SAVE PARLINGTON ACTION GROUP RESPONSE TO INSPECTORS MATTERS, ISSUES AND QUESTIONS LEEDS SITE ALLOCATIONS PLAN EXAMINATION MATTER 5A – M5.7.2

Matter 5A – Revised Submission SAP Infrastructure

Issue: Whether the necessary infrastructure will be in place to support the planned development

1. Question 1: For sites which have been brought forward in to Phase 1 in the Revised Submission SAP does the evidence demonstrate that the necessary critical infrastructure will be provided in a timely manner to support the planned delivery of development? (See Appendix 1 for relevant sites).

1.1 SPAG has reviewed the critical local and strategic infrastructure needed in order for the Parlington site to be a successful location for residential accommodation. As there is minimal infrastructure currently, and possibly no infrastructure useful to the delivery of the allocation, implementing the requisite infrastructure will be a complex and difficult process.

1.2 There is little evidence that demonstrates that the critical infrastructure will be provided in a timely manner to support the planned delivery of development of the Parlington site MX2-39.

1.3 Indeed, delivery is unlikely to occur in time for the first occupied dwelling; our comments supporting this statement are below.

1.4 Infrastructure delivery – site specific plans - In LCC’s Background Paper (CD1/35), page 10, point 1.10 the document states that the “most appropriate sites for SAP and AVLAAP allocations have been proposed having regard to planning, highways, environmental and other considerations. The site selection process has been informed by the consultee comments of infrastructure providers or technical planning consultees. Some allocations contain site specific requirements relating to infrastructure. These set out where sites cannot come forward without delivering infrastructure improvements or contributing land or payments towards locally identified priorities.”

1.5 The above is contentious regarding MX2-39. SPAG argues that there is no current infrastructure whatsoever for residential housing. The allocation of MX2-39, therefore, does not have one or two “specific requirements relating to infrastructure”, the site requires all aspects of infrastructure to be delivered before a single resident can move into a single dwelling.

1.6 MX2-39 – an unsustainable site as assessed by LCC, At the last consultation of February 2018, LCC continued to make reference to the Parlington site as:

“An Area Of Land For A New Sustainable Settlement Has Been Identified At Parlington (See Plan Edged Orange (Providing For Up To 5,000 Homes)”.

1.7 At that time the Parlington site failed LCC’s own sustainability appraisal and scored badly on almost all of the Sustainability Objectives as set out in LCC’s document CD1-17 Submission Draft Sustainability Appraisal Report May 2017, page 23 section 4.24. SPAG has contended, since the outset of the SAP consultation process in 2016, that MX2-39 was, and remains, an unsustainable site because of the lack of infrastructure at and around the site.

1.8 As the site scores low on all Sustainability Appraisal objectives SPAG contends Amendment 64 for MX2-39a should NOT BE CLASSED in any LCC documentation, and certainly not be orally or verbally described, AS A SUSTAINABLE SITE.

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1.9 Yet LCC described the site as “… Allocated For The First Phase Of The New Sustainable Settlement (C 1,850 for 792 Dwellings) (114ha) And 5ha Of General Employment Land. A wider area of land surrounding the allocation (outlined in blue) has been designated as a Broad Location for Growth (BL42) and will potentially supplement the initial allocation subject to a further review of the Plan.”.

1.10 Accessibility and the strategic and local road network

1.11 Policy MX2-39 describes a single access road into the site from the B1217. The access road has still to be designed and the planning application process is expected to be long and drawn out. SPAG will describe the detail of the landscape that the access road has to cut into at the EiP.

1.12 LCC’s stated intention is for this access road to connect to the B1217. The B1217 is a single carriageway road that has a large volume of traffic during the working week.

1.13 In order to gain access to MX2-39 a new junction will be needed somewhere along the B1217, and this access will have to be developed from scratch. Furthermore, due to the B1217’s close proximity to the M1 J47, SPAG will explain, at the EiP, that this will create significant impediments to the current flows of traffic both during the course of building the junction, and thereafter.

1.14 Around the Parlington site the strategic road (M1, A1 or M62) and local road (A64, A63, A58 and B1217, Cattle Lane, Long Lane and Great North Road) networks are, at present, not coping with:

I. The continuum of increased volume of traffic at peak times;

II. The traffic jams on the non-strategic roads when there is an incident on one or more of the strategic roads;

III. Traffic jams on the non-strategic roads when there is an incident on the non-strategic roads;

1.15 Strategic road network LCC’s MX2-39 plan appears to be significantly reliant on the access to the M1 at Junction 47. Highways England has stated that the M1 is unable to cope with increased traffic from a number of sources in the emerging East Leeds Extension building programme, which includes the East Leeds Orbital Route (“ELOR”), Thorpe Park (comprising retail, leisure and housing facilities), the Manston Lane Link Road and the 5,000+ houses that are expected to be built on ELOR’s western border. Inherent in LCC’s design for ELOR is access to the M1 (via Thorpe Park).

1.16 Difficulties on the strategic road network are well known and documented. Simon Jones, Spatial Planning Manager (Yorkshire, Humberside and North East) of Highways England stated the following, in his correspondence with Barwick In Elmet and Scholes Parish Council on 21st March 2018, when asked about the ability of the strategic network to cope with traffic at Junctions 46 and 47 of the M1 (his answers are in red text)

i. “As further East Leeds Extension housing development comes forward, it will be necessary for site promoters with the Council to identify and mitigate their impact on the M1 in order to ensure that they do not exacerbate current levels of congestion”

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ii. “As stated in our Route Strategy for London to Scotland East, we are aware that congestion on the local road network causes queuing back to M1 junction 46, leading to issues on diverging slips between junction 46 and junction 47.”

1.17 The ELE does not include the Parlington site and so with Parlington the issues will become greater. However, his statement advises that it will be necessary for the site promotors to identify and mitigate their impact on the M1.

1.18 It should be noted by the Inspector that in point 2 Mr Jones appears to be laying the blame on the local roads for the current queuing of cars on the M1 north carriageway. The queues extend (tailback) from J47 M1 to J46 M1. The reality is that the local and strategic road networks cannot, in combination, cope with the current traffic situation.

1.19 Local road network

1.20 LCC does not offer any local road changes or enhancements in its SAP to accommodate the growth in traffic to and from the Parlington site, whether for building materials or earth moving equipment. Despite there being several small access roads into the site, there is no capacity for the country lanes around Parlington to enable access of heavy machinery. SPAG will explain this further at the EiP.

1.21 The existing road system does not provide easy access to MX2-39’s proposed main access road. As MX2-39’s main access route emanates from the busy B1217, SPAG highlights to the Inspector that this road traverses the M1 at J47.

1.22 SPAG contends that if a new major junction is built on the B1217 between J47 roundabout and Hook Moor, this will increase the congestion that Simon Jones refers to in his point 2 above.

1.23 The layout of the roads around Parlington’s proposed access road means that drivers wishing to access the M1 northbound and southbound can use J47 but it has its constraints and drivers wishing to drive southbound on the A1 will have to travel an extra 5 miles northbound before turning south at A1 J44.

1.24 The restrictions now seen on the poor local road network would take a long time to mitigate due to various factors including the following:

I. Existing B roads surrounding the site will need to be significantly enhanced (widened and straightened);

II. The strategic road system is at capacity and Highways England has not yet stated proposed any solutions to the cumulative effect of the East Leeds Extension;

III. Any new roads will take a long time to plan, consult on and deliver. The exemplar for the length of time taken is the East Leeds Orbital Route (“ELOR”) which has been in the planning stage for over 20 years – as at 13th June 2018, work has still not started on the ELOR;

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IV. The knock-on effect of modification of existing roads which would divert traffic from established routes and create hazardous rat running through the surrounding villages;

V. The above issues are further compounded as the main access road requires a brand new junction, which does not currently exist and which will have a detrimental effect on currently well-used and busy route. LCC and Highways England cannot offer alternative routes as they do not exist. LCC has not planned for or offered any mitigation to the above. In summary existing commuters and users of the local roads around Parlington will have their daily commutes impaired significantly by the building of the junction with the B1217.

1.25 The above contradicts West Yorkshire Transport’s strategy of (EB9/18) which states the following 3 objectives:

I. Improve connectivity and reduce congestion- thereby increasing business productivity and providing access to wider labour markets;

II. Have a positive impact on our built and natural environment - increasing longer term resilience against climate change;

III. Create a 'sense of place' – encouraging walking and cycling for health and other benefits and increasing access in a safe way;

1.26 SPAG contends that neither LCC nor Highways England will be able to mitigate the impacts of house building at Parlington whether this is for the 792 number or anything greater and this contradicts LCC’s own Core Strategy policies. SPAG believes that LCC will fail to deliver the West Yorkshire Transport Strategy (EB9/18) objectives.

1.27 SPAG anticipates that there may have been discussions between the owner of the Parlington site, LCC and Highways England regarding the work required to mitigate the traffic issues. It may be that such discussions are being undertaken now. Until records of such discussions, including the funding required, are released into the public domain it is not prudent for SPAG to make speculative comments. However, if such information becomes available during the EiP SPAG will provide its comments to the Inspector.

1.28 SPAG is clear in its belief that any changes to the local and strategic road system will have to pass through the due planning processes. Mitigation cannot be achieved without changes to all of the roads around the Parlington site, and this will take many years to complete before any work commences.

1.29 The use of the existing road infrastructure is therefore UNSOUND making MX2-39 UNSOUND.

1.30 SPAG contends, the surrounding settlements and the road networks are UNABLE to offer any infrastructure to support LCC’s allocation of the Parlington site due to the restrictions of the individual roads, namely:

• Cattle Lane – this cannot be used for the second access to the site due to its size and topography and has a severe right angle bends that are very difficult to traverse by public

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transport vehicles and lorries. It should be noted that LCC is planning on imposing a 20mph speed restriction in Barwick and Aberford;

• Long Lane – this is a narrow road with two single track stretches, one at Laverack Bridge and one at the railway bridge;

• B1217 – this is a narrow road that Highways England appears to cite as one reason for the queues on the M1 at J47. Mitigation will require significant widening of the road from J47 to beyond the M1 and A1 bridges towards Lotherton. SPAG believes that these could possibly be rebuilt to accommodate such widening BUT ONLY AT HUGE COST;

• Great North Road – whist this is a wide road from Hook Moor northwards into Aberford, the road narrows in Aberford village. Legitimate road side parking adds to the difficulties of traversing the village.

1.31 Incidents on the roads that service our settlements create damaging queues that bring other parts of the road system to a standstill. Significantly this occurs within the village centres as motorists attempt to find a route past the primary incident. The nett result is that the M1 no longer offers a reliable route to and from the Parlington site.

1.32 At the EiP SPAG will describe the effect of incidents occurring on the strategic road system on the local road system and the harm done to the settlements that surround the Parlington site. We will also provide evidence that the local road network has no capacity for any additional traffic such as that generated from even from the proposed 792 dwellings at MX2-39.

1.33 Rail travel - HS2 - As HS2 offers little support to the policy MX2-39 it is worthwhile briefly describing the HS2 route. It will traverse an east/west route immediately south of M1 J47. Although this is within 2 km of the proposed housing at MX2-39, SPAG notifies the Inspector that:

o HS2 trains will not stop at any stations between Wakefield and York (no stations are planned for Garforth);

o HS2 will not provide a service between Leeds and York – there is no HS2 link between Leeds and York;

1.34 Network Rail’s infrastructure At the EiP SPAG will explain that there is no new capacity planned for the existing Leeds/York/Selby line.

1.35 The strategic rail network passes through Garforth, which currently has stations at East Garforth and Garforth. The twin lines (one up line and one down line) currently do support commuter services between Leeds and Selby and Leeds and York). The new (May 2018) timetables for Northern and TransPennine services have removed significant commuter train services and these stations are now not providing the needed number of trains for the current commuters - longer haul services are taking a greater precedent over commuter trains. It is clear that the train operators do not see commuters from and to Garforth as sufficiently profitable to warrant respectable services.

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1.36 Until the number of lines passing through Garforth is increased from two to four (two up and two down) by Network Rail, any notion of LCC stating that rail travel helps to make the Parlington site sustainable is now destroyed.

1.37 SPAG contends that LCC and the land owner M & G have not consulted with the train operators as this would have been withdrawn from LCC’s argument for the promotion of the Parlington site.

1.38 Services from Leeds to York, Newcastle, Edinburgh and Glasgow will still operate on the existing Leeds/York/Selby line and with the passenger growth continuum seen on the railways over the past decade or so SPAG expects the capacity problems to be manifest in increased inconvenience to passengers and will fail to achieve the objectives of the West Yorkshire Transport EB9/18 strategy.

1.39 We will explain to the Inspector the state of the provision of commuter services from East Garforth and Garforth to Leeds, York and Selby now and into the near future. SPAG anticipates that additional rail services will not be available in a timely manner as there is no planned mitigation to the line’s current capacity problems.

1.40 Second access road - LCC has deemed that a second access road is required. As at 13th June the route of this access road is unknown to SPAG. At the EiP we will describe to the Inspector the possible routes and the landscape in which the road will be cut.

1.42 - Poor site accessibility impacting provision of electricity, gas and water services – This accessibility issues will make it difficult for the services to be delivered in a timely manner. SPAG contends that until the primary access road is built very little of this infrastructure will be constructed and delivered. We will describe this to the Inspector at the EiP.

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2. Question 2 - Is it necessary to be satisfied that the critical infrastructure is likely to be provided in a timely manner for development in Broad Locations given Policy BL1 confirms they will contribute to the CS housing requirement?

2.1 Whilst developing our rationale above we anticipated this question and we reviewed the effects on the infrastructure if Policy BL1 confirms they will contribute to the CS housing requirement.

2.2 In SPAG’s view the idea of more dwellings on the site will simply exacerbate the situations described above. Where the roads and rail systems are unable to cope without major overhaul – specifically the local and strategic road and rail systems - more houses and more cars and more journeys will create more congestion.

2.3 Therefore, we believe that it is necessary to be satisfied that the critical infrastructure can be provided in a timely manner. SPAG will provide its rationale for this perspective at the EiP.

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