwellings(i) together as a one household.
D1 Non-residential GFA GFA GFA To be Institutions between agreed(k)(l) 2 includes: up to 500 m 500 - 1000 (j) Medical m2 and health services Educational and culture Places of worship, religious instruction and church halls.
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Land Use and No Transport Transport Concept use(b) description of assessment statement(c) assessment proposal and development and travel supporting plan(c)(d)(e) information(f)(g)
D2 Assembly and GFA GFA GFA To be agreed leisure between 2 includes: 500 - 1500 over 1500 m cinemas m2 dance and concert halls sports halls swimming baths skating rinks gymnasiums bingo halls casinos other indoor and outdoor sports and leisure uses not involving motorised vehicles or firearms.
Others Includes, for To be agreed To be To be agreed To be agreed example: agreed stadium retail warehouse clubs amusement arcades launderettes petrol filling stations taxi businesses
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Land Use and No Transport Transport Concept use(b) description of assessment statement(c) assessment proposal and development and travel supporting plan(c)(d)(e) information(f)(g)
car and vehicle hire businesses selling and displaying motor vehicles nightclubs theatres hostels builders‘ yards garden centres post offices travel and ticket agencies hairdressers funeral directors hire shops dry cleaners.
Notes
a. Based on the national DfT Guidance on Transport Assessments; GFA = gross floor area.
b. In certain circumstance more than the minimum information is required. For example:
where there are areas of existing traffic congestion
where there are areas of existing on-street parking problems
any development that is likely to increase accidents or conflicts among drivers and non-drivers, particularly vulnerable road users such as children, people with disabilities and elderly people
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where there are areas of poor accessibility to public transport or where the local transport infrastructure is inadequate, for example, the roads are substandard the pedestrian and cyclist facilities are poor
any development that generates HGVs which impact on 'sensitive' areas, such as residential areas or an area subject to a weight restriction
any development generating significant abnormal loads per year
Any development located on or adjacent to the Classified Road Network
any development located within or adjacent to Air Quality Management Areas
any development in other ‘sensitive’ areas, such as where development traffic may affect a school or where there are significant numbers of vulnerable people.
any development that does not conform with the adopted development plan; and
any development which proposes 100 or more parking spaces. c. Please refer DfT Transport Assessment guidelines for more details d. A scoping report is required before a major transport assessment. See the DfT Transport Assessment guidelines e. Based on national guidance on the preparation of travel plans, linked to that for DfT Transport Assessment guidelines . f. Please see DfT Transport Assessment details on concept proposals and supporting information. g. Refer to safety audit guidance h. Concept proposals for retail, general employment, office and warehousing developments that will be owned or occupied by more than one person or company. i. For residential developments over 10 dwellings, it shall be necessary to provide at least ‘welcome packs’ for residents, providing details of:
local public transport services and bus travel vouchers;
provision for cyclists and pedestrians; and
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any nearby services and facilities.
Developments of more than 80 dwellings will normally require a formal travel plan, which includes the information listed above as well as proposals for monitoring, targets and so on. Please see parking for cycles for details of cycle parking to serve residential developments.
j. In the case of schools and further and higher education establishments, there may be need a major transport assessment if pupil or student numbers would be increased by 10% or more.
k. In the case of schools and further and higher education establishments, consideration will be given of facilities such as a new sports hall or a community facility on a site-by-site basis.
l. Where a new school is proposed on a site, you should include it in the concept proposal for the development. A concept proposal for a new stand-alone school depending on its location, proposed size and facilities and traffic conditions in the area is usually required.
Table 10.2: Parking Standards
Table 10.2
Parking Standards
The Council seeks a well designed solution to parking provision in development schemes, and this will be delivered through the development management process where new parking is to be provided or existing parking provision is to be altered. The residential parking standards contained in Table X will apply to all developments with the provision of 1 or more residential units (gross).
Applications for extensions and alterations to existing dwellings should ensure that a suitable level of parking provision is retained. The standards contained in Table X will be used as a guide having regard to the size of the dwelling that is to be created, the impact upon highway safety and the level of provision that already exists on site.
The non-residential parking standards contained in Table XA will apply to all developments that result in the creation of non-residential floorspace. This includes the extension of and alterations to existing non-residential premises and all changes of use.
Where mixed-use, residential and commercial developments are proposed, the parking requirements for each element should be calculated individually using the standards contained in Tables X and XA. Where appropriate, the Council will consider the shared use of parking between residential and commercial elements where it can be demonstrated that the relevant standards are met.
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The NPPF states that there is an overall need to reduce the use of high-emission vehicles. Therefore the Council will ensure that consideration is given to making provision for electric vehicle charging infrastructure in new developments. It is recognised that making provision for electric vehicle charging points will potentially reduce emissions and thereby contribute towards sustainable development.
Proposals for larger schemes, including all major developments (as defined in statute) will be assessed against the criteria and transport assessments and travel plans. There may be extenuating circumstances where it may be appropriate to allow a variation from the standards for larger schemes. Any such circumstance will need to be justified by a transport statement or assessment. A travel plan is likely to be required to support lower parking standards on major development schemes.
Residential
The Local Plan seeks to allocate development in accessible locations and the Council is committed to improving sustainable transport options. However, it is acknowledged that even with good public transport provision or proximity to local services and jobs, whilst car usage may be less in Hull, high levels of car ownership are likely to remain as a consequence of residents’ desire to retain the option of keeping a car to use for other journeys, such as family visits, shopping, work, DIY collections, waste recycling, holidays etc.
Hence, if parking provision is not made to meet the likely level of car ownership for new developments, including house conversions and sub-division, it is probable that cars will be parked in areas not designed for such purposes, such as grass verges and landscaped areas. Additionally, there is evidence of these effects in newer housing developments where some occupiers and visitors are frustrated by an apparent shortage of parking spaces. Furthermore, such situations can impact on surrounding areas and adjoining roads as new residents look further afield to find parking spaces.
There may be exceptions where anticipated levels of car ownership may well be less than the proposed standards in some development schemes. Such development proposals will need to be justified by a transport assessment and a travel plan to support lower parking provisions at a discounted standard.
The design and provision of parking spaces in recent and many older developments does not make best use of the quantity of parking provided. This is apparent in higher density housing schemes where parking is located in areas away from the street frontage, such as parking at the rear of dwellings in Kingswood, which appears to lead to indiscriminate on-street parking and no obvious parking areas for visitors, raising issues of highway safety and residential amenity and eventually the need to introduce engineering and enforcement measures to resolve.
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Parking provision on new housing developments generally allocates spaces to specific dwellings. This approach, though desirable for buyers and therefore attractive to developers, does not always represent the most efficient use of the parking spaces provided. The level of car ownership varies between households and in some instances there will be under provision of spaces and in others there will be over provision of spaces.
The proposed parking standards therefore seek a different approach that places a greater emphasis on need, location and design of parking spaces in the way that they are provided. The proposed revision of existing standards therefore require provision for visitor parking sufficient to meet demand based on levels of car ownership, provided there is a combination of off-street (allocated parking) and communal (unallocated parking). Allocated parking should be clearly provided for off the public highway. On-street parking should therefore be provided for visitors only. The standards provide for the typical level of additional demand for unallocated parking suggested in the ‘Residential Car Parking Research’: DCLG May 2007 and ‘Car Parking: What Works Where’ (English Partnerships 2006).
Visitor Parking
‘Car Parking – What Works Where’ states that “generally parking standards project a level of provision for visitors of about one space for every five homes”. This target serves as a useful starting point in considering visitor car parking provision but consideration needs also to be given to local circumstances and how parking is to be catered for in the overall development. For instance is there communal parking and how many on site spaces are provided per home? On this basis local guidelines for visitor car parking are:-
no special provision need be made for visitors’ parking when at least half of the parking provision associated with a housing development (5 dwellings or more) is unallocated (i.e. communal parking).
if less than half the parking was to be unallocated (i.e. communal parking), then an extra 0.2 spaces per dwelling in a housing development (5 dwellings or more) are needed to provide for visitors.
if an average of more than 2 allocated spaces per dwelling is provided, the demand for visitor spaces reduces to about 0.1 space per dwelling.
In all cases parking requirements will be rounded up or down to the nearest whole visitor parking requirement.
The use of unallocated spaces can, therefore, significantly reduce the overall number of parking spaces to be provided in any scheme and offer greater flexibility for spaces to be used by visitors and residents.
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Unallocated parking spaces can be either off-street communal parking areas or designated spaces forming part of the street layout. A combination of both types of parking (unallocated and allocated) may form the most appropriate solution. The key considerations in using unallocated parking are that it:
only needs to provide for average levels of car ownership within a development
allows for changes in car ownership between individual dwellings over time
provides for both residents’ and visitors’ needs and can cater for parking demand from non-residential uses in mixed-use areas
Where unallocated visitor parking is provided, as part of major development proposals, the Council would encourage the majority of it to be provided as spaces within the new street layout / public highway as this provides the most flexible form of parking for the entire community. It will not be acceptable to provide required visitor parking in existing streets adjacent to the new development.
The Council has in recent years seen substantial numbers of planning applications for the conversion of existing dwellings into flats and changes of use from residential dwellings to houses in multiple occupation. Such developments can, if inappropriately located and / or by becoming concentrated in a locality, increase local on-street parking problems. It can also undermine amenity and street character by leading to the removal of front garden walls and landscaping to accommodate parking on private amenity space.
With regard to the conversion of existing buildings for flats, subdivision into two or more properties will generally be welcome where parking is provided on plot in accordance with the standards in Table X so it does not cause or add to existing parking problems in the locality.
The following bullet points provide further explanation with regard these criteria in respect of parking provision:
proposals should not prejudice the character of the area e.g. through the loss of front garden walls, trees or other vegetation that comprise a key characteristic of the appearance of the street
there should be no unacceptable loss of private amenity space through, for example, converting rear gardens into hard space for parking. It would be expected that adequate private amenity space is retained to provide for sitting out, the drying of clothes, storage of cycles and bins (if necessary) and some green space and / or planting beds
in providing an acceptable level of parking in accordance with the standards, it does not lead to the loss of unallocated on-street parking space(s), for example, through the formation of a driveway, where such
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roadside parking spaces provide the primary means of parking in the locality, as is the case for example in many terrace streets found in Hull.
On-plot parking ideally should be provided but where this is not possible parking may be catered for on-street where:
the highway is wide enough to allow for the parking of cars and the free passage of large vehicles such as delivery lorries, refuse vehicles and fire appliances.
there is no evidence /record of parking problems in the locality on-street parking in the immediate vicinity of the development would not cause an unacceptable safety hazard to pedestrians, cyclists and other road users.
Particular regard will be had in areas, such as the City Centre which suffer from acute parking problems. A balance has to be struck with the Local Plan's aim to provide more housing in the City Centre and the increased demand this can create for finite on-street car parking spaces also demanded by shoppers and businesses. In recent years there has been a significant rise in requests for residential off street parking permits in the City Centre.
Discounts
The following factors will be taken into account by the Council when considering a discount:
The type, tenure, size and mix of housing
The layout, design and form of parking provision
Whether the road layout is to be adopted and / or designed to adoptable standard
On-street parking conditions in the surrounding areas
Access to existing public or private car parking facilities and the potential for shared parking
Proximity to public transport and services
The level of cycle parking provided
The provision of mitigating measures
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In the case of housing developments in the City Centre - the availability of both on-street and off street parking in proximity to the proposal
Consultations with the Council's Service responsible for traffic regulations, parking permits, and controlled parking zones - particularly where housing developments are in the City Centre.
In order to qualify for the maximum discount, developments will be expected to provide cycle parking above the minimum required standard for units with more than 1 bedroom.
Additionally, the Council will pay particular attention to the overall housing and road layout in considering whether discounting is acceptable. Some developers are now submitting layouts which are not being designed to meet adoptable highway standards. These schemes may have narrow estate roads which may be unable to accommodate on-street parking and / or be private roads and are difficult to make subject to Council controls.
The Council will consider schemes that propose the shared use of existing car parking facilities where this can be reasonably accommodated, such as in the use of business car parking facilities by residential developments during evenings and weekends. Parking in excess of the stated required standard will exceptionally be permitted for sites in the city centre or at the edge of the city centre where genuine opportunities for shared parking exist.
Where new development or conversions are proposed within or close to an existing Controlled Parking Zone (CPZ), developers should take into account of the Council’s October 2014 ‘Hull Parking Policy and Operational Arrangements’ (or any subsequent revisions)and that there is unlikely to be any additional on-street parking capacity. In particular, the Council will expect all parking requirements to be met on site and parking permits will not normally be issued on these developments. Developers are strongly urged to make prospective purchasers of affected new dwellings aware of this and the Council will seek to attach an informative to planning permission to make applicants and other parties aware. The Council may also seek to use appropriate legal measures to remove the right for occupiers of new developments in existing CPZs to obtain parking permits.
Car Free Residential Development
A number of existing properties, notably flats above shops, do not provide car-parking facilities for residents, and there may be a limited number of cases where, subject to compliance with other relevant Local Plan policies, car-free development can be considered acceptable in principle. These may include:
The extension, alteration or re-use of an existing building with no access to parking
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The reversion of a previously converted property to its original residential use, including flats above shops
The provision of residential accommodation on a small (up to 5 units net) city centre site that may otherwise not come forwards for development
Where arrangements are made to share an existing car-park within the vicinity of the site which can reasonably accommodate the parking demand generated by the development.
In all instances, developers will be required to demonstrate why car-free development represents the best available option.
Homes in Multiple Occupation
Similar problems and issues arise with regard to Homes in Multiple Occupation (HiMOs). HiMOs requiring planning permission will be considered on their merits.
Garages
‘Residential Car Parking Research’ reveals that where a garage is provided 45% never parked their car in it, 14% only occasionally parked a car in it and were often too small to park a mid sized family car in. Given the need for storage and the fact that cars are generally larger than they used to be, garages will count towards the required standard only where they have a minimum internal dimension of:
Single garage: 6m x 3m
Double garage: 6m x 5.6m
Otherwise, where garages are proposed that fall below the minimum size standard these will not count towards the parking standards. Additionally, it will not be acceptable to provide garages as the sole parking space(s) serving a dwelling given the propensity for garages to be used for storage.
Electric vehicle charging points
Electric vehicle charging sockets’ should therefore be provided in the external walls or garages of suitable houses to serve private parking spaces and with regard major residential and mixed-use developments in appropriate public locations. This may include a space(s) designated for electric vehicles with a charging point as part of the visitor/unallocated parking requirement within the public highway and/or within private communal parking areas.
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New residential developments that consist of 50 or more new homes are expected to have provision for electric charging points. In developments of below 50 new homes, electric charging points are encouraged.
Electric charging points and parking for mobility scooters should be provided in new developments in a convenient location at ground floor level where possible. This, particularly, applies to flat developments and elderly persons housing where it may be difficult for occupants to charge scooters within the property itself.
Parking for people with disabilities
Specialist housing provided for groups, such as the elderly will also be required to provide spaces that meet disability standards. Registered Social Housing providers often design and provide housing, including parking spaces too and adapted to meet the needs of people with disabilities. In addition, this guidance promotes on-plot and on-street parking in close proximity to the dwellings it serves ahead of parking courts, which if not designed carefully can often be remote and inconvenient to users. This principle is intended to promote improved accessibility for all users.
Car parking for Elderly Persons Housing
The definitions of Elderly Persons Housing are set out in the Housing Corporation’s Scheme Development Standards :
Category I: Self-contained accommodation for the more active elderly, which may include an element of warden and/or call support and/or additional communal facilities.
Category II: Self-contained accommodation for the less active elderly, which includes warden or 24 hour peripatetic cover and the full range of communal facilities.
100% of the parking requirement for Category I and Category II developments should be of sufficient dimensions to be used by disabled persons.
Other dwelling types
There are a range of other living models provided for groups such as the elderly or those in need of care. Care can range from provision of full-time onsite wardens and associated services to off-site assistance accessed only infrequently on an emergency basis. Schemes with a high degree of care dependency will have reduced need for parking for residents but more for wardens and visitors and emergency vehicles whilst those tailored to ‘independent living’ models may need more resident parking and fewer warden spaces.
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Given the range of accommodation and care needs the Council will consider in relation to the residential parking standards with evidence submitted with applications that justify the parking provision. This should include a description of the level of care, staffing and anticipated number and age range of occupants. An additional allowance should also be made for visitors. It may be considered appropriate in some instances that 100% market schemes with very low levels of care dependency meet the minimum standards for general housing.
Table X Residential Parking Standards
Minimum number of parking spaces per dwelling plus visitor allowance
Please note parking requirements will be rounded up or down to the nearest whole parking space requirement.
Table 10.2
Use Class Type Space Additional Space
C3 Studio /bedsit Assessed 1 secure / on long term individual basis space per unit plus 1 bed 1 1 short 2 bed 2 term space 3 bed 2
4 bed 3 per 5 units where 5+ bed 4 (plus one space per communal additional parking is bedroom to be thereafter) provided
Additional
Houses with additional habitable 1 per additional
rooms on upper floors/ habitable room *** roofspace
Flats or Bungalows with a total 1 per additional of habitable room *** 6 or more habitable rooms and
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bedrooms
Houses with 5 or more habitable 1 per additional
rooms on the ground or lower habitable room ***
ground floor
Elderly Persons Housing** 1 per unit 1 short term Category I – Retirement space dwellings, per 3 units no warden control, 1 bedroom plus
case by case basis 1 long term Category I – Retirement 2 per unit space dwellings, per 5 units no warden control, 2 bedroom
Category II – Warden Control, 1 per unit
sheltered dwellings, 1 or 2
bedroom
Category II – Warden Control, To be determined on a sheltered dwellings, 1 or 2 case by case basis bedroom
* Standards applicable to all dwelling types unless specifically stated
** Category III Elderly Persons Housing is classified as a C2 use under the Use Classes order. Parking requirements for Category III housing is set out In Table XA under Non-Residential Parking Standards. Extra Care housing will be considered against the C3 parking requirements unless it can be demonstrated that it is specifically for frail older persons.
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*** All rooms over 8 square metres which are not kitchens, utility rooms, bathrooms, WCs or circulation space are considered to be a habitable room. Large habitable rooms or open plan areas, typically over 25 sq metres and capable of subdivision will be treated as two habitable rooms.
Evidence suggests that it is best dealing on an individual basis with parking requirements for additional habitable rooms on upper floors within dwellings with reversed layouts. Provision should only be sought where there are three or more additional habitable rooms within the entire property.
Unassisted ‘Independent’ retirement
1 space per 2 dwellings may be appropriate for unassisted ‘independent’ retirement living models with high levels of market units, whilst 1 space per 4 dwellings may be appropriate for frail elderly assisted living schemes. An additional space per 4 dwellings should also be provided for communal/visitor parking and 1 space per warden / staff, if applicable. Site design should also provide for access for emergency vehicles and the parking needs of people with disabilities. Proximity to services will also be considered as there is likely to be less reliance on cars and more on buggies.
Supported housing schemes
Use class C3b for Up to 6 people living together as a single household and receiving care, e.g. supported housing schemes such as those for people with learning disabilities or mental health problems - 1 space per warden and 1 space per 1 dwellings for communal/visitor parking.
Use Class C3c which allows for groups of people (up to 6) living together as a single household, which do not fall within the definition of HiMOs, e.g. a small religious community - Comply with minimum standards as set out above.
Disabled car parking provision
Where communal parking is proposed over 20 units, 6% of the total number of spaces should be provided for exclusive disabled use plus 1 space of sufficient dimensions to be used by disabled persons for every 10 units. This should be provided over and above general parking requirements. Requirements for smaller schemes, over and above general parking requirements, are set out below:
Scheme size; exclusive disabled spaces; spaces meeting disabled standards
5-10 units; 1 space; 0
11-20 units; 1 space; 1 space
21-30 units; 6%; +1 space
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31-40 units; 6%; +2 Spaces
Car parking for Motorcycles and other powered two-wheelers
Where communal parking is proposed, major residential applications will be required to make parking provision for motorcycles and other powered two-wheelers which should be secure and undercover. As a guide, 5% (1 in 20) of the required car parking provision (excluding disabled car parking spaces) should be allocated for motorcycle use.
Non-Residential parking standards
Unless otherwise stated, floor areas are gross measured externally.
FTE = full time equivalent s/t = short term l/t = long term
Please note parking requirements will be rounded up or down to the nearest whole parking space requirement (e.g. a B1 development of 275sq m would be expected to provide 11 car parking spaces)
Table 10.3
Use Class / Type Required number of car Minimum cycle parking parking spaces (includes standard visitor spaces unless
otherwise stated)
A1
Hypermarkets 1 space per 14 sqm s/t space per 150 sqm Superstores 1 l/t space per 10 Large supermarkets staff
Retail warehouses 1 space per 35 sqm
Garden centres
Other retail uses
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Use Class / Type Required number of car Minimum cycle parking parking spaces (includes standard visitor spaces unless
otherwise stated)
A2
Financial and 1 space per 40 sqm 1 s/t space per 200 professional sqm (Town centres) services 1 l/t space per 10 1 space per 30 sqm staff (Banks, building societies (neighbourhood or local
etc.) centres)
A3
Restaurants and Cafes 1 space per 5 sqm of public 1 s/t space per 100 sqm floorspace 1 l/t space per 10 staff
A4
Drinking establishments 1 space per 5 sqm of public 1 s/t space per 100 sqm floorspace 1 l/t space per 10 staff
A5
Hot food takeaways 1 space per 5 sqm of public 1 s/t space per 100 sqm floorspace 1 l/t space per 10 staff
B1
Offices 1 space per 30 sqm 1 s/t space per 500 sqm
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Use Class / Type Required number of car Minimum cycle parking parking spaces (includes standard visitor spaces unless
otherwise stated)
1 l/t space per 10 staff
Research and 1 space per 30 sqm Development
Light industrial up to 1 space per 25 sqm 250 sqm floorspace
Light industrial over 250 10 spaces plus 1 space per sqm 35 sqm floorspace
B2
General industrial up to 1 space per 25 sqm 1 s/t space per 500 250 sqm sqm floorspace 1 l/t space per 10 staff
General industrial over 10 spaces plus 1 space per 250 1 l/t space per 10 staff 35 sqm sqm floorspace
B8
Storage or distribution 1 space per 25 sqm 1 l/t space per 10 up to staff
250 sqm floorspace
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Use Class / Type Required number of car Minimum cycle parking parking spaces (includes standard visitor spaces unless
otherwise stated)
Storage or distribution 10 spaces plus 1 space per 1 l/t space per 10 over staff 35 sqm 250 sqm floorspace
B1 / B2 / B8
Flexible consent 1 space per 40 sqm 1 s/t space per sqm
1 l/t space per 10 staff
C1
Hotels and motels1 1 space per bedroom plus 1 l/t space per 20 beds 2 spaces per 3 FTE staff plus 1 l/t space per 10 1 space per 5 sqm public staff
floorspace for conference or
exhibition facilities plus
1 coach space per 100
bedrooms (minimum)
Small hostel (single 0.75 spaces per unit parent
or couple with no children)
Family hostel (two 1 space per unit 1 l/t space per 3 units adults
and two children)
C2
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Use Class / Type Required number of car Minimum cycle parking parking spaces (includes standard visitor spaces unless
otherwise stated)
Institutions / homes with 1 space per 5 resident bed 1 s/t space per 20 beds care staff on premises spaces at all 1 l/t space per 10 plus staff time2 1 space per 2 non-resident
staff
Frail Elderly space per 4 resident bed
Accommodation2,3 spaces
Hospitals To be assessed on a case by
case basis
Education – Halls of 1 space per 2 FTE staff plus 1 l/t space per 3 students Residence 1 space per 6 students 1 l/t space per 10 staff
D1
Public halls and places 1 space per 9 m2 or 1 s/t space per 200 of m2 1 space per 3 fixed seats assembly (not D2) 1 l/t space per 10 plus staff
3 spaces per 4 FTE staff
Community and family 1 space per 9 sqm 1 l/t space per 10 staff plus centres 1 space per FTE staff
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Use Class / Type Required number of car Minimum cycle parking parking spaces (includes standard visitor spaces unless
otherwise stated)
Day centres 1 space per 9 sqm or
1 space per 4 visitors plus
1 space per FTE staff
Places of worship 1 space per 10 sqm
Surgeries and clinics 3 spaces per consulting room 1 s/t space per consulting (including doctors, 1 space per FTE non dentists consultant room
and vets) staff 1 l/t space per 10 staff
Libraries 2 spaces plus 1 s/t space per 100 sqm 1 space per 30 sqm public 1 l/t space per 10 floorspace staff
Nursery schools / 1 space per 4 pupils 1 l/t space per 10 staff playgroups
Schools (including 1 space per FTE staff plus 1 l/t space per 15 students residential) 1 space per 5 full-time further (primary) education students 1 l/t space per 5 plus students
1 space per 8 students over (further education and 17 years of age plus secondary) 1 space per 20 students aged 1 l/t space per 5 staff 17 years or less
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Use Class / Type Required number of car Minimum cycle parking parking spaces (includes standard visitor spaces unless
otherwise stated)
plus
1 visitor space per 100
students
Further education 1 space per FTE staff plus 1 l/t space per 5 students 1 space per 5 full-time 1 l/t space per 10 students staff
D2
Places of entertainment 1 space per 5 sqm 1 s/t space per 25 sqm 0.75 spaces per FTE staff 1 space per 10 staff
Multi-screen cinemas 1 space per 3 seats on free 1 s/t space per 20 seats standing development 1 l/t space per 10 staff
Swimming and leisure 1 space per 10 sqm public 1 s/t space per 25 pools sqm floorspace 1 space per 10 staff 1 space per 2 FTE staff
2 coach spaces (minimum)
Tennis / badminton 2 spaces per court courts
Squash courts 2 spaces per court
Gyms and health clubs space per 7 sqm public
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Use Class / Type Required number of car Minimum cycle parking parking spaces (includes standard visitor spaces unless
otherwise stated)
floorspace
Ice rink 1 space per 12 sqm rink area
Ten pin bowling 3 spaces per lane s/t space per 3 lanes /
rink
1 s/t space per 25
spectator seats
1 l/t space per 10 staff
Football pitches 20 spaces per pitch 2 s/t space per pitch
1 space per 5 paying
spectators (where there is
fixed or temporary seating)
Other outdoor pitches 1 space per 2 users
(maximum potential usage)
1 space per 5 paying
spectators (where there is
fixed or temporary seating)
Golf course 100 spaces plus 50 overflow 5 l/t spaces per 9 holes (18 holes)
9 holes at 50% of above
rates
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Use Class / Type Required number of car Minimum cycle parking parking spaces (includes standard visitor spaces unless
otherwise stated)
Golf driving range 1.5 spaces per tee 1 s/t space per 5 tees
Other sports and To be assessed on a site by site basis, dependant on recreational uses anticipated staffing, levels of use and numbers of paying
spectators
Motor Trade related (Sui Generis)
Staff 0.75 spaces per FTE staff 1 l/t space per 10 staff
Showroom and car 1 space per 10 cars sales displayed
Vehicle storage 2 spaces per showroom
space or 10% of annual
turnover
Hire cars 1 space per 2 cars based on
site
Ancillary vehicle storage 3 spaces or 75% of the total if
more than 3 vehicles
Workshops 3 spaces per bay
Tyre / exhaust centres 2 spaces per bay
Parts store / sales 3 spaces for customers
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Use Class / Type Required number of car Minimum cycle parking parking spaces (includes standard visitor spaces unless
otherwise stated)
Car wash / petrol filling 3 waiting spaces per bay
Disabled parking
Development proposals should provide adequate parking for disabled motorists, in terms of numbers and design.
Motorcycles and other Powered Two-Wheelers
Appropriate provision should be made for the parking of motorcycles and other powered two-wheel vehicles. As a guide, approximately 5% (1 in 20 spaces) of the required car parking provision (excluding the disabled requirement) should be allocated for motorcycle use. This proportion should be included in the total parking provided for a development rather than in addition to it.
Service Vehicles
Parking and access requirements for service and delivery vehicles shall be additional to the requirements set out in these standards unless specifically stated. Where required, the quantity and design of Heavy Goods Vehicle (HGV) parking will be assessed on a site-by-site basis.
Electric vehicle charging points
New non-residential / commercial developments under 5,000 square metres are encouraged to have provision for electrical charging points. Non-residential developments of 5,000 square meters of more are expected to have provision for electric charging points.
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11. Water Management Introduction
11.1 The National Planning Policy Framework is clear that Local Plans must address pollution, flood risk, climate change mitigation and infrastructure for water supply and waste water. It recognises that these are strategic issues.
11.2 As well as being the planning authority, the Council is also the Lead Local Flood Authority. The LLFA is responsible for flood risk from ordinary watercourses, surface water and ground water. Responsibility for flood risk from main rivers, the sea and large reservoirs is with the Environment Agency. The LLFA brings with it a number of responsibilities. One of these is the SuDS Approving Body which is to ensure national standards of sustainable drainage are enforced.
11.3 Local authorities must also have regard to river basin management plans which implement the Water Framework Directive when carrying out their functions. The Water Framework Directive applies to surface waters, some coastal waters and groundwater. It places a requirement on member states to prevent deterioration of aquatic ecosystems and to protect, enhance and restore water bodies to ‘good’ status.
11.4 These issues are interlinked and so are explored under the heading of water management.
Water management in Hull
11.5 The system of water management in Hull is unique and complex. Information about the risks and responsibilities is set out in a number of documents. It is therefore considered appropriate to summarise Hull’s flood risk and how Hull’s drainage system operates before examining the options for the Local Plan. For context, the following map shows a simplified version of the drainage system in Hull and the agencies involved in its operation and maintenance.
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Map 11.1 Hull's drainage system
11.6 In terms of the national system of assessing flood risk, the majority of Hull is located within flood zone 3a. This is because ground levels in the city are generally lower than the high tide level of the Humber and means that the city is reliant on flood defences. The scale of the issue is highlighted by the fact that Hull and the neighbouring Haltemprice settlements immediately to the west are identified as an Area of Significant Flood Risk. This brings additional requirements for flood risk plans: these have been produced.
11.7 Flood risk is commonly perceived as flooding from rivers – in Hull’s case from the River Hull or the Humber Estuary. Tidal flooding from the Humber can occur either because the tide level in the estuary rises above the level of the defences along the shoreline or because water from the Humber flows up the River Hull and causes water levels to rise above the river defences. These issues are likely to be exacerbated by climate change in the form of rising sea levels, and, as experienced in 1953 and 2013, from tidal surges. The 2013 tidal surge significantly affected the Humber area and has been subject to detailed analysis by the Environment Agency.
11.8 The Environment Agency has extensive flood defence assets within the city along the banks of both the River Hull and the Humber Estuary, consisting of embankments, flood walls, pumping stations and the Hull tidal surge barrier. A smaller network of Hull City Council and privately maintained flood defence infrastructure is also present in the city. There is a risk of flooding if the defences were breached.
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11.9 There is also a risk from fluvial flooding from the River Hull – when so much water enters the river in the upper and middle catchment areas that it causes overtopping. This is considered to be less of a concern for Hull (which occupies the lower catchment of the river) because overtopping tends to occur in the upper and middle catchments. However flooding along the River Hull corridor could also occur if large amounts of water flowed downstream at the same time as a high tide.
11.10 Pluvial flooding occurs when intense rainfall is unable to permeate into the ground or enter drainage systems quickly enough to prevent a build-up of water. Surface water flooding can be exacerbated by sewer flooding. Both of these factors are relevant in Hull and this is where the complexity of Hull's drainage system becomes apparent. Hull is built on chalk, which is permeable. However, this chalk is overlain by mainly clay soils of varying depths which have low permeability, reducing infiltration into the ground and increasing surface water run off. The chalk also houses an aquifer, giving Hull a high water table, meaning that overall, there is relatively little permeation of rainfall into the ground, especially when the ground is already saturated.
11.11 There are two drainage systems in the city. One is the fluvial drainage system which is made up of the River Hull, Beverley and Barmston Drain and Holderness Drain. This system drains the rural areas to the north of the city in the River Hull valley which then discharge into the Humber and ultimately the North Sea. This system only provides limited surface water drainage for the city at Bransholme and Kingswood.
11.12 The rest of the city is drained by the Hull and Haltemprice drainage system. This consists of the drainage infrastructure serving the city and surrounding area in the form of sewers and underground piped systems. In this combined sewerage system rainwater mixes with domestic and commercial sewage. The flat geography of the city means that the system is heavily reliant on pumping stations, operated by Yorkshire Water. The system is unique in that almost all of the surface water and storm drainage is piped round the city and discharges through the Saltend Waste Water Treatment Works, rather than being discharged into the nearest watercourse. This is where surface water flooding can be exacerbated by sewer flooding. When rain falls on the higher ground to the west of the city, it flows into the sewers, rapidly filling them, leaving little capacity for the drainage needs of the city. High rainfall and saturated ground conditions combined in 2007 to cause substantial surface flooding across the city.
11.13 Actions are being taken to address flooding and drainage issues. The detail of these actions is explored through the policy approaches set out in the following sections.
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Flood Defences
11.14 Flood defences protect the city from the risk of tidal flooding or fluvial river flooding. There are a number of important documents that address flood defences and strategies, setting out long term investment plans.
Planning for the Rising Tides: Humber Flood Risk Management Strategy
11.15 This sets out that the Environment Agency intends to continue to provide and maintain flood defences in Hull. It assesses the condition of flood defences in Hull as being generally in good condition and a 1 in 200 level of protection. However there are some local defences which are at a lower standard so improvements are required. It confirms that the Environment Agency would be involved at stages in the planning process to ensure flood risk is taken into account. It also states that the Environment Agency would seek to supplement public funds with contributions from major beneficiaries and developers would be expected to pay the full cost of new works required to protect development from undue flood risk.
River Hull Integrated Catchment Strategy
11.16 The River Hull Strategy states the number of people and properties at risk in Hull mean there is an overwhelming case for continuing to maintain and improve the flood defences in the lower Hull catchment. It does recognise that some of the privately owned defences along the Hull are in poor condition and promotes working with the Council and landowners to improve these.
Strategic Flood Risk Assessment
11.17 The Strategic Flood Risk Assessment includes an assessment of the flood defences in the city along the Hull and Humber frontages. It notes the variable age, type and condition of the Humber defences.
11.18 It advises that the existing River Hull defences are in a very variable condition. The hard defences are noted as being in a poor condition in some parts. Some of these defences are owned by private landowners. The Council has powers to make landowners maintain flood defences to the statutory levels. As the Hull is a main river, the Environment Agency also has permissive powers.
11.19 The SFRA also provides technical advice as to where and how new development should be designed. It was adopted in 2007 and is currently being updated.
Works to defences
11.20 Works to upgrade the River Hull Tidal Barrier have been completed and improvements to the defences at Albert Dock have also been carried out since the 2013 tidal surge event.
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You Told Us
There was strong support for important flood defences to be identified on the proposals map and for policies to protect and enhance flood defences but enhancement should not be identified unless there is a commitment to delivery. It was put forward that the plan should seek contributions from developers for flood defences It was suggested that the 8 metre easement should be incorporated into new development to allow for inspection and maintenance of defences Specific improvement and enhancements to the existing hard defences were suggested, along with a comment that the potential for ‘soft’ defences should be fully used.
Options
Option A: This option would be to not have a policy about flood defences. There is no requirement for local planning authorities to have policies regarding flood defences. The Council does have a role as Lead Local Flood Authority and management plans for the flood defences in Hull are produced by the Environment Agency.
Option B: This option would be a policy preventing development which could harm the integrity of the defences and supporting works to improve the defences. This could also include reference to the 8m easement requirement from the Environment Agency.
Option C: This option would indicate the quality and standard of the defences. It would be supported by a policy which would require improvements to weak parts of the defence, along with preventing development which could harm the integrity of the defences and supporting works to improve the defences.
Option D: This option would apply where a development would require an improvement in related flood defences. This would be likely to only apply where particularly significant development.
Preferred Option
11.21 Option B and Option D.
Draft Policy 53
Flood Defences
1. Development proposals adjacent to flood defences must not reduce the effectiveness of the flood defences, including the future maintenance of those defences. Proposals should include an 8m easement to allow for access to flood defences and main rivers unless otherwise agreed with the regulatory body.
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2. Proposals to improve the standard of flood defences will be supported, particularly where these improvements would improve local amenity, recreation and access.
3. Development proposals may be required to improve the standard of flood defences if required by the development proposed.
Justification
11.22 Option A is discounted. The flood defences along the Hull and Humber frontages are of key importance in protecting the city. They are in the ownership of a number of people and organisations and some will require improvement over the plan period. There are also areas of potential change and development adjacent to those defences so it is important that developers and decision takers have clear guidance on how flood defences should be considered in development proposals.
11.23 Option C is also discounted. The powers available to require improvements to the flood defences are not derived from the Planning Acts. While it would be useful to indicate the areas of the defences which require improvement, this information is available within the SFRA and is subject to review by the Environment Agency through their work.
11.24 Option B is therefore considered to be the most appropriate. A policy will clearly set out that development must not reduce the effectiveness of flood defences and that the improvement of flood defences is supported. This improvement should include improving access to the waterfront areas of the city, as it has been highlighted in other parts of the Local Plan that this is an important part of the future development of the city.
11.25 Option D is also considered to be an appropriate option to progress in light of the pressures that the Environment Agency have highlighted with regard to providing flood defences. Surface Water Storage and Drainage
11.26 The Surface Water Management Plan (SWMP) identifies that the flow of water from the settlements on higher ground to the west of Hull, both onto land and into the combined sewer system, has the potential to exacerbate surface water and sewer flooding in Hull. The SWMP promotes the use of aqua greens to reduce the risk of flooding. This idea was refined into the current three schemes: a partnership with Hull City Council and East Riding of Yorkshire Council. The aim of these schemes is to store surface water and slow its flow before it reaches the East Riding villages and Hull. These projects are underway and are of strategic importance to the city.
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You Told Us
There was a comment that the potential for ‘soft’ defences should be fully used.
Options
Option A: This option would involve not having a policy that referred to surface water storage schemes.
Option B: This option would have a policy of supporting the development of surface water schemes.
Option C: Have a combined surface water storage and flood management policy
Preferred Option
11.27 Option B.
Draft Policy 54
Surface Water Storage and Drainage
Strategic schemes for the storage of water will be supported where they are well designed and will be shown to improve the flood resilience of the city.
Justification
11.28 Option A is discounted. While it is acknowledged that much of this policy will be implemented outside the boundaries of the city, the issue of surface water storage is a pressing one in terms of improving the resilience of both Hull and the neighbouring settlements within the East Riding. This approach would also recognise the strategic importance of these schemes in defending large parts of the city, support those aspects of them that are within the city’s boundaries and provide a framework for any future schemes. It is also possible that the need for further schemes could be identified through the plan period and it is important that policy support is in place for this. Option C is discounted on both issues. They are significant in their own right and a combined policy would be overly complex. Sustainable Drainage
11.29 Paragraph 100 of the NPPF advises that Local Plans should include policies to manage flood risk from all sources.
11.30 Planning practice guidance contains detailed information on planning for sustainable drainage systems. These are designed to control surface water run off close to where it falls and mimic natural drainage as closely as possible. They provide opportunities to reduce the causes and impacts of
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flooding, removing pollutants from urban run-off at source and combine water management with green space with benefits for amenity, recreation and wildlife.
11.31 Planning practice guidance sets out a hierarchy for sustainable drainage where the aim should be to discharge surface run off as high up the following hierarchy as reasonably practicable:
1. Into the ground (infiltration)
2. To a surface water body
3. To a surface water sewer, highway drain or other drainage system
4. To a combined sewer
11.32 The guidance also advises that it would be helpful if local planning authorities could set out local situations where it is anticipated that particular sustainable drainage systems will not be appropriate.
11.33 When assessing sustainable drainage, the authority will need to be satisfied that proposed minimum standards of operation are appropriate and that there are clear arrangements in place for ongoing maintenance. The relevant flood risk management body should be consulted about sustainable drainage system measures. Guidance is produced on technical standards and also on what is reasonably practicable.
11.34 Hull is located on mainly clay and silt sub-soils. This can become rapidly waterlogged during intense or sustained rainfall. This means that while there is some potential for soakaways and filter drains to be used, extensive use of such measures will not be appropriate because of the poor ground permeability.
11.35 Surface water flooding can either pond, or flow across the surface. It can be hazardous because of its depth, velocity or its unexpected presence in areas with little warning. It is difficult to warn and prepare for surface water flooding as it is dependent on many factors; how empty the sewers are, gradients, how localised is the rainfall and how saturated is the ground beforehand. Heavy rainfall on saturated ground combined in 2007 and resulted in localised flooding.
You Told Us
There was strong support for the inclusion of sustainable drainage policies within the Local Plan. The policy should outline the SuDS hierarchy: SuDS, watercourse and only draining to sewer as last resort. Policy should restrict run-off rates to greenfield for undeveloped sites, and require a reduction in volume of flow to the sewer for previously developed sites to allow for climate change.
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Policy should ensure that where possible, SuDS schemes have the widest range of benefits such as (increasing) biodiversity and amenity. There needs to be agreement on how to solve conflicts with undertakers and agencies. There should be use of smaller areas which hold water all year round to slow down the flow of surface water, not just for large flood events. Policy should require conditions and obligations for new developments to include grey water recycling. Planning applications over a certain threshold should be accompanied by a site specific surface water management plan Policy should include the use of green roofs and wall given urban nature of Hull. Site specific policies should outline the type of SuDS would be appropriate and the amount of land required to ensure allocations are deliverable.
Options
Option A: Have no policy on Sustainable Urban Drainage in the Local Plan. This option would rely on the requirements to submit drainage information with planning permissions and follow national guidance.
Option B: Have a policy supporting sustainable drainage to be incorporated into development. This option would provide a policy which would highlight Hull's particular drainage issues.
Option C: Have a policy supporting sustainable drainage to be incorporated into development and the retrofitting of sustainable drainage where possible.
Preferred Option
11.36 Option C.
Draft Policy 55
Sustainable Drainage
1. All planning applications should provide sustainable drainage systems unless it has been demonstrated this is not technically or economically feasible.
2. Site development should account for the following:
Run-off rates for greenfield sites should not exceed 1.4 litres per second per hectare;
Run-off rates for brownfield sites should not exceed 50% of the current run-off rate;
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The on-site drainage system should be capable of storing water for the 1 in 75 year (1.33% annual probability) rainfall event;
The site should be capable of storing the water from a 1 in 100 year (1% annual probability) rainfall event;
A 30% allowance should be added to the above requirements to account for climate change and to ensure that the development is safe for its lifetime.
3. The drainage system should be designed that in the event of the system failing or the tolerances are exceeded, no surface water flooding is caused on or off-site.
4. Site layout should have regard to the relative flood risk and any existing features which could support sustainable drainage on site.
Justification
11.37 As has been demonstrated earlier in this chapter, Hull has a very specific set of local circumstances in relation to flood risk and drainage. Sustainable drainage will play an important role in future proofing the city and allowing for the most effective use of the existing infrastructure, which serves a wider area than just the city. It is on this basis that the criteria have been set in the policy. It is also considered that retro-fitting is vital, given that the majority of Hull is developed. It also highlights to developers that retro-fitting is possible and could encourage its incorporation where people are carrying out works that do not require planning permission.
11.38 A background paper explaining the options and preferred option rationale for the run-off rates and details in the above policy is available as part of this consultation and comments can be submitted regarding that document as part of this consultation. Flood Risk Zones
11.39 The Environment Agency provides maps which show land in Flood Risk Zones 1, 2 and 3. Planning practice guidance defines these zones as follows:
Table 11.1
Flood Zone Definition
Zone 1 Land having a less than 1 in 1,000 annual probability of Low Probability river or sea flooding.
Zone 2 Land having between a 1 in 100 and 1 in 1,000 annual Medium Probability probability of river flooding; or
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Flood Zone Definition
Land having between a 1 in 200 and 1 in 1,000 annual probability of sea flooding.
Zone 3a Land having a 1 in 100 or greater annual probability of High Probability river flooding; or
Land having a 1 in 200 or greater annual probability of sea flooding.
Zone 3b This zone comprises land where water has to flow or be The Functional stored in times of flood. Floodplain Local planning authorities should identify in their Strategic Flood Risk Assessments areas of functional floodplain and its boundaries accordingly, in agreement with the Environment Agency.
(Not separately distinguished from Zone 3a on the Flood Map)
11.40 Hull’s Strategic Flood Risk Assessment (Levels 1 and 2 for the whole authority area) was published in 2007 and is currently under review. This provided a detailed map of Flood Zones 1, 2 and 3. As approximately 95% of Hull fell within flood zones 2 and 3, it was agreed that Flood Zone 3 should be refined to allow for the sequential and exceptions tests to be applied. This approach has been used in the determination of planning applications since 2008 and the SFRA was a key evidence base document in the successful adoption of the Newington and St. Andrews Area Action Plan and the Holderness Road Corridor Area Action Plan. Prior to this, informal guidance developed by the Environment Agency and Hull City Council was used to lead and shape developments from 2003.
11.41 Flood Zone 3a was divided into hazard zones as follows:
Table 11.2
Flood Zone Definition
Zone 3a(iii): High Hazard Areas within flood zone 3a with defences that Zone have a predicted depth of over 0.6metres; Areas that flood during the 4% flood which are Areas that either have a not within the functional flood plain; high probability of flooding or have a severe consequence of flooding
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Flood Zone Definition
Areas with a severe or extreme flood hazard from defence breaches; and
Areas that have a high risk of surface water flooding (depth over 0.6m)
Flood Zone 3a(ii): All areas within Flood Zone 3a with defences Medium Hazard Zone Areas having a moderate (deep or fast flowing water) flood hazard from defence breaches; Areas that either have a and moderate probability of flooding (1% fluvial; 0.5% Areas that have a medium risk of surface water tidal where there are flooding (depths between 0.3m and 0.6m) defences) or have a moderate consequence of flooding (danger to some, e.g. children)
Some areas were placed into the high and medium hazard zones due to the risk of surface water flooding.
Zone 3a(i): Low Hazard Everything within Flood Zone 3a that is not in Zone the high and medium hazard zones and any areas with a low risk of surface water flooding (depths between 0.15m and 0.3m)
You Told Us
There was support for using locally defined flood risk zones but work would need to be prioritised. There was agreement that the function flood plain should not be developed unless it could be demonstrated it was appropriate.
Options
Option A: This option would use the information from the Environment Agency maps which locates the majority of the city within flood zone 3.
Option B: This option would use locally defined flood zones.
Preferred Option
11.42 Option B.
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Draft Policy 56
Flood Risk Zones
Development will be located and designed through use of the council's locally defined flood risk zones.
Justification
11.43 Option A is discounted. It would make the application of the sequential approach very limited in Hull given that the majority of the city is located within flood zone 3.
11.44 Option B is the preferred option. It allows for the sequential test to be applied in Hull. This means that more vulnerable uses can be located within the most appropriate locations, given the relative flood risk within Hull. It has been used for a number of years and is considered effective by the key stakeholders involved in water management.
11.45 This preferred option has been assumed as being taken forward in the following policy options and for site allocation purposes. Flood Risk Assessment, Sequential Test and Exception Test
11.46 Sites which are allocated in the Local Plan will have been subject to the sequential test and an exception test in accordance with the findings of the Level 2 SFRA as appropriate. However, the detailed layout of any proposal will need to take into account specific considerations such as levels and relative vulnerability within the site as well as have regard to sustainable drainage. Any identified requirements will be included within the allocation for each site.
11.47 However, over the lifetime of the plan, sites will come forward for development which have not been subject to the allocations process. It will be necessary for those sites to be supported by a detailed flood risk assessment and subject to sequential and exceptions tests.
11.48 The Strategic Flood Risk Assessment sets out locally defined standing advice for different types of development in different flood risk zones. This sets out when a flood risk assessment needs to be carried out, areas where compliance with defined finished floor levels and place of safety requirements are sufficient in place of a site specific flood risk assessment and the developments which require a sequential and exception test.
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11.49 This standing advice has been used since 2007 in determining planning applications. It is subject to regular review between the Council and the Environment Agency. As such, any policy approach which sought to make use of standing advice would refer to using the standing advice and not to the specific requirements which may change over the lifetime of the plan.
You Told Us
Support for use of locally determined standing advice Future proofing the city is vital 8 metre easement should be incorporated into new development to allow for inspection and maintenance of defences
Options
Option A: This option would require developers to justify applications as set out in planning practice guidance.
Option B: Require unallocated sites to submit sequential and exceptions test in line with Hull’s locally defined criteria
Preferred Option
11.50 Option B.
Draft Policy 57
Flood risk assessment, sequential test and exception test
Applications to develop sites not allocated or not allocated for development proposed must be accompanied and justified by a flood risk assessment, sequential and exception test as set out in the Council's locally defined standing advice.
Justification
11.51 Hull is particularly vulnerable to flood risk, and it is necessary for the appropriate level of consideration to be given to how developments will be designed to minimise this risk. The Strategic Flood Risk Assessment has considered the overall level of risk and identified appropriate mitigation for the majority of sites. Option B recognises Hull’s particular circumstances in relation to flood risk. It simplifies the process of flood risk assessment for developers, particularly for smaller proposals and would result in development occurring in the most appropriate places with the necessary flood precautions in place. This approach reduces cost and uncertainty for developers when preparing schemes and may help direct development to sequentially preferable sites.
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Flood Risk Assessments Areas of Search
11.52 Environment Agency guidance advises that areas of search will usually be over the whole of the Local Planning Authority (LPA) area but may be reduced where justified by the functional requirements of the development or relevant objectives in the Local Plan. For example, if a local need such as affordable housing or town centre renewal has been identified, this might mean that the geographical area of search is restricted to a specific regeneration area. Equally, in some circumstances it may be appropriate to expand the search area beyond the administrative boundary for uses that have a sub-regional, regional or national market.
11.53 The Strategic Flood Risk Assessment identified areas where development could be focussed. Recommendations 4 and 5 related to the city centre. While the City Centre Action Plan is no longer being progressed, and there is no longer higher level policy supporting the regeneration of Hull City Centre, the principles behind the regeneration of the city centre remain, and have been strengthened by the award of City of Culture status to the City. Furthermore, strategic planning now occurs through the duty to co-operate, and the Joint Planning Statement for Hull and the East Riding specifically recognses the importance of the regeneration of Hull City Centre, including housing.
You Told Us
Support for use of locally determined standing advice
Options
11.54 Option A: Do not specify areas of search within local plan policy and allow to be determined on a case-by-case basis
11.55 Option B: Specify areas of search within local plan policy
Preferred Option
11.56 Option B.
Draft Policy 58
Areas of Search
Developments located within the following areas will use the boundary of those areas for carrying out the sequential test
1. City Centre 2. Area Actions Plans
Outside of these areas, the area of search would be city wide.
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Justification
11.57 Option A would allow the greatest flexibility for developers when preparing flood risk assessments. However, it would mean that developers would have to justify their area of search and this could lead to increased work and delay if there are disagreements on what the area of search should be. It has the potential to add delay to the system should there not be agreement on the area of search, therefore Option B is the preferred option. The City Centre and Area Action Plan areas are all established priorities for the City, justifiying their selection. Water Quality
11.58 Planning Practice Guidance acknowledges that water supply concerns will vary depending on the character of the area, the issues facing the Local Plan and the contribution that can be made to a catchment based approach. A catchment based approach is one which promotes better understanding of the environment at the local level and which encourages local collaboration and transparent decision making when planning and delivering activities to improve the water environment.
11.59 In terms of water quality, it highlights that plan making may need to consider:
how to help protect and enhance local surface water and groundwater in ways that allow new development to proceed and avoids assessment at the application stage; and
types of development or locations where an assessment of the potential impacts on water bodies may be required;
Sustainable drainage systems (considered in a previous section).
11.60 Map 11.2 shows the areas of Hull which are designated as source protection zones. These zones are designated around public water supply abstractions and other sensitive receptors that signal there are particular risks to the groundwater source they protect. They are based on an estimation of the time it would take for a pollutant which enters the saturated zone of an aquifer to reach the source abstraction or discharge point. The protection of the aquifers is important because they play an important role in the environment and in drinking water supplies. If groundwater becomes polluted, it can be extremely difficult or impossible to clean and efforts to do so will be very expensive.
11.61 There are three zones found within Hull. The zones are defined as follows:
Inner Zone I is 50m from the abstraction point and the distance from where it would take 50 days for water to travel from below the water table to the abstraction point.
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Outer Zone II is based on the larger of a 400 day travel time or 25% of the catchment area. Source Catchment Zone III is the area needed to support the protected yield, effectively from rainfall.
You Told Us
Yorkshire Water suggested a reference to protecting the groundwater resource from potentially polluting new development as groundwater is abstracted from boreholes at Springhead. It was also mentioned that developers should be made aware of restrictions that could be placed either on certain types of development or ancillary development eg double lining foul sewerage serving new housing.
The Environment Agency noted that Hull's public drinking water supply comes entirely from groundwaters. The abstraction points are located within the East Riding, so this may be an area which should be considered through the duty to co-operate. Policies could be included which refer to the wider source protection zones.
It was commented by another respondent that these policies should not duplicate other controls and guidance should not hamper growth
Options
Option A: Include a policy in the Local Plan requiring the impact of development on the source protection zones to be considered in submitting and determining planning applications.
Option B: No policy needed and leave to Environment Agency to protect.
Preferred Option
11.62 Option A
Draft Policy 59
Water Quality
Development proposals must have regard to the presence of any groundwater source protection zones and demonstrate how this has been taken into account. Applications which have not been demonstrated to have considered the presence of source protection zones and in particular, demonstrated how the risk of pollution has been mitigated for, will not be approved.
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Justification
11.63 All of Hull's public drinking water supplies come from groundwater: its protection is therefore of vital importance, particularly given the immense challenges in dealing with contaminated groundwater. It is of use to developers to be made aware of this issue at the planning stage.
Map 11.2 Source protection zones
Water Supply
11.64 Paragraph 162 of the National Planning Policy Framework requires the local planning authority to work with water companies to assess the quality and capacity of infrastructure, including that for water supply and wastewater and its treatment, and its ability to meet forecast demands and any need for strategic infrastructure.
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11.65 The Infrastructure Study has considered water supply in Hull. It has identified that Hull receives water from more than one source and the Yorkshire Water has a supply grid which allows water to be transferred around the region. Yorkshire Water did not identify any issue with water supply in the Issues and Options consultation.
You Told Us
It was commented by another respondent that these policies should not duplicate other controls and guidance should not hamper growth
Options
Option A: Do not include a policy on water supply in the Local Plan.
Option B: Include a policy on water supply in the Local Plan.
Preferred Option
11.66 Option A is the preferred option.
Justification
11.67 Hull is an urban area with a well established network to supply water. No issues have been identified with water supply in the area: it was not specifically referred to by either Yorkshire Water or the Environment Agency in their response to the Issues and Options document. The proposed policy on protecting groundwater indirectly protects water supply. Waste Water
11.68 Paragraph 162 of the National Planning Policy Framework requires the local planning authority to work with water companies to assess the:
quality and capacity of infrastructure for water supply; quality and capacity of infrastructure for wastewater and its treatment; and ability to meet forecast demands; and any need for strategic infrastructure.
11.69 Planning Practice Guidance highlights that plan making for waste water may need to consider:
identifying sites for new or enhanced infrastructure; considering whether new development is appropriate near to sites for water and wastewater infrastructure; and phasing new development so that the necessary infrastructure will be in place when required.
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11.70 Planning Practice Guidance also states that wastewater must be considered by Waste Planning Authorities when preparing its Waste Local Plan. Wastewater treatment plants are classed as waste developments.
11.71 The Infrastructure Study considered waste water treatment. Waste water from Hull and the surrounding area is treated at the Hull Waste Water Treatment Works, located just outside the City's administrative boundary at Saltend. Yorkshire Water have no planned water supply or waste water treatment upgrades planned between now and 2020.
11.72 The Saved Local Plan has two policies regarding the siting of waste water treatment plants and development near to waste water treatment plants. This was in response to the EU Directive on Urban Waste Water which was placing additional requirements regarding waste water treatment which had to be in place by the year 2000.
You Told Us
Yorkshire Water supported the inclusion of a policy regarding wastewater treatment.
It was also suggested that the Local Plan should make it clear that large housing developments may have to be phased to allow for delivery of essential waste water and water infrastructure. It is likely that other types of infrastructure would also require a phased approach and so it is essential that the phasing model reflects the interests of all infrastructure providers.
It was commented by another respondent that these policies should not duplicate other controls and guidance should not hamper growth
Options
Option A: Do not include a waste water specific policy within the Local Plan
Option B: Include a policy on waste water within the Local Plan
Preferred Option
11.73 Option A is the preferred option.
Justification
11.74 While Yorkshire Water have indicated they would like to see the Local Plan include a policy regarding waste water treatment, they have not provided any information as to what the aim of that policy should be. The Infrastructure Study has not indicated any issues with the infrastructure which need addressing. The issue will also be considered through the preparation of the Joint Waste Local Plan and it is considered that is the most appropriate place to do so.
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Supporting Evidence
Sustainability Appraisal Objectives
2. Maintain and enhance water quality and limit water consumption to levels supportable by natural processes and storage systems, taking into account the impact of climate change
3. Ensure that new development does not increase flood risk and protects or enhances the capacity & integrity of flood storage areas
6. Ensure that development is capable of withstanding the effects of climate change
Sustainability Appraisal Working Paper Comments
Currently the flood risk chapter includes an option to include policies on sustainable drainage solutions for residential buildings. Consider extending the concept to commercial and industrial buildings.
In addition to known flood risk management measures from tidal and fluvial flooding, consider attenuation of surface water run-off related flood risk at residential and commercial buildings and at car parks where occurrence of impermeable surface will be high;
Main Evidence Base Sources
Hull Strategic Flood Risk Assessment
Hull Surface Water Management Plan
Hull Local Flood Risk Management Strategy (draft)
Drainage Impact Assessment Guide
Planning for the Rising Tides: Humber Flood Risk Management Strategy (March 2008)
River Basin Management Plan Humber River Basin District
River Hull Integrated Catchment Strategy
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12. Open Space Introduction
12.1 The Town and Country Planning Act 1990 defines open space as “any land laid out as a public garden, or used for the purposes of public recreation, or land which is a disused burial ground.” The National Planning Policy Framework describes open space as: “open space of public value, including not just land, but also areas of water (such as rivers, canals, lakes and reservoirs) which offer important opportunities for sport and recreation and can act as a visual amenity.” The National Planning Practice Guidance (NPPG) adds: “[open space] can take many forms, from formal sports pitches to open areas within a development, linear corridors and country parks.”
12.2 Open spaces are important for health, not only in terms of their use for physical activity. Good quality accessible green spaces are also linked to positive mental health benefits and can support community cohesiveness. Public Health have identified that there is growing evidence suggesting that health inequalities between the most and the least deprived groups are reduced where there is improved access to greenspace. It also links to the Health and Wellbeing Strategy outcome of healthier, longer, happy lives: one of the actions is to create an environment that promotes physical activity and active transport in everyday settings for all ages.
12.3 It should be noted that the terms “green space” and “open space” are often used interchangeably, however they are slightly different. Green space includes all areas that are green, whereas open space tends to define areas that have public value which may or may not be green. The main difference is that open space includes “civic space”, which are hard surfaced areas that have community value, usually found in the city centre. This section will focus on open space, i.e. areas of public value, and the remaining green space issues will be handled by the following section on the Natural Environment. However, it should be noted that the saved Local Plan (2000) used the term “Urban Greenspace”, and therefore both terms are used in this section.
12.4 Hull City Council continuously updates its inventory of open space sites. The saved Local Plan (2000) identified all areas of Urban Greenspace that were 0.25 hectares or greater. It showed 376 existing sites on its Proposals Map plus 13 new sites. The existing sites covered just over 1,500 hectares and the new sites covered another 115 hectares. The latest list of sites is published in the Open Space & Natural Environment Review (November 2014). A key addition to the inventory is the inclusion of smaller sites (0.1 ha and greater). This has meant that the list has grown substantially, with 892 sites identified within the city boundary, covering over 1,670 hectares.
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12.5 Hull City Council also owns and maintains a number of sites just outside the city boundary. In addition, some larger sites (such as Springhead Golf Course) span over the city boundary. We recognise that many of these sites are important to Hull residents. However, the Hull Local Plan can only influence land within the city boundary. Areas of land outside the boundary are excluded from this discussion because as far as the planning regime is concerned, they fall under the control of the East Riding of Yorkshire Council but they still play a key role in meeting the needs of Hull residents. Designating and allocating open space sites
12.6 The table below describes the different site categories identified by the Open Space & Natural Environment Review (November 2014). The descriptions are a guide because it can be argued that some sites fall into more than one category. In those cases they are either split into multiple parts or the most appropriate category is used. A few categories of open space have changed since the saved Local Plan (2000) and these changes are noted in the description column. In particular, “Civic spaces” are now included. As they are hard-surfaced areas, they are not counted under the older term “greenspace”, but come under the broader term ‘open space’.
Table 12.1 Summary of open space types in Hull
Type Description Total
Agricultural Commercial farmland for growing crops or 250 land grazing livestock. In Hull this includes a few fields hectares on the eastern edge of the city.
Allotments Opportunities for residents to grow their own 55 hectares produce. Includes urban farms. Does not include private gardens.
Amenity green Green spaces for informal recreation set around 187 space housing areas. hectares
Cemeteries & Includes disused churchyards and other burial 67 hectares churchyards grounds.
Civic spaces Hard surfaced areas that have community value. 16 hectares Generally located within or near to the city centre. Not included in the saved Local Plan (2000).
Educational Land belonging to a school or college. Generally 222 grounds consist of areas for formal sport, informal play, hectares landscaping and nature conservation. For safety and security reasons they are usually locked up and made inaccessible to the general public. Often schools allow community use of the sports facilities for a fee but this cannot be guaranteed.
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Type Description Total
Green corridors Includes rivers, drains, cycleways, rights of way 200 and disused railway lines. Described as “Other” hectares in the saved Local Plan (2000).
Natural and Includes publicly accessible woodlands, forestry, 233 semi-natural scrub, grasslands, wetlands and wastelands. hectares green spaces Described as “Other” in the saved Local Plan (2000).
Outdoor sports Natural or artificial surfaces either publicly or 251 facilities privately owned used for sport and recreation. hectares They include:
pitches / playing fields tennis courts and bowls greens golf courses athletics tracks
Described in the saved Local Plan (2000) as “Public playing field/play area”, “Private pitch” or “Golf course”.
Parks and Includes urban parks and formal gardens. Usually 140 Gardens contain a variety of facilities, and may have one hectares or more of the other types of open space within them.
Private grounds Generally large private grounds and gardens 23 hectares that, because of their size, offer some sort of wider nature or amenity value.
Provision for Usually described as playgrounds or play parks. 7.6 children Areas designed with equipment primarily for play hectares and social interaction involving children below aged 12. Included under the category “Public playing field/play area” in the saved Local Plan (2000).
Provision for Areas designed with equipment primarily for play 5.6 young people and social interaction involving young people hectares aged 12 and above. Examples include: teenage shelters skateboard parks BMX tracks Multi Use Games Areas. Included under the category “Public playing field/play area” in the saved Local Plan (2000).
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You Told Us
Broad agreement with sites shown on the Issues and Options Evidence Map. General support for showing smaller sites (down to 0.1 ha) as these allow better connectivity across the green network. One comment that we should show community growing spaces as well as allotments. Suggestion that land to the rear of Punch Bowl Pub, James Reckitt Ave could be an allotment site. Recommendations that employment land to the east of green space site 1 should be protected as green space as it has a high wildlife value. The following proposed housing sites should be retained as green space:
Land at Goddard Ave (212) Former Dane Park Primary School (721) Land NW of Sutton Park Golf Course (862) Land North of Heartlands Park (805)
Comments regarding improving the connectivity of the following green space sites:
Site 111 extended eastwards along cycle track to join site 728, then Barmston Drain, continuing to River Hull. Continue Foredyke Stream cycle track (site 179) northwards to join greenspace site 237. Sites in the Old Cottingham Drain area need to be joined together better (sites 94, 95, 97).
Options
Option A: In this option, the Policies Map would include similar sites to those in the saved Local Plan (2000) which showed “urban greenspace” sites down to 0.25 hectares. If this size threshold is applied, then it would filter out many of the smaller sites identified in the Open Space & Natural Environment Review (November 2014). The saved Local Plan criteria would also exclude Civic Spaces.
Option B: In this option, the Policies Map to include all sites identified by the latest Hull City Council survey of open space sites. As explained above, the Council continuously updates its inventory of open space sites, with the latest snapshot published in the Open Space & Natural Environment Review (2014). The aim is to identify all sites down to 0.1 ha using the categories described in Table 10.1 above. This would add a lot more smaller sites than were identified by the saved Local Plan (2000). It would also add Civic Spaces, which are not green but are a type of ‘open space’. It should be noted that some of the smaller sites may be difficult to identify clearly depending on the scale of the Policies Map.
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Option C: In this option, the Policies Map would only include sites that meet a particular definition of open space. The first paragraph of the introduction to this section lists the definitions of open space published by the Government in legislation, the NPPF and the NPPG. The definitions offer various examples, but can probably be summarised down to “land or water of public value”. It could be argued that not all the 892 sites on our database can be said to meet these definitions of open space. We could potentially exclude several categories such as agricultural land and private grounds, and perhaps even educational grounds.
Option D: In this option, the Policies map would allocate the former employment land site to the east of Urban Greenspace site 1 as Potential Urban Greenspace site 1. This will create a large continuous area of natural / semi-natural green space along the western part of the Humber foreshore.
Map 12.1 Potential urban greenspace allocation
Option E: In this option, the Policies Map would not identify open space sites. With almost 900 potential open space sites on the database, there is a risk that we have missed some. We could avoid this problem by choosing not to identify existing open space sites on the Policies Map. Sites could still be protected by a criteria-based policy, which would take into account their past/present use. At present, policy NE2 of the saved Local Plan (2000) does this for greenspace sites smaller than 0.25 ha. However, it should be noted that showing sites on a map gives a higher degree of certainty to developers and residents.
Preferred Option
12.7 Options B and D. Urban Greenspace, Potential Urban Greenspace, and Civic Space sites are shown on the Policies Map (Part 2) and in more detail in the Area Designations document (Part 4). Part 4 also includes a schedule of all of the sites identified by the Open Space & Natural Environment Review (November 2014), and where sites have not been included on the Policies Map, then an explanation is given. Reasons for not including sites is because they fall outside the city boundary, fall within the Kingswood AAP boundary, or because they have been allocated for an alternative use.
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12.8 It should be noted that the following amendments have also been made following responses to our previous consultation.
Cycle track Site 728 has been extended from Station Drive to Wilncolmlee – helping link site 111 at Beverley Road to Barmston Drain and the River Hull. Green corridor Site 767 running between Brunswick Ave and Liddell Street has been added – this helps links together sites 94, 95 and 97. Site 179 has been extended north to Leads Road and green corridor site 955 has been added, running between Leads Road and Humburg Road.
Justification
12.9 Hull is a densely built urban area with a limited amount of open space. Some sites are under pressure to be built on by developers but need to be protected wherever possible because open space sites are difficult to replace. Even privately owed sites that are not publicly accessible have value because they benefit wildlife by providing habitat and linkages between sites, and help improve the built environment by absorbing surface water, air-borne pollutants and noise, and provide visual amenity and urban cooling.
12.10 The decision to allocate the former employment land site as Potential Urban Greenspace site 1 (Option D) has been made because limitations of the highways network mean that the site is undevelopable for most other uses. In our previous consultation, wide support was expressed to allocate the site for Urban Greenspace because of the potential benefits for wildlife, particularly as the site is immediately adjacent to the Humber Estuary, which is a European site. Open space standards
12.11 Paragraph 73 of the NPPF states:
Planning policies should be based on robust and up-to-date assessments of the needs for open space, sports and recreation facilities and opportunities for new provision. The assessments should identify specific needs and quantitative or qualitative deficits or surpluses of open space, sports and recreational facilities in the local area. Information gained from the assessments should be used to determine what open space, sports and recreational provision is required.
12.12 The National Planning Policy Guidance adds: “It is for local planning authorities to assess the need for open space and opportunities for new provision in their areas.”
12.13 Hull City Council is currently implementing the standards set out in policies NE5 and NE6 in the saved Local Plan (2000). These are described in Option A, below.
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12.14 Hull City Council published the Open Space, Sport and Recreation Assessment in 2009. This was a thorough study of open space and how it is used in the city. The main aim of the study was to form a key part of the planning policy evidence base. As such, it was successfully used as supporting evidence for both the Newington and St Andrew’s AAP and the Holderness Road Corridor AAP. One of the key recommendations of the 2009 Assessment was a set of open space standards. The quantity and accessibility aspect of these are printed under Option B below. The quantity standards were based on average levels of open space provision across the city. They therefore act as a benchmark – inevitably some areas of the city will have levels of provision above these standards and others will be below.
12.15 The Open Space & Natural Environment Review (November 2014) compares the existing levels of provision against the recommended quantity and accessibility standards to produce a series of maps. These maps highlight areas of surplus and deficit for different types of open space based on where people live.
12.16 However, simple analysis using the citywide open space standards has its limitations. We are aware that levels of demand may vary across the city – for instance, areas that are densely built with smaller gardens are likely to have greater demand for public open space and allotments. Despite these limitations, the standards can still be useful. They can indicate how much open space should be provided to support new residential development. They can help justify improvements (either in terms of quantity or quality) in areas that appear to have a deficit. And in areas that appear to have a surplus, further consideration needs to be given to whether the open space sites are underused, and if so, why. Ultimately, if open space sites are deemed to be surplus to need, and there is no prospect of them being required to provide for latent demand, then it may be appropriate to allocate them for an alternative use.
12.17 We recognise that the 2009 Assessment is now 6 years old. As a result, the Council has prepared Open Space update reports for 2013 and 2014. The aim of these is to provide up-to-date snapshots of the current levels of open space provision. The latest information on open space sites, collected as part of these position statements, can be compared to the recommended open space standards from 2009. The quantity standards are expressed in terms of hectares per 1000 people, which allowed the 2009 Assessment to estimate how much open space would be required for different growth scenarios. Consequently, it is a simple exercise to substitute the population figures used in the 2009 Assessment with the latest ONS estimates and our latest set of growth scenarios. Notably, the latest ONS population estimate is just over 257,000, which is only a 1,000 more than that used in the 2009 Assessment. In addition, analysis of the population profile of the city over the last few years shows there has been little change. With this in mind, we believe that the standards recommended in the 2009 Assessment are still applicable and form a sound basis for plan making.
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You Told Us
Several respondents agreed that the standards set in the 2008/9 study should be used. However, some added that they should be seen as minimum standards. Sport England suggested that the Open Space study and Playing Pitch Strategy are both out of date and need reviewing. Yorkshire Wildlife Trust suggested that the proposed standards were well below Natural England’s ANGSt guidelines. Where possible, open space should be multi-functional, delivering multiple benefits. Areas of natural/semi-natural space in or near to the city centre are desireable. Allotment demand statistics should be used when planning new allotments, instead of a blanket citywide standard. Brownfield sites should be recognised as important semi-natural habitats.
Options
Option A: This option would retain the standards set in policies NE5 and NE6 of the saved Local Plan (2000). The standards are:
Type Quantity (Policy NE6) Accessibility (Policy NE5)
Urban Greenspace 60 sqm per dwelling 800 metre walking distance
Children’s play area 3 sqm per child bed space 250 metre walking distance
Paragraph 6.36 of the saved Local Plan explains that the quantity standard takes into account density of housing and is sensitive to the number of children likely to live in the area. The standard only includes publicly accessible areas of urban green space, for example, play areas, public parks and amenity areas. The standards have been adapted from the 6-Acre Standard, which was promoted by the National Playing Field Association (now known as Fields in Trust). The standards set out in the saved Local Plan have been applied to new residential development for the last 15 years.
Option B: This option would adopt the quantity and accessibility standards recommended by the Open Space, Sport and Recreation Assessment (February 2009). These are as follows:
Type Quantity standard Accessibility standard
Allotments 0.24 ha / 1000 people 20 minute walk
Amenity green space 0.67 ha / 1000 people 10 minute walk
Children's play facilities 0.03 ha / 1000 people 10 minute walk
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Type Quantity standard Accessibility standard
Natural / semi-natural 0.62 ha / 1000 people 20 minute walk greenspace
Outdoor sports & 1.68 ha / 1000 people 20 minute walk to tennis, education grounds bowls and synthetic pitches;
15 minute walk to grass pitches;
20 minute drive to athletics tracks and golf courses
Parks / public gardens 0.50 ha / 1000 people 20 minute walk
Young people's facilities 0.023 ha / 1000 people 15 minute walk
The standards were based upon levels of provision in 2009 and then adjusted following analysis of an extensive household survey.
Option C: This option would be to undertake another study to produce a new set of open space standards. A new study, on the same scale of the 2009 assessment, would, from past experience, be costly and time-consuming. It would therefore risk setting back the production of the Local Plan. There is no compelling evidence to suggest that the findings of a new assessment would be radically from the 2009 assessment since, as mentioned above, the demographic of the city has changed little since 2009.
Option D: This option would be to adopt another organisation's open space standards. Some organisations promote their own set of standards, such as Natural England’s ANGST standard, or the Fields In Trust 6-Acre standard. The difficultly with national standards is that they do not take into account local circumstance. Hull is a highly built up area with a tight administrative boundary. The application of national standards is therefore not always helpful and goes against national planning policy, which requires policies to be based on local needs.
Preferred Option
12.18 Option B.
12.19 In addition, the policy requiring new public open space needs to be considered in order to appreciate how the standards would be applied.
Draft Policy 60
Open Space Standards
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The City Council will aim to deliver open space provision across the city that at a minimum meets the standards set by the latest assessment of local needs. This will be done by improving existing open space and the creation of new open space (see the Site Allocations document and the Policies Map for details).
Justification
12.20 Open space, sport, recreation and play facilities are important to the quality of place and to people’s overall wellbeing. They provide relief from the built form, provide a venue for exercise, play and the exploration of nature, and are important for the adaptation to and mitigation of climate change. For these reasons, they make an essential contribution towards sustainable development in the city.
12.21 It is difficult to compare directly the standards in Option A to those in Option B. However, we can make an approximate comparison of the quantity standard if we make a couple of assumptions. For Option A, if we assume an average of two child bed spaces per dwelling, then that equates to a total of 66 sqm per dwelling. For Option B we get 3.76 ha / 1000 people if we add together all the quantity standards in the table above. Then if we assume 2.2 people per household (the Hull average), this equates to 83 sqm per dwelling. Although this is higher, it includes allotments and natural/semi-natural greenspace, which were not included in the old standard set out in Option A. If these two categories are removed from the equation then the two standards are very similar.
12.22 In order to mitigate the effects of population growth, new open space will be created or existing open space improved to serve new housing. This provision should meet the standards outlined in Option B. Open space improvements will be funded through planning gain. Traditionally this has been in the form of Section 106 agreements, but the Council is looking to fund open space improvements through the proposed CIL tariff.
12.23 Option B is also based on the most up-to-date survey. Protecting open space
12.24 Hull is highly urbanised, land is in short supply and there are many competing demands for it. New development can provide benefits to the city, such as housing, employment and community facilities. It should therefore be considered in what circumstances, if any, it might be justified to lose open space sites to new development. And when it is deemed acceptable to develop on an open space site, what should be required (if anything) in return? Should we always require replacement open space, or are there circumstances where improving existing open spaces is sufficient?
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12.25 Paragraph 74 of the National Planning Policy Framework states: “Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:
an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.”
12.26 Hull City Council is currently implementing policies NE1, NE2 and NE3 of the saved Local Plan (2000). The saved Local Plan policies should be read together to understand fully how urban greenspace sites are currently protected. However, they differ significantly to paragraph 74 of the NPPF. Policy NE1 states that designated sites (0.25 ha and greater) should not be lost in the following circumstances:
loss of sporting or recreation facilities; an adverse effect on nature; the loss of a link between other Urban Greenspaces; or an adverse effect on the amenity or character of an area, in particular the loss of an important view or sense of openness.
12.27 Policy NE2 states that development on smaller greenspace sites (under 0.25 ha) will not be allowed if it “would have a significant adverse effect on urban greenspace value.”
12.28 Notwithstanding the protection afforded by policies NE1 and NE2, policy NE3 states that “the development of Urban Greenspace will be allowed if an overriding justification is demonstrated.” Paragraph 6.28 explains that this might be if a proposed development has overriding environmental, social or economic benefits.
12.29 The decision maker has to decide on a case-by-case basis whether the wider benefits of the development significantly outweigh the presumption for protecting open space sites in the city. When a decision maker is satisfied by the argument for development, then policy NE3 states that it will be necessary to:
replace it within the locality with a site of equivalent community benefit; or improve an existing Urban Greenspace within the locality to provide equivalent community benefit.
12.30 Paragraph 6.29 explains that improvement of existing open space would typically be chosen when there are no opportunities for creating new open space in the locality.
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You Told Us
12.31 With regards to protecting open space:
Support for the current approach set out in the saved Local Plan (2000) Support for no net loss of existing sites – given that open space provision in Hull is low. Support for loss only in exceptional circumstances Policy should be consistent with the Sport England playing fields policy exceptions – require robust evidence to demonstrate that a site is surplus before it can be redeveloped. Support for a net gain for nature involving all open space sites protected and any losses compensated. Support for a criteria-based policy for the protection of biodiversity sites. Protect sites that meet Local Wildlife Site criteria even though they have not been formally designated.
12.32 With regards to compensation for loss of open space:
Support for creation of equivalent open space. Support for improving nearby open space. Should be on a case-by-case basis so as not to create unwanted space. If open space is lost to development, then we should insist on things like green roofs on the development. Need for an up-to-date evidence base to know which sports sites are surplus and which require improvement. New sites require long-term maintenance and management.
Options
Option A: This option is for a similar approach to protecting sites from development as that set out by policies NE1, NE2 and NE3 of the saved Local Plan (2000). These policies are described in the introduction above. In summary, they protect green space sites from development unless an overriding justification is demonstrated. If a justification for developing a site is successfully demonstrated, then replacement or improvement of existing green space will be required in all circumstances.
Option B: This option would adopt the approach set out by paragraph 74 of the NPPF. In summary, development will not be allowed on open space except:
1. when the open space is surplus to requirements; 2. the lost open space would be replaced by equivalent or better provision; or 3. the development is for alternative sports and recreational provision.
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In this option, the most up-to-date and appropriate set of open space standards should be used (these are set out in Option B in the section above). (Sport England methodology could be used for built facilities.) This policy would ensure minimum levels of open space are preserved across the city, while allowing needed development to go ahead.
The policy text would be similar to paragraph 74 but would add that population growth (as planned for by the Local Plan) should be considered, and that re-use of the site to address all types of open space deficit should be considered.
Option C: In this option, there would be no policy specifically protecting sites. Open space, sports and recreational buildings and land that are not protected by other parts of the Local Plan (for example, the Green Network and the Local Wildlife Sites policy) are not afforded protection beyond what they receive from national planning policy and legislation.
Preferred Option
12.33 Option B
Draft Policy 61
Protecting open space
Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:
An assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements, including consideration of population growth over the plan period. The assessment should fully consider the potential to re-use the site to address deficits for all types of open space in the area; or The loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or The development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.
Justification
12.34 The proposed policy is considered to be NPPF compliant. New public open space requirements
12.35 Policy NE6 of the saved Local Plan (2000) currently requires all new residential development to provide new “publicly accessible urban greenspace”. The standards are described above in Option A of Open Space Standards section.
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12.36 Policy NE6 goes on to state that if the standards cannot be achieved on site, then improving existing greenspace or creating new greenspace nearby will be required. Paragraph 6.38 explains that this could be where the size of the new development makes it impractical to provide greenspace. Small developments (e.g. fewer than 50 dwellings) only require a small area of greenspace. Individually these small areas of greenspace are of little value and are costly to maintain. In such cases it is usually better to collect financial contributions from several developments and use them to create and/or improve larger areas of greenspace. This has operated through the Section 106 (S.106) ‘planning obligations’ system.
12.37 From April 2015 local authorities cannot pool from more than five separate S.106 agreements. This presents a problem as Hull City Council currently pools all S.106 payments for greenspace. To get around this limitation, the Council is intending to adopt a Community Infrastructure Levy (CIL) charging schedule, and use the proceeds to improve public realm and open space provision across the city. This leaves the question whether we should still require on-site open space, and if so, in what circumstances and how much?
12.38 It should also be noted that policy NE7 of the saved Local Plan (2000) requires urban greenspace for non-housing development “if appropriate”. The policy does not provide any more detail. Paragraph 6.41 explains:
Publicly accessible Urban Greenspace and children’s play areas will probably not be appropriate in commercial or industrial development and therefore the priority will normally be to improve the appearance of the area or safeguard or strengthen the nature conservation value of part of the site. In many cases, Urban Greenspace fronting onto the main road would therefore be appropriate. Tree planting and associated landscape treatment can significantly help a new development blend into its surroundings. Suitably landscaped areas will normally be required on all non-housing developments.
12.39 Given that this section is focused on open space of public value, the requirements of policy NE7 are probably best handled by the following section on the Natural Environment, which deals with green infrastructure and biodiversity, and by the Design section.
Options
Option A: This option would be to adopt a policy similar to saved Local Plan policy NE6 and require all new residential development to provide on-site public open space. Policy NE6 requires all new residential development to provide “publicly accessible urban greenspace”. When it is not possible to provide this on site, then the developer pays Section 106 money towards improving greenspace near to the site. As explained above, this blanket requirement that applies to all sizes of development could be difficult to implement when the pooling of Section 106 money is limited. In addition, the policy risks delivering new open space in areas that already have a surplus of open space.
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Option B: With this option, the policy would specify a minimum number of dwellings needed on a development before on-site open space is required. This should avoid the problems of either producing lots of small open space sites or collecting small amounts of Section 106 money that cannot be pooled.
As an example, suppose we wish to ensure that the minimum size of an Amenity Greenspace is 1,000 sqm (0.1ha). If we take the requirement for 0.67 hectares of Amenity Greenspace per 1000 people and assume an average of 2.2 people per household, then the development will have to be at least 67 dwellings. Alternatively, we could combine several of the categories in order to create a pocket park with a range of features. If we combine the quantity requirements for Amenity Greenspace, Parks, Children’s Play Facility and Young People’s Facility and aim for a minimum size of 2,500 sqm (0.25ha), then we would require 100 dwellings.
It should be noted that smaller developments that fall under the threshold would still contribute to improvements in open space provision by paying the Community Infrastructure Levy.
Option C: Whereas saved Local Plan policy NE6 always requires a fixed amount of greenspace per dwelling, this option would first require an assessment of nearby open space provision. The assessment would use the latest open space standards to determine whether there is a quantitative surplus or deficit of open space in the locality, both before and after the development is built. If in either case there is a deficit, then new open space should be provided on-site. In cases where there is a quantitative surplus, then the developer may still have to pay Section 106 towards the improvement of nearby open spaces.
The advantage of this option is that it avoids creating new open space in areas where it is not needed. This is important in a city which has a limited land supply. The disadvantage is that the calculations required for each development can be complicated. It therefore adds complexity to the planning permission process and creates uncertainty for developers. To mitigate this problem, the policy could have a minimum size threshold (e.g. 100+ dwellings), as explained in Option B.
Option D: In this option, the Council does the work outlined in Option C for each potential housing allocation as part of the Local Plan's preparation. The allocations section of the new Local Plan then specifies how much on-site open space is required to address local deficits. As a condition for developing a site, developers will be expected to deliver the specified quantity of open space on site.
The advantage of this option is that once the plan is adopted it is easier to implement. It also provides greater certainty to developers by making it clear how much of each site should be public open space. The disadvantage is that the requirements for on-site open space risk going out of date after the plan’s adoption. This could easily happen if there is a change in open space provision nearby. This approach would also not require any on-site provision from windfall sites. However, there are unlikely to be many windfall sites that are 100+ dwellings.
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Option E: This option would be to not require on-site public open space. This option avoids the complexity of the other options. The Council still makes improvements to open space using money collected through the Community Infrastructure Levy, which is charged to all new residential development. However, this option risks creating large residential developments without any on-site open space. In order to deliver the all the plan’s visions and objectives, high quality publicly-accessible open space should be integral to the design of residential development.
Preferred Option
12.40 Option D
Justification
12.41 The pros and cons of each option are outlined above. We consider that Option D is the best option as it creates certainty both for where new open space will be provided in order to meet assessed demand, and also provides developers with the implications of developing each site in an upfront and transparent manner. Supporting evidence
Sustainability Appraisal Objectives
1. Protect and enhance habitats and biodiversity. Improve connectivity between sites and prevent habitat fragmentation.
2. Maintain and enhance water quality and limit water consumption to levels supportable by natural processes and storage systems, taking into account the impact of climate change;
6. Ensure that development is capable of withstanding the effects of climate change;
7. Achieve good air quality;
11. Conserve and enhance the landscape and townscape, encouraging local distinctiveness;
12. Encourage healthy lifestyles and reduce the health impacts of new developments;
16. Enhance community identity and participation;
Sustainability Appraisal Working Paper Comments
Consider including explicit directions to small developments on the requirement to community infrastructure levy contribution should the development result in loss of open spaces.
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Main Evidence Base Sources
Hull Open Space & the Natural Environment Review (November 2014) Hull Open Space, Sport and Recreation Assessment (PMP, February 2009) Hull Playing Pitch Strategy 2011-2021
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13. Natural Environment Introduction
13.1 Although Hull is predominantly an urban area, the natural environment within the city boundary is seen as important and worthy of protection. The Ministerial foreword to the NPPF says that "our natural environment is essential to our wellbeing". One of the 12 core planning principles in the NPPF is to "contribute to conserving and enhancing the natural environment".
13.2 Much of Hull's natural environment is covered by open space designations (see previous chapter). This section will focus on the benefits of connecting open space sites into a cohesive network, and the protection and enhancement of wildlife habitat and species. It also provides a policy relating to trees, as tree protection and planting is seen as an important priority for Hull. Planning positively for green infrastructure
13.3 NPPF describes green infrastructure as “a network of multi-functional green space that is capable of delivering a wide range of environmental and quality of life benefits for local communities.” Paragraph 114 states that local planning authorities should “[plan] positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure”.
13.4 Benefits that green infrastructure can deliver include: improving health and wellbeing; enhancing biodiversity; helping to mitigate and adapt to climate change; providing business and educational opportunities; encouraging tourism; and promoting sustainable use of scarce land resources.
13.5 Green infrastructure should be designed to be multi-functional. A single piece of land can offer opportunities for play and adventure, store water during heavy rainfall, provide habitat for wildlife, and improve residential amenity by offering high quality landscaping that complements the built environment.
13.6 The saved Local Plan (2000) includes a citywide Green Network. Saved policy NE13 protects sites that are part of the Green Network from development that adversely affects the Network’s continuity and value. The Green Network includes linear features such as the river, estuary, drains and railways along with adjoining areas of Urban Greenspace. The main aims of the Green Network are to provide a refuge for wildlife and to connect wildlife areas with the surrounding countryside. In addition, it was recognised that the Network had the potential to provide pedestrian and cycle routes into and out of the city.
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13.7 In 2009, Natural England facilitated the mapping of green infrastructure (GI) across the Humber sub-region. The work identified green corridors and counted the number of GI functions that each corridor was likely to deliver. Based on the corridor’s size and number of functions, they were categorised as either of regional, sub-regional, district, or local importance. The corridors, as they relate to Hull and its immediate surroundings, are shown in the map below.
Map 13.1 Natural England Green Infrastructure corridors
13.8 The map shows that many of Hull’s GI corridors link up with the surrounding East Riding. Hull has one regional corridor, the Humber, which runs along the southern edge of the city. This is already protected by national and European legislation (see next section). Hull has two sub-regional corridors. The first of these is the River Hull & Holderness Drain corridor. This comes to the northern edge of the city as a single wide corridor and then splits into two, following the River Hull and the Holderness Drain separately. The other sub-regional corridor is called South Holderness, and comes into the east of the city following the disused Withernsea railway line. One district corridor, called ‘Priory Fields – Walkington’, comes to the western edge of the city at Springhead Golf Course. The remaining corridors were all considered of local importance. ‘Local’ GI corridors were not published on the final version of Natural England’s map for Yorkshire and the Humber. Instead, local authorities were encouraged to consider including them in their Local Plans, particularly where they link to more strategic corridors. It should be noted that some of the corridors highlighted in the map above are obstructed by buildings, roads and walls and the green spaces within them are highly fragmented.
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13.9 The next map is an alternative suggested basis for creating a new Green Network for the city. It shows all the rivers, drains, and railway lines that run through the city, along with other green corridors and highlights broadly where the open countryside outside the city boundary lies. For information purposes, it shows the Green Network as it is proposed within the Kingswood AAP boundary.
Map 13.2 Potential basis for Green Network
13.10 There are many ways to improve green infrastructure. The Local Plan’s open space policies (see previous section) are obviously important for protecting open space sites. The Council also has a Rights of Way Improvement Plan and a Local Transport Plan, both of which seek to improve walking and cycling routes. Managing flood risk is a key priority for Hull. The Council is investigating more natural solutions, such as using ponds and swales to store flood water (see the Flood Risk section). The Council works with the Yorkshire Wildlife Trust to help design and manage some of its best nature sites. A key aim of the work is to improve the connectivity of each site to its surroundings to allow wildlife to migrate more effectively.
13.11 East Riding of Yorkshire Council has prepared a Local Plan which also includes a map showing Natural England’s Green Infrastructure corridors. It also includes a policy for “strengthening green infrastructure” that requires new development within or near to one of those corridors to enhance the functionality and connectivity of the corridor. As noted above, many of Hull’s green corridors connect to the surrounding East Riding. As we have a duty to cooperate with neighbouring authorities on planning issues that cross
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administrative boundaries, we should aim to produce a similar policy that helps improve the green infrastructure corridors in Hull which link with the East Riding to the benefit of the wider network.
You Told Us
13.12 With regards to Green Infrastructure:
Make green space multi-functional where possible Use a network of volunteers to maintain sites – in return they could be provided with areas that they can use themselves. Endeavour school playing field should be made for public use. Detailed Green Infrastructure planning would be beneficial. Add weight to tenders that incorporate a positive effect on the natural environment. Plant hedges around playing fields for wildlife Increase trees, green roofs and walls, especially in the city centre. Require green roofs on buildings over a certain size. Green gateways into the city, linking culture with nature Ensure that tree planting does not displace habitats such as wildflower meadows. Safety warnings along the large drains SUDS should be required in line with the Aqua Greens project All new developments should be required to create a green environment – including growing food, wildlife and green waste disposal (composting, reed ponds, etc.) Requirements should be proportionate and viable. Go beyond the statutory requirement to move towards a net gain for nature. This should include buffering and enhancing the green network. Biodiversity enhancement should be a planning condition on all new development – including ongoing maintenance. Incorporate swift bricks, bird and bat boxes, green roofs and walls and SUDS into new development. New development should consult existing biodiversity groups to form ideas and management plans. Only native plants – with emphasis on creating semi-natural habitats. New development should never cause green space to be lost.
13.13 With regards to designating the Green Network:
Widespread support in favour of continuing the green network designation/protection. Green network seen as very important for the movement of species. Green Network is in line with current ecological thinking so should continue to be protected. Are there not already enough safeguards in place? Rename it habitat network or ecological network to make it clear that it is for wildlife.
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Have two networks, the first highlighting the green network, the other the biodiversity corridors. Railway lines should be included as they are important for wildlife. Green network requires ongoing, long-term maintenance. Brownfield sites with high ecological value should be included, e.g. Lord Line site and land adjacent to Makro.
13.14 With regards to protection of the Green Network:
Green network should be given higher level of protection than open space sites. Green network should be given the same level of protection as Local Wildlife Sites. Include policies to protect, enhance and buffer the network.
13.15 With regards to criteria for including sites in the Green Network:
Take into account functionality and connectivity. Criteria need to be consistent, straightforward and easy to implement. Should be backed up by robust and up-to-date ecological data. For biodiversity network, current Local Wildlife Sites should be the base. For GI network, identify corridors across the city and into the city centre. This should be consulted on with key stakeholders.
13.16 With regards to the potential New Green Network shown on the Evidence Map:
Include larger sites such as: East Park, Pearson Park, Northern Cemetery, Newland Allotments Looks promising – should be work in progress. Concern that it only identifies existing green space rather than connections between these areas.
Options
Option A: This option would be to identify and protect a citywide Green Infrastructure Network. As explained above, the saved Local Plan (2000) designated an extensive Green Network based around the main linear, semi-natural features that dissect the city. Sites in the Green Infrastructure Network will be protected from development seriously adversely affecting its continuity and value.
As this network requires updating, we need to agree a methodology for creating a new Green Infrastructure Network. Based on the maps presented above, there are two significant options:
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a. a network based on the Natural England Green Infrastructure Corridors; or
b. a network based around the open countryside, the Humber estuary, rivers, drains, green corridors, and railways (both live and disused).
Option B: In this option, location-specific improvements to the Green Network could be made. In addition to protecting existing Green Infrastructure (Option A), a more pro-active approach might be to identify particular weaknesses in the Network and propose methods for remedying them. For example, where there are small gaps in the Network, solutions could be investigated. The chosen solution would depend on the use and ownership of the land in question, but could include creating new green space, tree planting, or requiring new development to install green roofs.
Option C: This option would be to include a generic policy that requires new development to incorporate green infrastructure features as part of the design. Examples of green infrastructure incorporated into new development include green roofs and walls, sustainable drainage systems (SuDS), tree and hedgerow planting, and creating links with neighbouring green space. As new development comes in many shapes and sizes, it could be quite difficult to specify what is required in a policy, and would ultimately be left to the decision maker to determine what is reasonable.
Option D: In this option, there would be no Local Plan policy specifically on Green Infrastructure. As noted in the introduction above, there are other plans and strategies for Hull that will deliver gains for Green Infrastructure. The Local Plan is also likely to include policies on Open Space and Wildlife Sites. Therefore, additional Green Infrastructure policies may be considered unnecessary.
Preferred Option
13.17 Options A(b) and C. The new green network is shown on the Policies Map.
Justification
13.18 Option A is essentially carrying forward the saved Local Plan policy of protecting a citywide Green Network. This approach and widely considered to be positive way to plan for green infrastructure in the city.
13.19 Although it would nice to identify location-specific improvements (option B), this is considered to be too resource-intensive, and unless development applications come forward, there is no method to require the improvements from private landowners.
13.20 Option C allows green infrastructure improvements to be considered on a case-by-case basis, as new applications for development come in. This is considered to be a sensible route to securing green infrastructure and green network improvements across the city.
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Draft Policy 62
Green Infrastructure
1. The Green Network designated on the Policies Map will be protected from development which adversely affects its continuity and value. 2. Development proposals within, or in close proximity to, a Green Network corridor should enhance the functionality and connectivity of the corridor. 3. Development proposals should incorporate existing and/or new green infrastructure features within their design (such as green roofs, SUDS, trees, etc.).
Planning positively for biodiversity and wildlife
13.21 NPPF tells us that planning should “minimise impacts on biodiversity and provide net gains in biodiversity where possible”. With regard to protecting sites, NPPF states that planning authorities should:
...set criteria based policies against which proposals for any development on or affecting [protected wildlife sites] will be judged. Distinctions should be made between the hierarchy of international, national and locally designated sites, so that protection is commensurate with their status and gives appropriate weight to their importance and the contribution that they make to wider ecological networks.
13.22 And to minimise impacts on biodiversity, NPPF states that planning policies should:
plan for biodiversity at a landscape-scale across local authority boundaries; identify and map components of the local ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity, wildlife corridors and stepping stones that connect them and areas identified by local partnerships for habitat restoration or creation; and promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan.
13.23 The Humber Estuary (along the southern edge of the city boundary) is protected by the international Ramsar convention, the European Habitats and Wild Birds Directives (SPA and SAC), and by UK law as a Site of Special Scientific Interest (SSSI). Any development that would be likely to have a significant effect on the Humber, either alone or in combination with other
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plans or projects, would be subject to an assessment under the Conservation of Habitats and Species Regulations 2010. The statutory designations relating to the Humber are shown on the map below.
13.24 Local Nature Reserves (LNR) are designated by local authorities. They are places with wildlife features of special local interest. They offer people the chance to study nature, or simply to enjoy it. In 2012 the first two LNRs were declared for Hull. These were Rockford Fields (north of Rockford Avenue) and Bransholme Fishing Lake (Noddle Hill Way). These are also shown on the map below.
13.25 Many other sites in Hull benefit wildlife but do not receive any legal protection. These are called Sites of Nature Conservation Interest (SNCIs) in the saved Hull Local Plan, but are known more generally as Local Sites or Local Wildlife Sites. These sites are protected from adverse development by local planning policy. The saved Local Plan (2000) identified over 120 SNCIs. These are shown on the map below. However, the list of sites is in need of review. Some sites need de-listing because they have lost their nature value, and some new sites may require adding. Defra have published a guide on identifying, selecting and managing Local Sites. A Local Sites Partnership for Hull needs to produce site selection criteria. When this criteria is established, it can be used to determine which sites should be protected for their local wildlife value.
13.26 The Yorkshire and Humber Biodiversity Forum (YHBF) is an association of organisations committed to supporting biodiversity across Yorkshire and Humber. In 2009 YHBF produced a regional ‘Biodiversity Opportunity Areas Map’. The map provides an overview of the core areas where biodiversity action would have the greatest benefits, with the particular aim of raising the profile of biodiversity priorities outside of designated areas. In Hull the Biodiversity Opportunity Areas follow the River Hull and Holderness Drain corridors and part of Old Fleet Drain. In 2010, YHBF produced a 5-year Delivery Plan which included a suite of ‘Priority Landscape-scale Project Areas’. These are intended to be the core focus for delivering the region’s habitat targets. The approach is to maintain, restore and enhance ecological connectivity between existing biodiversity resources and to build on existing patches of habitat to increase their robustness. Hull has one Priority Landscape-scale Project Area, which follows the River Hull corridor. Both mapping exercises from the YHBF are shown in the map below, along with their connections with the surrounding East Riding of Yorkshire. The East Riding of Yorkshire Biodiversity Action Plan uses the outputs of the YHBF work to define its Biodiversity Priority Areas. In the absence of an up-to-date Hull Biodiversity Action Plan, it would seem sensible to adopt the same network of Biodiversity Priority Areas as the East Riding in order to maintain continuity and strengthen the network.
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13.27 The Government publishes a list of Priority habitats and species. These are species and habitats of national importance. In addition to these, the Hull Biodiversity Action Plan (2002) provides details of additional habitats and species of local importance to Hull. Both of these lists should be of consideration when planning to protect and improve biodiversity in the city.
Map 13.3 Biodiversity and wildlife designations
You Told Us
13.28 With regards to designating and protecting Local Sites:
Widespread support for designating and protecting Local Sites. Required by NPPF. Need for up-to-date and relevant evidence – Hull is falling behind other local authorities. Local Sites need to be evaluated against a robust set of criteria rather than simply adopting all the sites surveyed in 2008. Need a Local Sites Partnership to ratify site criteria. Sites need to be monitored for condition and integrity and rolling basis. Potential for some sites to become Local Green Space and have the same level of protection as Green Belt. Plan should include indicators for the protection and management of sites.
13.29 With regards to criteria for selecting Local Sites:
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Local Sites Partnership (a panel of experts) should agree the basis for site selection – based on local evidence and knowledge. Hull Biodiversity Action Plan is out of date – new evidence is needed. Sites need to be objectively assessed against Defra guidance. Seek advice on criteria from YWT, the University and local natural history groups. Consult Local Nature Partnership, YWT, EY bat group, Bumblebee Conservation Trust, RSPB, BTO, etc. Penny Anderson Study would make a good baseline but is now 6 years’ old and is out of date. HCC could work alongside ERYC and use their criteria. Criteria from other areas (York or East Riding) could be adapted. System needs to be robust so it can be defended if challenged.
13.30 With regards to a Local Sites Partnership, is there an existing local group or does a new one need to be formed:
For these to work, local people need to have motivation and ownership. Hull Biodiversity Partnership – although has no contact with HCC. Hull Biodiversity Partnership – but does not represent all partners that should be involved. East Riding Local Sites Partnership – or a sub-group. Adding to an existing partnership would be preferable so not to waste resources. YWT, RSPB, Woodland Trust and local conservation groups may be able to help with criteria.
13.31 With regards to sites to be considered for Local Nature Reserve status:
Oak Road Playing Fields (187) General Cemetery (100) Bude Fields, east of Thomas Clarkson Way (202). Semi-natural area on Summergroves Way (557) The Lozenge (271) Various rail trails throughout the city Mudflats south of Clive Sullivan Way (1) along with land to the east. Flood plain areas Longhill Playing fields (357/358) and Loglands
Options
Option A: Adopt a set of policies protecting wildlife sites from development. Following national advice, distinctions are made between international, national and locally designated sites so that protection is commensurate with their status (NPPF paragraph 113). These sites should be identified on the Policies Map (NPPF paragraph 117).
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Option B: As stated above, a Local Sites Partnership is required to review the existing list of SNCIs using locally determined selection criteria. Until the sites are reviewed, existing SNCIs will be considered Candidate Local Sites. They should be protected unless it can be demonstrated that the development will not have a negative impact on their biodiversity value.
Option C: Adopt a policy to promote the preservation / restoration and priority habitats, ecological networks and priority species (NPPF paragraph 117).
Option D: No policies regarding wildlife and biodiversity.
Preferred Option
13.32 A, B, and C.
Draft Policy 63
Biodiversity and wildlife
European Sites
1. Proposals for development that may affect a European protected sites or a site that is proposed as a Ramsar, SAC or SPA will need to do a Habitats Regulations assessment. This will need to consider the impact of the scheme both on its own and in combination with other schemes that have permission. The proposal will need to follow the relevant legislation to determine whether it is acceptable.
National Sites
2. Natural England will be consulted on proposals for development that are likely to have an effect on a SSSI. Schemes that will have a negative effect will not normally be permitted, except where the benefits of development clearly outweigh both the impact on the site and any broader impacts on the wider network of National Sites. In such cases, compensation for the harm will be sought.
Local Sites
3. Development resulting in loss or significant harm to a Local Wildlife Site will only be supported if it can be demonstrated there is a need for the development in that location and the benefit of the development outweighs the loss or harm. Where loss or harm cannot be prevented or adequately
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mitigated, as a last resort, compensation for the loss/harm must be agreed. Development will be refused if loss or significant harm cannot be prevented, adequately mitigated against or compensated for.
4. Until formally reviewed, sites designated as Sites of Nature Conservation Interest in the Hull Local Plan (2000) will be considered Candidate Local Wildlife Sites, and will be afforded the same level of protection as Local Wildlife Sites unless it can be demonstrated that the site does not have nature conservation value.
Protected Species
5. Development adversely affecting a species protected by legislation will not be allowed.
Promoting biodiversity improvements
6. Proposals should seek to achieve a net gain in biodiversity where possible and will be supported where they:
a. Conserve, restore, enhance or re-create biodiversity interests, particularly national Priority Habitats and Species and locally important habitat and species identified in the Hull Biodiversity Action Plan.
b. Safeguard, enhance, create and connect habitat networks (particularly those highlighted by the Yorkshire and Humber Biodiversity Forum and the Yorkshire Wildlife Trust) in order to:
i. protect, strengthen and reduce fragmentation of habitats;
ii. create a coherent ecological network that is resilient to current and future pressures;
iii. conserve and increase populations of species; and
iv. promote and enhance green infrastructure.
Justification
13.33 These measure are required in order to make the Local Plan NPPF compliant. It also recognises that the city does not currently have an up-to-date Local Sites list, so puts in necessary safeguards to protect existing SNCIs.
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Tree Protection and Replacement
13.34 The value of trees in urban areas is well documented. They can reduce air pollution by absorbing gaseous pollutants and filtering dust, ash and smoke. They can absorb noise, reduce glare, provide wind protection, and cool the air. They contribute to greater health and wellbeing. They provide habitat of wildlife. They can reduce surface water runoff and thereby reduce flood risk. Last but not least, they make places more attractive – people want to live in leafy suburbs not concrete jungles. These are all vitally important functions in a densely built urban area like Hull.
13.35 Hull City Council is a partner in the HEYwoods initiative. This has the aim of significantly improving the landscapes of Hull and the East Riding through the creation of functional green infrastructure based on trees and woodland. This is important as Hull has relatively little tree cover compared with many parts of England. Hull City Council is also working with William Jackson Food Group on a long-term project to plant 200,000 trees by 2051 to celebrate the company’s 200th anniversary.
13.36 In terms of existing local policy, the saved Local Plan (2000) contains a number of policies that support or encourage the protection of trees and tree planting. For instance, policy NE18 relates to the protecting of trees and woodland. It states:
Development resulting in the loss of, or damage to, a tree or group of trees of significant amenity value will not be allowed.
13.37 The only policy in the saved Local Plan that requires replacement trees is BE22 which relates to Trees in a Conservation Area. It states:
If felling is acceptable then replacement planting of appropriate size and standard will normally be required.
You told us
13.38 With regards to trees, you told us:
The provision of green space and the sight/smell and touch of green plants including trees can lower stress levels and there is the added bonus of enhancing biodiversity and improving environment awareness and education. Plant more trees to mitigate climate change. Trees can often make an important contribution to both mitigating flooding and improving water quality role in helping to reduce flood risk. Manage sites according to habitat potential – don’t just plant trees. Increase greenspace, such as trees, in the city centre Ensure that tree planting in Hull doesn’t displace scarce habitats such as wildflower meadows, grasslands and wetlands. Jacksons tree planting project – would be better to have 200 school children planting trees each year.
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Evidence that greening by trees and plants may reduce urban temperatures by transpiration of water – desirable with increasing global warming. City has lowest tree cover in England. Woodland and suitable access should be promoted as requirement for development schemes. Woodland Trust’s Woodland Access Standard should be taken into account – no one should live more than 500 m from accessible woodland no less than 2 ha; and no one should live more than 4km from accessible woodland no less than 20ha. Create links between woodland sites using native trees.
Options
Option A: Adopt a policy that protects existing trees from harm caused by development, particularly if they offer significant amenity value.
Option B: Adopt a policy that requires new developments to plant trees.
Option C: Adopt a policy that requires a replacement tree for every tree that is lost to development.
Option D: Adopt a policy that requires two replacement trees for every tree that is lost to development.
Option E: Do not adopt a policy relating to trees.
Preferred Option
13.39 Options A, B and C.
Draft Policy 64
Tree protection and replacement
1. Permission for residential development will be granted on condition that three new trees are planted for each new dwelling. 2. Development resulting in the loss of, or damage to a tree, group of trees or areas of woodland of significant amenity value will not be allowed. 3. All other trees should be retained whenever possible unless:
a. They are dead, dying or have been professionally assessed to be causing an immediate a hazard to public safety; or b. The benefit of the proposed development outweighs the benefit of their retention.
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4. If felling is deemed acceptable then replacement planting of an appropriate species in an appropriate location will normally be required. 5. The City Council will make Tree Preservation Orders when necessary in order to protect specific trees, groups of trees, or woodlands in the interests of amenity.
Justification
13.40 As outlined above, trees offer numerous benefits but for historical reasons, Hull has low levels of tree cover. We therefore think that a policy that protects existing trees and requires new trees to be planting is justified.
13.41 Further details regarding the implementation of the policy could be set out in a Supplementary Planning Document (SPD), which the Council’s Aboricultural Officer would help draft. This may help explain what is meant by “significant amenity value”, and where new and replacement trees might be appropriately located. Supporting evidence
Sustainability Appraisal Objectives
1. Protect and enhance habitats and biodiversity. Improve connectivity between sites and prevent habitat fragmentation.
2. Maintain and enhance water quality and limit water consumption to levels supportable by natural processes and storage systems, taking into account the impact of climate change;
6. Ensure that development is capable of withstanding the effects of climate change;
7. Achieve good air quality;
11. Conserve and enhance the landscape and townscape, encouraging local distinctiveness;
12. Encourage healthy lifestyles and reduce the health impacts of new developments;
16. Enhance community identity and participation;
Sustainability Appraisal Working Paper Comments
The Green Infrastructure policy options are supportive of biodiversity and health objectives. Further clarity on how the Local Plan will help support improvement of Green Infrastructure, including its protection and enhancement is recommended. For example in relation to a proposed development, how will GI improvements be sought or what
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criteria will apply for future planning applications with respect to contribution to the GI; Local Nature Reserve- policy option could provide direction on how the planning process will consider LNRs when determining applications;
Main Evidence Base Sources
Hull Open Space & the Natural Environment Review (November 2014) Sites of Nature Conservation Importance Report (Penny Anderson, October 2008)
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14. Environmental Quality Introduction
14.1 The quality of the physical environment is vitally important for human health and biodiversity. The NPPF, at paragraph 109, sets out the role of the planning system as being:
preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of oil, air, water or noise pollution or land instability; and remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land where appropriate.
14.2 Paragraph 120 of the National Planning Policy Framework advises that planning policies should ensure that new development is appropriate for its location. The effects and cumulative effects of pollution on health, the natural environment or general amenity and the sensitivity of the proposed development to adverse effects from pollution should be taken into account.
14.3 Roles and responsibilities in relation to pollution are shared between a range of agencies including the Environment Agency, the Health and Safety Executive and Local Authorities through their Environmental Health responsibilities. Paragraph 122 of the NPPF is clear however: planning authorities should not be concerned with the control of processes and emissions where these are controlled through pollution control regimes and it should be assumed that these regimes will operate effectively.
14.4 The Saved Local Plan contains policies regarding pollution. Policy ME2 relates to the control of developments which could cause pollution. It seeks to refuse development which would have an unacceptable pollution impact and to encourage developers to design their developments in a way which would minimise their pollution impact.
14.5 Policy ME3 relates to development near pollution sources. It seeks to refuse development unless it is demonstrated that the level of risk is acceptable. It highlights that an assessment of the existing pollution source, the extent of any off-site problem and the sensitivity of the proposed development will be taken into account in determining if the level of risk is acceptable. Atmospheric Pollution
14.6 It is estimated that air pollution causes 29,000 excess deaths in England each year. The Ambient Air Quality Directive sets legally binding limits for the levels of major air pollutants such as particulate matter and nitrogen dioxide. It is important, particularly where limits have been exceeded or are close to being exceeded, that the potential impact of new development on
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air quality is taken into account. Where limits are exceeded or are at risk of being exceeded, an air quality management area must be declared by the local authority who must then also prepare an air quality action plan. This can have implications for planning.
14.7 These limits have been exceeded in Hull, resulting in the designation of air quality management area, illustrated in Figure 14.1. The Action Plan identifies a role for land use planning in seeking to reduce levels of pollutants.
Figure 14.1
14.8 Paragraph 124 of the National Planning Policy Framework advises that planning policies should sustain compliance with and contribute to EU limit values or national objectives for pollutants. This should take into account the presence of air quality management areas.
14.9 Planning Practice Guidance contains a section on the role of Local Plans with regard to air quality. It advises that Local Plans can affect air quality in a number of ways such as what development is proposed where and the support given to sustainable transport options. It also states that odour and dust can also be planning concerns because of the impact they can have on amenity.
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14.10 It advises that the Local Plan should draw on the review of air quality and may need to consider:
the potential cumulative impact of a number of smaller developments on air quality as well as the effect of more substantial developments; the impact of any pollution that originates from one place (point sources); and ways in which any new development would be appropriate in locations where air quality is or is likely to be a concern and not give rise to unacceptable risks from pollution.
14.11 Planning Practice Guidance also highlights that air quality can affect biodiversity and could impact on international obligations under the Habitats Directive.
You Told Us
Local Plan should include policies regarding pollution control However general caution was also raised that policies should not duplicate other controls and guidance on these issue should not hamper growth
Options
14.12 Air quality is a pressing issue and national guidance is clear that planning should support air quality management. As an Air Quality Management Area has been designated within the city, it is considered that the options regarding air quality relate to the criteria included within the policy.
Preferred Option
Draft Policy 65
Atmospheric Pollution
1. Major development which could, individually or cumulatively with planning permissions or developments under construction:
worsen air quality within an Air Quality Management Area; lead to the creation of a new Air Quality Management Area; or increase the number of sensitive receptors within an Air Quality Management Area
must be accompanied by an assessment of air quality.
2. The scope of any assessment of air quality should be agreed prior to the submission of a planning application and is likely to be required to:
identify the site, development proposal and area in which the impacts will be assessed
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assess the existing air quality assess the impact of the proposal on air quality individually and in conjunction with any outstanding planning permission or development under construction on air quality identify mitigation measures and quantify the impact of those measures.
The assessment should also, if located in proximity to the Humber Estuary Special Protection Area, specifically consider any impact on the SPA.
3. Developments which cannot appropriately mitigate air quality concerns, including dust and odour, will only be approved where the social and economic benefits significantly outweigh the negative impact on air quality.
Justification
14.13 The criteria included within the policy set out what would be required to demonstrate that a development would have an acceptable impact on air quality, along with criteria to allow development despite a negative assessment. Land affected by contamination
14.14 The issue of land affected by contamination is primarily addressed through the Environmental Protection Act 1990. The role of the planning system is to ensure that a site is suitable for any new use that would require planning permission and to prevent unacceptable risk from pollution. However this must be done only to the extent that it is not addressed by other regimes.
14.15 Paragraph 121 of the National Planning Policy Framework requires planning policies to ensure that sites are suitable for new uses taking account of pollution and that after remediation land should no longer be contaminated.
14.16 Planning Practice Guidance examines the role of Local Plans in considering contamination. It acknowledges that the issues will be different for each authority, but suggests that the following issues are considered.
If contamination is an issue over a wide area, a strategic phased approach may be useful and can contribute to achieving objectives such as those of the Water Framework Directive. If land is known to be affected by contamination, only allocate for appropriate development and be clear on the approach to remediation. Where a site neighbours contaminated land, regard should be had to the potential impacts from that land.
14.17 It also advises that the role of developers and the requirements for information and assessments should be clear.
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14.18 Policy ME4 of the Saved Local Plan relates to the removing contamination. It supports the development of contaminated land. It sets out that developers will required to provide a site investigation for land known to or suspected of being contaminated. If the site requires treatment, an agreed programme of work will also be required.
You Told Us
Local Plan should include policies regarding pollution control However general caution was also raised that policies should not duplicate other controls and guidance on these issue should not hamper growth
Options
14.19 It is considered that there must be a policy regarding contaminated land within the Local Plan. There is land within Hull which is contaminated and it is through the planning system that the impact on contamination on future land uses is considered. The only options therefore are the criteria contained within the policy.
Preferred Option
Draft Policy 66
Land Affected by Contamination
Applications which involve the development of land known or suspected to be contaminated, where the development would introduce a vulnerable end use or the development could result in the creation of new pathways between contamination sources and receptors must be accompanied by an appropriate contamination assessment. Where necessary, applications will be conditioned to ensure that appropriate remediation takes place.
Justification
14.20 There are contaminated sites within the city, and as future growth will depend on the re-use of land, there will always be the potential for contamination to be an issue. The proposed approach makes clear that contamination is an issue which must be addressed. Noise Pollution
14.21 Paragraph 123 specifically relates to noise pollution. It advises that planning policies should aim to avoid significant adverse impacts on health and quality of life as a result of noise from new development and that any other adverse impacts from noise should be mitigated where possible. It should also be recognised that development will often create some noise and existing
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businesses wanting to develop should not have unreasonable restrictions put on them because of changes in nearby land uses since they were established.
14.22 Planning practice guidance advises that Local Plans can include noise standards in their Local Plan. It does specify that noise standards developed through the local Plan should only be concerned with management of noise to and from the local environment.
You Told Us
Local Plan should include policies regarding pollution control However general caution was also raised that policies should not duplicate other controls and guidance on these issue should not hamper growth
Options
Option A: Do not include a policy regarding noise pollution in the Local Plan.
Option B: Include a policy regarding noise pollution in the Local Plan.
Preferred Option
14.23 Option B
Draft Policy 67
Noise Pollution
1. Applications which would site noise sensitive receptors in proximity to noisy uses or areas should demonstrate that there would be an acceptable level of amenity for end users.
2. Applications for noisy uses should be accompanied by evidence to show how the noise can be mitigated and that there would be an acceptable impact on the amenity of surrounding land uses.
Justification
14.24 Hull is a constrained urban area which has developed over time and land uses continue to change. This can result in land uses in proximity to each other which may impact the amenity or use of the other. It is important that this issue is explicitly considered as part of the application process and does not only rely on environmental health legislation.
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Light Pollution
14.25 Paragraph 125 specifically provides for planning policies to encourage development which limits the impact of light pollution.
14.26 Further detail is provided in planning practice guidance. It sets out when light pollution is relevant to planning: in Hull's case this will primarily relate to when light would be a source of annoyance to people, however consideration should be given to the potential for light to be harmful to wildlife.
You Told Us
Local Plan should include policies regarding pollution control However general caution was also raised that policies should not duplicate other controls and guidance on these issue should not hamper growth
Options
Option A: to not include a policy on light pollution.
Option B: to include a policy on light pollution.
Preferred Option
14.27 Option B
Draft Policy 68
Light Pollution
Applications for all uses in proximity to sensitive receptors such as residential properties or the Humber Estuary should ensure that lighting is designed in such a way as to avoid an adverse impact on those sensitive receptors.
Justification
14.28 Light pollution is an important consideration in Hull because of the density of development. Residential properties can be in proximity to commercial, industrial or leisure uses which may required the use of flood lighting or security lighting. Along the Humber frontage, it may also be the case that lighting could have an impact on the wildlife in the designated sites. It is considered that it would be useful for developers to be aware of these specific considerations. Hazardous Substances
14.29 The Council also acts as the Hazardous Substances Authority
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14.30 Paragraph 172 of the National Planning Policy Framework requires planning policies to be based on up-to-date information on the location of major hazards and on the mitigation of the consequences of major accidents. There is detailed information contained within the Planning Practice Guidance.
14.31 Article 13 of EU Directive 2012/18/EU concerns the control of major-accident hazards involving dangerous substances and has been transposed into UK planning law through the Planning (Hazardous Substances) Regulations 2015. Article 13 specifically concerns land use planning. It requires the objective of preventing major accidents and limiting the consequences of such accidents for human health and the environment to be taken into account in land use policies. This should be achieved through controls on:
the siting of new establishments; modifications to existing establishments; and new development in the vicinity of establishments which may be a source of or increase the consequences of a major accident.
14.32 It also requires land use policies to take into account the long term need to:
maintain appropriate safety distances between establishments and vulnerable or public areas; protect areas of particular natural sensitivity or interest; and allow existing establishments to take measures so as not increase the risks to human health and the environment.
14.33 Planning practice guidance advises that plan preparation can be informed by taking into account the likely advice on application within the hazardous substances consultation zones – enabling the local planning authority to have regard to the objective of preventing major accidents and limiting their consequences. Planning practice guidance is very clear that there should be active engagement with businesses to support their development ambitions while still protecting people and the environment.
14.34 Additionally, some sites and pipelines are known as notifiable installations
14.35 Policy ME5 of the Saved Local Plan seeks to restrict hazardous installations where it would create an unacceptable hazard to health and life or if it would severely prejudice nearby development.
14.36 Policy ME6 seeks to restrict development near hazardous installations unless it has been clearly demonstrated that the level of risk is acceptable. This would be determined through an assessment of the existing hazard, the extent of any off-site problems and the sensitivity of the proposed development.
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You Told Us
Local Plan should include policies regarding hazardous substances. However general caution was also raised that policies should not duplicate other controls and guidance on these issue should not hamper growth
Options
Option A: Only consider hazardous substances through the site allocations process in the Local Plan. The Local Plan would not contain a policy regarding hazardous substances consent and applications would be determined in line with planning practice guidance and advise from the Health and Safety Executive. The presence of Hazardous Substances Consents would be taken into consideration as part of the site allocations process.
Option B: Include a policy addressing hazardous substances consent, alongside consideration of hazardous substances through the site allocations process. The Local Plan could contain a policy which sets out how applications for hazardous substances consent will be considered and how applications in proximity to sites with a hazardous substances consent would be considered.
Option C: Do not include a policy on Hazardous Substances. Planning practice guidance and the relevant Regulations would guide how to deal with any applications for Hazardous Substances Consent.
Preferred Option
14.37 Option B is the preferred option.
Draft Policy 69
Hazardous Substances Consent
1. Applications for hazardous substances consent will be allowed where they have been determined in consultation with the Health and Safety Executive, Environment Agency and any other regulatory bodies as appropriate and they support the approval.
2. Applications for development in proximity to a site with a hazardous substances consent or in proximity to a notifiable installation have demonstrated that the future occupiers of the development would not be adversely affected by the proximity to the relevant sites.
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Justification
14.38 Hull's dense pattern of development means that conflicting uses can sometimes be in close proximity to each other. Going forward, we need to ensure that the need for economic development and growth of industry happens in a way that is safe, while at the same time not allowing other developments in the wrong place near to notifiable installations or sites with the benefit of a hazardous substances consent. Supporting Evidence
Sustainability Appraisal Objectives
2. Maintain and enhance water quality and limit water consumption to levels supportable by natural processes and storage systems, taking into account the impact of climate change
4. Minimise the loss of soils to new development and encourage remediation of contaminated land.
7. Achieve good air quality
Sustainability Appraisal Working Paper Comments
Consider incorporating provision of directions to address ground water pollution during construction at potentially contaminated sites;
Main Evidence Base Sources
Hull Local Plan 2000
Technical Guidance for Developers, Landowners and Consultants, Yorkshire & Humberside Pollution Advisory Council, February 2015
Noise Policy Statement for England
Infrastructure Study
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15. Energy and Utilities Renewable and low carbon energy
15.1 A reliable and plentiful supply of renewable and low carbon energy is vital if we are to cut greenhouse gas emissions in order to mitigate climate change. Moving to such technologies also has other benefits including greater energy security, tackling fuel poverty and improved air quality. In addition, better methods of storing energy are needed in order to support the adoption of renewable energy as renewable sources tend to be intermittent in their nature.
15.2 Paragraph 97 of NPPF relates to renewable and low carbon energy. It states:
Have a positive strategy to promote energy from renewable and low carbon sources; Design policies to maximise renewable and low carbon energy development while ensuring that adverse impacts are addressed satisfactorily; Consider identifying suitable areas for renewable and low carbon energy sources where this would help secure the development of such sources; Support community-led initiatives for renewable and low carbon energy; and Identify opportunities where development can draw its energy supply from decentralised, renewable or low carbon energy supply systems and for co-locating potential heat customers and suppliers.
15.3 The UK is committed to meeting 15% of its energy demand from renewable sources by 2020. Hull City Council is keen to promote renewable and low carbon energy developments as it helps reinforce Hull as a green energy city. The authority has granted planning permission for numerous renewable energy installations that were considered appropriate to the built environment. However, the dense urban nature of Hull and the proximity of the protected Humber Estuary mean that the siting of certain technologies, such as large wind turbines, can be difficult. The technologies that are potentially most suitable for Hull are listed in the table on the next page, along with a summary of their most significant pros and cons. Some technologies will be better suited to particular areas of Hull, for example, residential or industrial areas. Also, the impact of a particular technology will often depend on its size and design. Hull City Council continues to investigate opportunities to install such technologies in the city.
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RF UE2015 JUNE DRAFT Table 15.1 Renewable energy technologies - pros and cons
Technology Pros Cons
Wind turbines Established method for generating electricity Can cause noise and shadow flicker affecting Come in a range of different sizes and residential amenity designs making them suitable for different Minimum distance required between buildings and locations other obstacles Can injure birds and bats Possible interference with radar and radio communications
Solar panels (photovoltaic Silent and can have a low visual impact. May not be suited to listed buildings or conservation or thermal) Many schemes are ‘permitted development’ areas. so do not require planning permission. Important that they are correctly angled to maximise their effectiveness.
Ground source heat No visual impact Requires electricity to run pumps Requires the right ground conditions
Air source heat pumps Easier to install than GSHP as does not Some visual impact – similar appearance to air require earth works conditioning units
Biomass (wood chips or Can be a replacement to gas heating Can impact on air quality pellets) Wood chips/pellets can be easily sourced Space implications for fuel storage Increase in traffic due to delivery of fuel
Anaerobic digestion Helps recycle waste products Potential smell Delivery of waste – traffic issues Technology Pros Cons
Tidal power The Humber has a large tidal range Technology still in infancy Impact on Humber – shipping lanes and wildlife
Combined heat and power Reduces carbon emissions Requires a fuel (fossil or biomass) (CHP) More complicated than a simple boiler.
District energy network Can use a range of fuels, including waste High start-up cost. heat from industrial processes. Ideally requires a mixed-use development in order Simplifies maintenance as buildings don’t to even out the demand for heat. require separate boilers. Requires a high density development in order to Electricity transmission is more efficient than be viable. over the national grid. ulLclPa:PeerdOptions Preferred Plan: Local Hull RF UE2015 JUNE DRAFT 301 Hull Local Plan: Preferred Options
15.4 One of the easier technologies to install in an urban setting like Hull is solar panels. They can function on any broadly south-facing roof or wall, and have few negative effects. They require daylight to operate and therefore generate more power in the summer than winter months. Hull City Council is demonstrating the potential for solar technology in the city by installing panels on top of Pryme Street multi-storey car park, Western Library and 130 social houses. Many solar panel installations are now permitted development and therefore do not require planning permission anymore. In June 2015 Hull City Council granted permission for a 10MW solar PV farm on agricultural land east of Cumbrian Way. It is estimated that this will produce enough electricity for 2,850 homes per year.
15.5 Biomass is another renewable technology that may be appropriate for certain developments in Hull. As part of the Building Schools for the Future programme, new biomass boilers were installed in all the new schools, replacing gas as the main fuel for heating the buildings. Permission has also been granted for a large-scale biomass plant (50MW), and there are also plans for harnessing energy from waste in the city. However, with all these schemes, air quality will be an important consideration.
15.6 A policy in the former regional plan for Yorkshire and the Humber required new developments to meet 10% of their energy requirements through the use of on-site renewable energy technology. The regional plan has since been revoked, so this is no longer a requirement. Similar policies currently exist in the adopted Newington and St Andrews AAP and the Holderness Road Corridor AAP. Developments in those areas of the city still have to meet these requirements at the moment. However, citywide viability analysis suggests that such requirements are on the whole unviable. It is therefore unlikely that we can continue to require them in planning policy.
15.7 Hull City Council is also investigating the potential for district energy networks in parts of the city. A district energy network involves a large energy plant producing enough heat for a district. By running continually, it can achieve high levels of efficiency. Even greater efficiency can be gained by generating electricity at the same time using combined heat and power (CHP) technology. Heat is distributed through a network of insulated pipes. Each property that connects to it has a device called a heat exchanger that heats the central heating and hot water similar to a traditional boiler. District energy networks are typically best suited in areas where there is a mix of different building types, so that there is demand for heat throughout the day. They also represent a considerable upfront cost in terms of infrastructure, and therefore require a large number of users in order to make them viable. Hull City Council has commissioned a feasibility study into the potential for a citywide district heating scheme. Potential options for heat sources include a biomass energy plant, Jackson’s Bakery, and hospitals. Another option that is being considered is extracting heat from the River Hull using heat pump technology.
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You Told Us
15.8 With regards to renewable and low carbon energy:
HCC and ERYC should encourage new investment in renewables wherever possible. HCC should again consider waste incineration. Where possible, reduce energy demand through insulation, smart technology, etc. Solar is the most suitable technology. As Hull lies adjacent to Humber, prioritise lower risk technologies – e.g. energy efficiency, heat pumps and solar panels. Renewable energy should consider impact of ecology – especially areas like the Humber. Solar powered roofs (constructed off-site) should be examined. City centre is the best place for district energy network because of its mix of uses. Economic advantage to local population is the best way to promote the development of district energy networks. Biomass power station at Saltend connected to a district energy system. District energy networks are an excellent idea for a number of areas. Support policies that promote renewables, including waste as a source of energy.
Options
Option A: Adopt a criteria-based policy that supports renewable and low carbon energy technology providing all negative impacts can be addressed satisfactorily. As noted above, the authority is keen to move to become a low carbon economy, but is also aware of the potential difficulties of locating certain technologies within the city boundary. Potential impacts that are particularly relevant to this type of development are:
Local amenity, including noise, air quality, traffic, vibration, dust, visual impact; Biodiversity, particularly in relation to national and international designations, and priority species and habitats; Historic environment, such as conservation areas and listed buildings; Telecommunications, so as not to interfere or block radio communications and radar systems.
Other development considerations, such as flood risk, should also be considered where relevant.
The policy should also include a clause requiring the decommissioning of the technology at the end of its operational life. This is particularly important for large, free-standing technologies such as wind turbines.
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Option B: Adopt a policy requiring new development to provide a percentage of their energy requirements from on-site renewable or low carbon energy sources. As stated above, such a policy was implemented citywide using the now revoked regional plan for Yorkshire and Humber, and is still implemented in the Newington and St Andrew’s and Holderness Road areas. However, it is difficult to demonstrate that such a requirement is generally viable in Hull, and development costs are likely to increase in the near future as the energy efficiency component of building regulations is tightened further.
Option C: Adopt a policy that would require new development to connect to a district energy network, should one exist nearby and it has the capacity to serve the development. Such a policy would give greater confidence to the investors in district energy networks that they can be operated viably.
Option D: Do not adopt any policies that encourage, promote or control the installation of renewable or low carbon energy technology.
Preferred Option
15.9 Option A and C.
Draft Policy 70
Renewable and Low Carbon Energy
1. Proposals for development that generate, transmit or store renewable and low carbon energy will be accepted where the impact is or can be made acceptable. Potential impacts that are particularly relevant to this type of development are:
Local amenity, including noise, air quality, traffic, vibration, dust, visual impact; Biodiversity, particularly in relation to national and international designations, and priority species and habitats; Historic environment, such as conservation areas and listed buildings; Telecommunications, so as not to interfere or block radio communications and radar systems.
2. Arrangements should be put in place for the effective decommissioning of renewable and low carbon energy technology when it gets to the end of its useful life. The aim should be to prevent abandoned technology from blighting areas of the city. 3. New development will be expected to connect to a district energy network, if there is a suitable one in place, and that it is viable and feasible to do so.
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Justification
15.10 We want a policy that promotes and supports renewable and low carbon technology where possible, hence we have selected options A and C. Although we have previously required development to provide a percentage of their energy requirements through the use of on-site renewable energy (option C), we are aware this may cause viability problems for development in the city, and the policy may largely be superseded by changes to Building Regulations. Wind turbines
15.11 A ministerial statement was issued on 18 June 2015 regarding planning applications for wind turbines. It states:
When determining planning applications for wind energy development involving one or more wind turbines, local planning authorities should only grant planning permission if:
the development site is in an area identified as suitable for wind energy development in a Local or Neighbourhood Plan; and
following consultation, it can be demonstrated that the planning impacts identified by affected local communities have been fully addressed and therefore the proposal has their backing.
In applying these new considerations, suitable areas for wind energy development will need to have been allocated clearly in a Local or Neighbourhood Plan.
15.12 The new Local Plan therefore needs to allocate areas in the city that are suitable for wind turbines if any more are to built (except for smaller turbines allowed through permitted development rights).
15.13 Because of the dense urban nature of Hull, the opportunities to install large-scale wind turbines are limited, although it is possible in the right place. Currently wind turbines in Hull have been built alongside industrial units and schools. The largest turbine in the city is the 125 metre 2MW turbine at Croda on Clough Road. There are two smaller turbines near by on Helsinki Road that are 40 metres tall. There are a number of 20 metre high turbines on Saltmarsh Court.
15.14 The map below illustrates some of the main constraints that limit the placement of large wind turbines within the city boundary. Using a relatively small 350 metre buffer around residential properties, most of the city is excluded.
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Map 15.1 Wind turbines - areas of opportunities and constraints
15.15 The above map is only provided for information purposes and should not be used to definitively decide where wind turbines might be acceptable. There are many different issues that need to be considered when dealing with an application for a wind turbine and these often only come out when the size and location is decided. Although wind turbines can have a negative effect on their surroundings (see the table above for a summary of pros and cons), most of these can be mitigated if correctly identified. For example, shadow flicker is only an issue at certain times of year when the sun is in a particular position. Modern turbines can be programmed to switch off for short periods of time during these circumstances.
15.16 On a related note, Hull will soon become a centre for offshore wind turbine construction with the completion of the Siemens Green Port Hull. There is far greater capacity for harnessing wind energy at sea than on land. Developments related to the wind turbine industry are supported in the port area by the adoption of Local Development Orders which help streamline the planning process. There is more information about the land allocations in the Port area provided in the Economic Growth chapter.
Options
Option A: Identify all current and proposed employment land areas are potentially suitable for wind turbines. This would be on the basis that the development does not undermine other plan objectives (for example, the need for the land to provide employment facilities) and the development is acceptable against the criteria listed in the Renewable Energy policy (see above).
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Option B: Identify all existing agricultural land as being potentially suitable for wind turbines.This would be on the basis that the development is acceptable against the criteria listed in the Renewable Energy policy (see above).
Option C: Identify all school sites as being potentially suitable for wind turbines. This would be on the basis that the development is acceptable against the criteria listed in the Renewable Energy policy (see above).
Option D: Identify all large open space sites (greater than 1 hectare) as being potentially suitable for wind turbines. This would be on the basis that the development does not undermine other plan objectives (for example, the need for open space facilities) and the development is acceptable against the criteria listed in the Renewable Energy policy (see above).
Option E: Do not identify suitable areas for wind turbines.
Preferred Option
15.17 Options A, B, C and D.
Justification
15.18 Hull City Council is keen to promote and embrace renewable energy technology as part of its image as an Energy City. The recent Ministerial Statement potentially reduces the Council's ability to approve schemes for wind turbines that it otherwise believes to be acceptable. It is therefore necessary to identify as many broad areas of the city as possible that would be potentially suitable for wind turbines. We have therefore selected options A, B, C and D. The largest land use that is excluded is residential land, but generally wind turbines are inappropriate when located near to residential properties due to the issues of noise and shadow flicker. Utility Equipment
15.19 NPPF explicitly supports the expansion of high quality communications infrastructure and the provision of necessary infrastructure. However it is important that the installation of new utility equipment, which can remain in place for many years, does not have a detrimental impact on the amenity of the surrounding area.
You Told Us
15.20 Minute 235 of the Planning Committee requires a policy to be developed in the Local Plan to ensure an adequate standard of appearance of utility infrastructure which takes account of the comments made at that Committee.
15.21 The minute records the following comments:
telecommunication equipment cabins should fit in with the public realm work being undertaken in the City; the use of anti-graffiti paint on telecommunication equipment cabins;
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the need to ensure that the telecommunication equipment cabins blend in with their surroundings and become part of the local infrastructure; that the telecommunication equipment cabins do not obstruct the views of road users; the use of scrub planting to ‘soften’ the outline of the telecommunication equipment cabins; that any policy needs to respond to the area in which the telecommunication equipment cabins are set; and the use of tall buildings to site telecommunications masts.
Options
Option A: Do not include a policy on utility equipment in the Local Plan. This option would rely on national policy and general design and infrastructure policies within the Local Plan to determine applications.
Option B: Include a policy on utility equipment in the Local Plan. This option would set out locally defined considerations when siting utility equipment.
Preferred Option
15.22 Option B is the preferred option.
Draft Policy 71
Utility Equipment
The installation of utility equipment will be supported where consideration has been given to the following criteria:
1. the equipment has been sited so as to minimise its impact on the visual amenity, safety and use of the surrounding area; 2. the equipment has an appropriate, anti-graffiti, colour treatment for its surrounds or an appropriate bespoke design; and 3. consideration has been given to the use of soft landscaping to minimise the visual impact of the equipment.
Justification
15.23 It would ensure that utility infrastructure providers are aware of the specific concerns that apply when installing equipment in the city. There is a particular emphasis on the quality of public realm in the city, and the use of option B is best to support this.
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Supporting evidence
Sustainability Appraisal Objectives
5. Reduce the factors causing climate change, with a particular focus on reducing the consumption of fossil fuels and levels of CO2;
7. Achieve good air quality;
9. Use natural resources, both finite and renewable, as efficiently as possible, and re-use finite resources (including waste) or recycled alternatives wherever possible;
Main Evidence Base Sources
Community Infrastructure Levy and Development Standards – Area Wide Economic Viability Assessment (HCC, November 2012) Renewable Energy and Energy Efficiency Study (HCC, July 2010) Hull Environment and Climate Change Strategy (HCC, 2010) The National Adaptation Programme (Defra, July 2013)
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Appendices
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Appendix A. Saved Local Plan (2000) policies to be deleted A.1 Once adopted, it is the intention that the following saved Local Plan (2000) policies will be deleted. General Policies
Saved Local Plan Description (2000) policy
G1 – Deciding The policy states that development complying with all development relevant CityPlan provisions will be allowed. If there is proposals a conflict with different parts of the plan, then development will be allowed if its benefits outweigh its disbenefits.
G2 – Detailed The policy states that development complying with planning specific policies of the CityPlan will be allowed if its considerations location and detailed planning considerations are acceptable. The policy lists various considerations, including amenity, design, parking, danger to health, risk of pollution, etc.
G3 – Development The policy specifies criteria for when a development briefs brief is required. It specifies what a development brief should consist of, who can prepare one, and that it will be subject of public consultation.
G4 – Protecting The policy states that within existing predominant use existing areas areas (as designated on the proposals map) new development must be compatible with the predominant use.
G5 – Planning The policy lists the reasons for use of planning obligations obligations. These are to achieve the appropriate use of land or buildings, an improved range of facilities, and a properly planned environment.
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Managing the Environment
Saved Local Plan (2000) Description policy
ME1 – Sustainable The policy supports development complying with development the principles of sustainability and respecting environmental constraints.
ME2 – Development not The policy lists factors that will be considered allowed if unacceptable when determining the pollution impact of new pollution impact development.
ME3 – Development near The policy prevents development near to pollution sources pollution sources unless the level of risk is acceptable. The extent of the pollution source needs to be assessed along with the sensitivity of the proposed development.
ME4 – Removing The policy supports development on contamination contaminated land but requires a developer to investigate the suspected contamination and undertake the necessary work to prevent the site being a hazard.
ME5 – Hazardous The policy constrains hazardous installations installations where they create an unacceptable hazard to health and life or they severely prejudice nearby development.
ME6 – Development near The policy prevents development near to hazardous installations hazardous installations unless the level of risk is acceptable.
ME12 – Waste water The policy sets criteria for waste water treatment treatment plant plant development. development
ME13 – Development near The policy constrains development near to a to a waste water treatment waste water treatment plant unless a satisfactory plant standard of amenity can be achieved.
ME14 – Trees, woodlands Protecting and managing trees, woodland and and hedgerows hedgerows will be encouraged.
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Urban Regeneration
Saved Local Plan (2000) policy Description
UR1 – Urban regeneration Development assisting urban regeneration will be encouraged.
UR2 – Regeneration Priority Areas This policy designates Regeneration Priority Areas.
Natural Environment
Saved Local Plan (2000) Description policy
NE1 – Protecting The policy does not allow development on designated Urban allocated green space sites if it results in loss of Greenspace (0.25 sporting or recreation facilities, an adverse effect hectares and above) on nature conservation, the loss of a link between other areas of greenspace, or an adverse effect on the amenity or character of an area and in particular the loss of an important view or sense of openness.
NE2 – Protecting Urban Policy does not allow development on green space Greenspace (below 0.25 sites less than 0.25ha where they have significant hectares) local value.
NE3 – Developing on and The policy states that development of greenspace replacing Urban will only be allowed if an overriding justification is Greenspace demonstrated. In such cases it will be necessary to replace it within the locality or if that is not possible, improve an existing green space within the locality.
NE4 – Open areas of The policy protects the “open nature” of certain strategic importance open space on the western edge of the city.
NE5 – Locating Urban The policy sets guidelines for the maximum Greenspace walking distances to play areas and public playing areas.
NE6 – Urban Greenspace The policy specifies the amount of urban in housing development greenspace that should be provided with housing development. This is 60 sqm per house and 3 sqm play area per children’s bed space.
NE7 – Urban Greenspace The policy states that urban green space will, if in non-housing appropriate, be required in non-housing development development.
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Saved Local Plan (2000) Description policy
NE8 – Outdoor sport and The policy states that development of outdoor recreation facilities sport and recreation facilities will only be allowed if there is a surplus in the area, redeveloping a small part is the best way of retaining/improving the remainder, or alternative provision is provided. New facilities will be encouraged.
NE9 – Protecting The policy protects the best and most versatile agricultural land agricultural land from development unless there is no other suitable site available.
NE10 – Agricultural The policy supports appropriate agricultural diversification diversification.
NE11 – Protecting river The policy prevents development on urban corridors and other greenspace forming river corridors and other waterside areas waterside areas. Improvement will be supported.
NE12 – Culverting The policy states that development involving watercourses culverting watercourses will not be allowed unless there is an unacceptable risk to public safety.
NE13 – Protecting and The policy protects and supports the improvement improving the green of the allocated green network. The primary reason network given is the wildlife, but it also provides pedestrian and cycle routes.
NE14 – Sites of Nature The policy protects designated SNCIs from Conservation Interest development adversely affecting their value. The improvement of these sites will be supported. New SNCIs will be identified, if appropriate.
NE15 – Nature The policy supports development that maintains conservation and and improves the nature conservation value of development sites. It also lists a number of sites allocated for housing and employment sites that nature conservation value should be taken into account.
NE16 – Statutory sites of The policy states statutory nature sites will be nature conservation identified if appropriate. importance
NE17 – Protecting The policy protects SSSIs, Ramsar sites, SPAs statutory sites of nature and SACs unless there are imperative reasons of conservation importance public interest and there is no alternative. It also protects sites hosting priority habitat or species unless there are reasons of human health and safety.
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Saved Local Plan (2000) Description policy
NE18 – Protecting trees The policy protects the loss or damage to trees of and woodland significant amenity value by development. The City Council will make Tree Preservation Orders, if appropriate.
NE19 – Planting trees and The policy supports tree planting initiatives if they woodland do not adversely affect the nature conservation value of a site.
NE20 – Species protection The policy does not allow development that would adversely affect a species protected by legislation.
NE21 – Managing and The policy supports the management and improving Urban improvement of urban Greenspace for the benefit Greenspace of the community and wildlife.
Built Environment
Saved Local Plan (2000) Description policy
BE1 – General design The policy requires high standards of design for principles all development and sets a number of criteria that design should achieve in order to be acceptable.
BE2 – Designing for energy The policy states that high standards of energy efficiency efficiency in development will be promoted. Development will be encouraged to take energy efficiency into account in its design. Factors that will be taken into account in the design of new development are listed.
BE3 – Designing for This policy requires high standards of design for housing housing development and sets criteria for assessing applications.
BE4 – Designing urban The policy sets criteria for designing urban greenspace in housing greenspace associated with housing. Play development equipment must be installed before the houses are occupied.
BE5 – Extending or altering The policy sets out criteria for allowing property extensions to ensure they have an acceptable impact both visually and on the amenity of surrounding residents.
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Saved Local Plan (2000) Description policy
BE6 – Designing landscape The policy is aimed at ensuring a good standard of landscape is provided alongside new development.
BE7 – Designing transport The policy is aimed at ensuring transport facility facilities development is inclusive, safe for its users, and that new development does not result in loss of a route or link.
BE8 – Designing traffic The policy requires that the design of traffic management and traffic management and calming schemes takes into calming account residents, businesses, the mobility impaired, cyclists, public transport, the emergency services, and the function of the road.
BE9 – Designing The policy supports employment development employment development if it is of good quality, respects its context and provides a sense of identity and variety.
BE10 – Designing access to The policy is aimed at ensuring development is a building and its accessible to all members of the community surroundings including people with impaired mobility, sight or hearing.
BE11 – Designing a shop The policy sets out detailed criteria regarding front shop front development.
BE12 – Designing for crime The policy set design criteria for assessing how prevention development minimises the opportunity for crime.
BE13 – Designing for utility The policy aims to minimise the visual impact of facilities utility equipment.
BE14 – Designing for The policy requires apparatus to be sited and telecommunications designed to minimise its impact on amenity, taking into account operation needs.
BE15 – Public art This policy supports the provision of public art, sets criteria for the assessment for proposals for public art and requires public consultation.
BE16 – Untidy sites The policy requires the owner of land or buildings that adversely affect the appearance of the locality to achieve an acceptable standard of appearance.
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Saved Local Plan (2000) Description policy
BE17 – Designing for noise The policy sets out that noise generating generating development development will not be allowed if it has an unacceptable adverse impact. It also sets out criteria to assess all development in relation to noise.
BE18 – Conservation Areas The policy states that the Council will have special regard to preserving or enhancing the character or appearance of designated Conservation Areas.
BE19 – Development within The policy states that development within a a Conservation Area Conservation Area will be allowed if it preserves or enhances the character or appearance of the area.
BE20 – Demolishing or The policy sets out the criteria for allowing removing a building, demolition within a Conservation Area. There structure or other feature are separate criteria for the demolition of features of particular importance and for other buildings.
BE21 – Development in the The policy requires development in the vicinity vicinity of a Conservation of a Conservation Area to not detract from the Area character and appearance of the Conservation Area.
BE22 – Trees in a The policy sets out the criteria for assessing Conservation Area works to trees in Conservation Areas.
BE23 – Additional control The policy sets out that the Council will impose over development in a additional controls over minor development Conservation Area where appropriate in Conservation Areas.
BE24 – Statement of The policy required Statements to be produced Proposals for enhancing for each Conservation Area by 2006. and preserving Conservation Areas
BE25 – Listed Buildings The policy states the Council will have special regard for the retention, restoration, maintenance and continued use of Listed Buildings.
BE26 – Changing the use of The policy supports changes of use to Listed a Listed Building Buildings where there is no adverse impact on its special architectural or historic interest.
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Saved Local Plan (2000) Description policy
BE27 – Altering or adding The policy sets criteria for assessing alterations to a Listed Building and additions to Listed Buildings.
BE28 – Development within The policy sets criteria for assessing the setting of a Listed development within the curtilage of a Listed Building Building.
BE29 – Repairing and The policy supports repairs and maintenance of maintaining a Listed Listed Buildings and sets out that the Council Building will require works to be carried out if appropriate.
BE30 – Demolishing a The policy sets criteria for the demolition of a Listed Building Listed Building.
BE31 – Preserving and The policy sets out criteria for assessing protecting important important archaeological remains. archaeological remains
BE32 – Assessing The policy sets out the requirement for the development affecting assessment of archaeological remains. archaeological remains
BE33 – Minimising adverse The policy provides additional controls for effects of development on important archaeological remains. important archaeological remains
BE34 – Recording important The policy sets out how archaeological remains archaeological remains which are to affected by development should be recorded and made public.
BE35 – Displaying an The policy sets out criteria for approving consent advertisement or sign for advertisements. It includes public safety and amenity.
BE36 – Removing an The policy states that the Council will seek the advertisement or sign removal of advertisements deemed seriously detrimental to amenity or endangering public safety.
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Movement
Saved Local Plan (2000) Description policy
M1 – A balanced transport The policy gives encouragement to a balanced system transport system, promoting public transport, cycling and walking.
M2 – Transport and Development has to be located in accessible sustainable development locations. Different location criteria are set for different types of development.
M3 – Protecting the The policy states that development adjacent to the Primary Route Network Primary Route Network will take into account the main function of the road as a route for through traffic and the capacity of the road to meet predicted traffic resulting from planned major development.
M4 – Public transport The policy states that improving public transport services and facilities services and facilities will be encouraged. This can include items such as bus lanes, bus stops, and park and ride services. Designing public transport schemes will take into account road safety and the needs of the mobility impaired, pedestrians, cyclists and businesses.
M6 – Rail services and The policy encourages the retention and facilities improvement of Hull’s rail services and facilities. It will resist development detrimental to the future of the rail system.
M7 – Taxis and traffic The policy states that taxis and their users will be management schemes considered in traffic management schemes.
M8 – Protecting proposed The policy lists various public transport schemes public transport and protects land required for them from other development. Schemes include guided busways, bus corridors, park and ride sites, Ferensway bus station, passenger service on the high level railway, and new rail halts.
M9 – Cycle and The policy aims to improve and protect facilities pedestrian routes and for cyclists and pedestrians. pedestrian areas
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Saved Local Plan (2000) Description policy
M10 – Pedestrian areas The policy supports extending and improving pedestrian areas, taking into account the interests of economic vitality and viability.
M12 – Protecting The policy lists various cycle and pedestrian proposed cycle and schemes. Land required for these proposals will pedestrian schemes be protected from other development.
M13 – Traffic in housing The policy aims to reduce the impact of traffic in areas housing areas through traffic management and traffic calming.
M14 – Traffic in shopping The policy encourages traffic management areas schemes in shopping centres, taking into account the interests of economic vitality and viability.
M16 – Criteria for road The policy states that road schemes will only be schemes encouraged if they improve road safety, improve the environment, assist public transport or cyclist, enable traffic restraint measures in housing or shopping areas, improve access to employment areas, open up land for agreed development, or are part of the Primary Route Network.
M18 – Protecting The policy lists road schemes proposed in the proposed road schemes Transportation Improvement Programme, which it says was subject to review. It states that land required for these proposals will be protected from other development.
M19 – Motorcycle parking The policy supports motorcycle parking facilities.
M20 – Long stay car The policy restricts long-stay city centre parking parking to 4000 spaces.
M21 – Short stay car The policy supports appropriate short-stay parking parking in shopping centres.
M22 – Park and ride The policy encourages parking on park and ride sites allocated on the proposal map. It also encourages other park and ride sites.
M23 – Cycle parking The policy encourages cycle parking in shopping centres and other places of attraction.
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Saved Local Plan (2000) Description policy
M24 – Residents’ parking The policy says that parking schemes for residents will be considered if appropriate. This is to resolve issues where commuters use residential parking.
M25 – Coach parking The policy aims to protect coach parking in the city. The site is currently at Waterhouse Lane but an alternative site of equal benefit would also be acceptable.
M27 – Traffic impact The policy requires a Traffic Impact Assessment assessments for development making significant demands on the transport system.
M28 – Developer The policy requires developers to contribute to contributions to the off-site transport improvements deemed necessary transport system to enable a development to proceed.
M29 – Transport criteria The policy sets criteria for new development for new development regarding road access, parking, access to public transport, safe access for cyclists and pedestrians, and the mobility impaired. Development must be acceptable in terms of traffic generation and road safety.
M30 – Parking and The policy sets the off-street parking requirements servicing space for for development outside the city centre. development outside the city centre
M31 – Parking and The policy sets the parking requirements for servicing space for development in the city centre. development in the city centre
M32 – Disabled parking The policy sets the disabled parking requirements and development for development in the city.
M33 – Cycle parking and The policy sets the requirement for cycle parking development facilities.
M35 – Lorries in housing The policy aims to introduce lorry bans in areas residential areas if appropriate.
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Saved Local Plan (2000) Description policy
M36 – Freight by rail and The policy aims to encourage freight movement water by rail or water.
M37 – Regional, national The policy aims to support the development of and international regional, national and international transport links. transport links
Housing
Saved Local Plan (2000) Description policy
H1 – Housing development The policy sets criteria for assessing applications for housing development.
H3 – Providing housing land The policy sets out housing land commitments and allocations over the Local Plan period. Some of these remain undelivered.
H4 – Affordable housing The policy seeks to ensure an adequate supply requirement of land for affordable housing.
H5 – Providing affordable The policy seeks to provide affordable housing. housing
H6 – Retaining affordable The policy requires affordable housing to be housing for successive retained in perpetuity households
H7 – Special needs housing The policy seeks to ensure an adequate supply requirement of land for special needs housing.
H8 – Providing special The policy seeks to provide special needs needs housing housing on suitable housing sites, if a need is demonstrated.
H9 – Purpose built The policy sets criteria for purpose built residential institutions residential institutions and seeks to restrict changes of use between residential uses if necessary.
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Saved Local Plan (2000) Description policy
H10 – Gypsies and travellers The policy sets criteria for allowing gypsy and traveller sites and will protect existing sites.
H12 – Converting a property The policy sets out the circumstances where into self contained flats or the conversions will be allowed, precludes HiMOs extensions if they would have a detrimental impact and allows for further local policies to restrict conversions if required.
H13 – Converting a property The policy sets criteria for allowing conversion into a residential institution of a property to a residential institution. Criteria include proximity to shops and services, minimum floor size, and local amenity and appearance of the area.
H14 – Housing within The policy allows housing development within shopping centres shopping centres if there is no serious adverse affect on the shopping function of the centre.
Employment
Saved Local Plan (2000) policy Description
E1 – Employment development Employment development allowed subject to location and details
E2 – Supply of employment land
E3 – Employment land provision The policy sets out employment land commitments and proposals over the Local Plan period. It also lists the strategic employment locations.
E4 – Removing development constraints on employment land
E6 – Port-related development
E7 – Office development
E8 – Business and science parks
E9 – General employment uses
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Saved Local Plan (2000) policy Description
E10 – Employment training and initiatives
E11 – Existing employment uses within or near to housing areas
E12 – Non-employment The policy seeks to retain strategic development on employment land employment land, and employment land unless there is existing adequate provision of such land nearby.
E13 – Small businesses and The policy allows for small employment working from home development in predominant employment areas. It also allows them in residential areas so long as there are no undue adverse effects on amenity or character of the area.
E14 – Vehicle hire development The policy allows vehicle hire development within employment areas. The justification text states that this is the best location for them.
Shopping
Saved Local Plan Description (2000) policy
S1 – Shopping and related development
S2 – Existing The policy lists the types of development that will be shopping centres supported within existing shopping centres. These include shopping development, financial and professional services, food and drink uses, leisure and community facilities, and improvements to the environment, facilities, access and parking. The policy also lists the hierarchy of shopping centres across the city.
S3 – New shopping The policy supports new shopping centres in areas of centres major housing development.
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Saved Local Plan Description (2000) policy
S4 – Locating The policy sets out a sequential approach for locating shopping, financial shopping, financial and professional services, and food and professional and drink development. Major development should be services, and food located in the larger centres first. Minor development and drink should be located in any of the centres. development
S5 – Shopping The policy allows shopping development within development within shopping centres unless it would undermine the vitality shopping centres and viability of any shopping centre.
S6 – Edge of centre The policy provides the criteria for when edge-of-centre shopping development is acceptable. It should meet the development sequential test set in policy S4 and not undermine the vitality and viability of any shopping centre.
S7 – Out of centre The policy prevents out-of-centre shopping shopping development if it fails the sequential test in policy S4, development undermines the vitality and viability of any shopping centre, and would result in unsustainable travel patterns. The policy also lists three sites where out-of-centre shopping development might be acceptable.
S8 – Range of goods The policy limits the range of goods that can be sold in edge-of-centre and out-of-centre locations to bulky goods. It restricts post offices and pharmacies in these locations if such facilities exist nearby. It also sets a minimum floorspace of 950 sqm for shop units in these locations.
S9 – Shopping and The policy supports recycling facilities associated with recycling facilities shops.
S11 – Financial and The policy allows financial and professional services professional services in shopping centres if they do not undermine the shopping function of the centre and the ground floor frontage is in keeping with the character of the area. Financial and professional services outside shopping centres will be prevented from change of use to shopping.
S12 – Food and drink The policy allows food and drink development in shopping centres if they do not undermine the shopping
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Saved Local Plan Description (2000) policy
function of the centre and the ground floor frontage is in keeping with the character of the area. Food and drink development outside shopping centres will be prevented from change of use to shopping.
S13 – Motor vehicle The policy supports motor vehicle sales development sales on main roads in employment areas. Motor vehicle sales development outside shopping centres will be prevented from change of use to shopping.
S14 – Petrol filling The policy supports petrol stations on main roads in stations employment areas. It restricts associated shopping floorspace to a maximum of 150 sqm if not within a shopping centre.
S15 – Private hire The policy allows private hire booking offices on main booking offices roads in employment areas and in shopping centres. Within shopping centres they must not undermine the shopping function of the shopping centre and the frontage must be designed to be compatible with the character of the area.
Community Facilities
Saved Local Plan (2000) Description policy
CF1 – Community facility The policy sets criteria for allowing community development facility development
CF2 – Reusing community The policy supports the reuse of community buildings buildings for other community uses
CF3 – Protecting community Committed land for community facilities will be facility sites protected from other development
CF4 – Improving community The policy supports the improvement of facilities existing community facilities
CF5 – Access to community The policy sets criteria for locations where facilities community facilities should be located.
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Saved Local Plan (2000) Description policy
CF6 – Community facilities in The policy sets criteria for allowing community shopping centres facilities within shopping centres
CF7 – Pre-school childcare The policy allows pre-school childcare development.
CF8 – Primary schools The policy sets criteria for allowing primary schools
CF9 – Secondary schools The policy sets criteria for allowing secondary schools
CF10 – Further Education The policy allows further education academic facilities development.
CF11 – Higher Education The policy has three distinct strands. It allows academic facilities higher education development. It supports a University campus in the City Centre. It allocates and sets criteria for future academic development at the University of Hull.
CF12 – Health care facilities The policy has two distinct strands:
Part (a) allows health care facility development;
Part (b) provides for a committed site for hospital expansion.
CF13 – Indoor sport and The policy has two distinct strands: recreation facilities Part (a) allows indoor sport and recreation facility development;
Part (b) encourages major new sports stadium development.
CF14 – Leisure facility The policy sets a sequential approach for the development siting of leisure facility development.
CF15 – Utility and emergency The policy supports development for utility services providers and emergency services.
CF16 – Community centres The policy supports development of community centres.
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Saved Local Plan (2000) Description policy
CF17 – Crematoria and The policy supports development of crematoria cemeteries and cemetery development.
CF18 – Religious meeting The policy supports the development of places religious meeting places.
Tourism
Saved Local Plan Description (2000) policy
T1 – Tourism The policy states that tourism development will be development allowed if its location and detailed planning considerations are acceptable. It gives a list of the detailed planning considerations.
T2 – Tourism Action The policy states that there are two Tourism Action Areas Areas allocated on the proposals map. These are in the city centre and St Andrew’s Dock.
T3 – Tourist attractions The policy supports developing tourist attractions and and facilities facilities, particularly in Tourism Action Areas.
T4 – Locating tourism The policy sets a sequential approach to the location development of tourism facilities. The preferred location is within the city centre and the St Andrew’s Dock Tourism Action Areas. The sites should also be accessible.
T5 – Hotel development The policy states that hotel development will be allowed in the city centre and particularly in the Tourism Action Areas, and elsewhere if it satisfies the criteria of Policy T4.
T6 – Converting a The policy allows the conversion of residential property to a hotel properties to hotels in the city centre. They have to be at least 150sqm and if in a housing area, not result in a concentration of similar uses adversely affecting the character of the area.
T7 – Public access to The policy supports extending and improving public the River Hull and access to the River Hull and Humber Estuary Humber estuary frontages if there is no adverse effect on the operation of the Port or River Hull users.
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City Centre
Saved Local Plan (2000) Description policy
CC1 – City Centre The policy states that development will be allowed Development in the City Centre if location and detailed planning considerations are acceptable. The policy sets out what detailed planning considerations would include and clarifies that these would apply to development considered under Policies CC4 to CC48.
CC2 – City Centre land The policy encourages a range and mix of land uses use. in the City Centre
CC4 – Business, The policy supports business, financial and financial and professional service development in the City Centre. professional service development.
CC5 – General industry The policy supports altering and improving existing and storage and general industry and storage and distribution distribution development employment generating uses in the City Centre.
CC6 – Shopping The policy supports shopping development in the City Centre within the Central Area of the City Centre as designated on the Proposals Map.
CC7 – Housing The policy supports housing development within the City Centre subject to a satisfactory standard of development and amenity appropriate to the needs of the likely residents and that housing development will not prejudice future nearby non-housing uses.
CC8 – Built Environment The policy supports development that respects the distinctive character and identity of the City Centre
CC9 – Community The policy supports the development of community Facilities. facilities in the city centre.
CC10 – Tourism The policy supports tourism development in the City Centre, especially within the Marina / River Hull / Old Town Tourism Action Area.
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Saved Local Plan (2000) Description policy
CC11 – Urban The policy seeks to protect existing Urban Greenspace and public Greenspaces and public spaces within the City spaces Centre and supports their enhancement. The policy supports development that includes greenspace provision
CC17 – On Street car The policy supports schemes that provide specific parking on-street parking for residents and their visitors, and short term on-street parking for businesses and their visitors, if appropriate.
CC20 – Protecting The policy protects permanent public car parks permanent public car designated on the proposals map and listed within parks the policy. Development will only be allowed if the same number of parking spaces are provided of equal benefit to users of the City Centre.
CC21 – Improving the The policy encourages the improvement of security security and and environment of permanent public car parks environment of designated through policy CC20. permanent public car parks.
CC24 – Areas of The policy identifies Areas of Potential Change Potential Change within the City Centre and directs that development should take account of the relevant area policy, and where affected, Key Development Site criteria.
CC25–CC29 – Detailed These policies set out the detailed criteria that policies for Areas of development within each of the Areas of Potential Potential Change Change should take account of.
CC30 – Key The policy identifies Key Development Sites within Development Sites. the City Centre and directs that development will be allowed if it complies with appropriate criteria set out for each site.
CC31–CC48 – Detailed These policies set out the detailed criteria that policies for Key development within each of the Key Development Development Sites Sites should take account of.
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Docklands
Saved Local Plan (2000) Description policy
D1 – Priory Park The policy supports employment development at Priory Park. It sets out a number of considerations that should be taken into account
D3 – St Andrew’s Dock and The policy lists the types of development that will St Andrew’s Quay be supported at St Andrews Dock and Quay.
D4 – Albert/William Wright The policy supports port-related development at Docks Albert/William Wright Docks.
D6 – Alexandra Dock The policy supports port-related development at Alexandra Dock.
D7 – Multi-purpose docking The policy supports a new docking facility south facility of Alexandra Dock that would extend out into the Humber Estuary. It was known as Quay 2000.
D8 – King George/Queen The policy supports port-related development at Elizabeth Docks King George / Queen Elizabeth Docks.
D9 – Marfleet The policy supports employment and housing development in the Marfleet area.
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