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Clerk to the Parish Council: Mr. K. Langley 33, Flats Lane, Barwick in Elmet, Leeds, LS15 4LJ Telephone 0113 393 5861: Email – [email protected]

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Clerk to the Parish Council: Mr. K. Langley 33, Flats Lane, Barwick in Elmet, Leeds, LS15 4LJ Telephone 0113 393 5861: Email – Clerkls154@Btinternet.Com BARWICK IN ELMET AND SCHOLES PARISH COUNCIL’S RESPONSE TO LCC’S RESPONSE TO COMMENTS ON EB9/35 & EB9/36 - LEEDS SITE ALLOCATIONS PLAN EXAMINATION Clerk to the Parish Council: Mr. K. Langley 33, Flats Lane, Barwick in Elmet, Leeds, LS15 4LJ telephone 0113 393 5861: email – [email protected] Introduction This representation is from Barwick In Elmet and Scholes Parish Council (“BIESPC”) regarding matters 5 and 7 submitted on 10 September 2018. This is our feedback to the Inspectors regarding the responses made by Leeds City Council (“LCC”) dated 22 August 2018 emanating from the EiP. LCC’s responses made to EB9/35 & EB9/36 are in black ink. BIESPC’s feedback responses to LCC’s comments (by BIESPC) are in blue ink. Barwick In Elmet and Scholes Parish Council’s Representation 1. Leeds City Council thanks the Inspectors for this opportunity to comment on the responses received to Examination documents EB9/35 and EB9/36. A significant proportion of responses received (35 out of 100) do not engage with the modelling work and instead re-iterate comments made earlier in the SAP process. Summarised below is the Council’s response to relevant comments raised in the responses. The Council does not consider that any of the comments raise issues of soundness in respect of proposed allocations at MX2-39 and HG2- 124. Response By subtraction from LCC’s point, 65% - a significant majority - of the responses to Examination documents do engage with the modelling work and provide eye witness commentaries on how the highways around the Parlington site are currently performing. BIESPC argues therefore that whilst the responses do not specifically use the word UNSOUND, or NOT SOUND, the comments are wholly objections to the Site Allocations Plan based on the unmitigated impacts of MX2-39. BIESPC therefore contends that this makes LCC’s comments, in Paragraph 1 above, incorrect. Comment: The modelling work has been prepared and shared too late for consultees to adequately engage with 2. The transport modelling results that are summarised in EB9/35 and EB9/36 represent a further iteration of the work already completed to assess the impacts of the SAP and which has already been reported in the Infrastructure Background Paper (EX51, Appendix 3). Response This is not clearly seen in EX51 Appendix 3. Paragraph 5 refers to “Transport Modelling Work” without referring to any specific model. Appendix 3 focuses on ranking criteria definitions only. © BIESPC Response to LCC’s comments on EB9/35 & EB9/36 Page 1 of 13 September 2018 BARWICK IN ELMET AND SCHOLES PARISH COUNCIL’S RESPONSE TO LCC’S RESPONSE TO COMMENTS ON EB9/35 & EB9/36 - LEEDS SITE ALLOCATIONS PLAN EXAMINATION If the ‘iteration’ results supersede the previous work, then the previous work is largely irrelevant from BIESPC’s point of view. EB9/35 & EB9/36 were not made available to the public until 28 June 2018, only 10 days before the start of the Examination in Public (EiP). Some of BIESPC’s councillors have volunteered to work as part of the Save Parlington Action Group (“SPAG”), which is a voluntary group whose members have limited time to review such substantial and technical documents. Work and family commitments in addition to the attendance at the EiP have made the last few months a busy period for BIESPC, and so when there was insufficient detail in that information provided we agreed with SPAG’s request at the EiP for further detail to be provided. We have noted that deficiencies still remain in the latest Transport modelling results in any event. Irrespective of the date on which this information was formally produced at Examination, it is emphasised that this work reflects the earlier results of the original strategic modelling (CD1-35 published May 2017) and the proposed site requirements, in particular: the need to improve M1 Jn 47; the requirements for a bypass of Garforth and impacts at M1 Jn 46. There has also been adequate time since production at the Examination for detailed responses to come forward. No party challenges, through any positive work of their own, the robustness of this modelling. Response BIESPC attended some of the EiP sessions. On 11th July. LCC’s officer Tim Harvey advised the Inspectors that the reports EB9/35 and EB9/36 “have allowed the Council to understand what is needed” in the east Leeds area. This statement was in relation to MX2-39 and HG2-124. He also followed on by saying “there is a huge amount of detail, and CD1/35 provides an overview.” Mr Harvey’s statement advises the Inspectors that LCC itself did not understand what was needed before the reports were completed. His statement also refutes LCC’s comments above that “there has been adequate time since production at the Examination for detailed responses to come forward”. BIESPC challenges the robustness of the overall modelling and reporting process by LCC since the Parlington site, policy MX2-39, was created by LCC. Herein BIESPC also challenges the accuracy and robustness of EB9/35 and EB9/36. The statement by LCC above, that “no party challenges, through any positive work of their own” is disrespectful. As mentioned BIESPC, for example, has had no sight of the modelling until June, nor have parties, such as BIESPC, had the data behind the reports. The TTHC report, commissioned by the Save Parlington Action group, M17902-03, highlights that modelling information remains outstanding in any event. Parish Council and group requests for sight of Highways England’s work have continued for over 15 months. The tardiness of LCC’s response to such requests for information is symptomatic of the fact that the policy MX2-39 was simply a last-minute replacement to cover ONE HMCA’s need to attain its target dwelling numbers at all costs. © BIESPC Response to LCC’s comments on EB9/35 & EB9/36 Page 2 of 13 September 2018 BARWICK IN ELMET AND SCHOLES PARISH COUNCIL’S RESPONSE TO LCC’S RESPONSE TO COMMENTS ON EB9/35 & EB9/36 - LEEDS SITE ALLOCATIONS PLAN EXAMINATION BIESPC attended the EiP on 11th July 2018 and witnessed LCC’s Mr Harvey reporting that “the work on the reports commenced during the Spring of 2017 with the modelling carried out during the summer (2017)”. BIESPC also witnessed SPAG’s requests to Highways England in August 2017 being answered with the advice that the modelling wasn’t completed. An important issue for BIESPC is that the modelling indicates, for the first time, the route of the second access road into and out of the Parlington allocation. We are sure the Inspectors, as well as BIESPC, perceive that it’s no coincidence that the HE reports, and the M & G Masterplan documents, were made available at approximately the same time. Of course, the Inspectors haven’t accepted the latter document for the EiP and we support that decision. Until we became aware of the full details of the allocation it was not possible for us to provide any accurate and detailed responses. This point therefore refutes LCC’s statement “There has also been adequate time since production at the Examination for detailed responses to come forward.” If it takes LCC months to generate a report that LCC says is an iteration of previous work, then we are astounded that the Inspectors are asked, by LCC, to agree to this statement. We supported questions to LCC, via the Inspectors at the EiP, about details of the costings for the improvements. LCC was asked whether they existed? LCC’s response was not forthcoming and BIESPC, and the Inspectors, are no wiser. We now know that the costing has not been undertaken. Costing has not and cannot be undertaken given the lack of scheme details, which is demonstrated in TTHC’s M17902-03. CD1/35 refers to the Leeds Transport Model and makes the statement that the analysis has led to a number of transport interventions (page 27). CD1/35 states, in paragraph 2.39, that “At this stage it has not been possible to model the schemes and assess the cumulative impact on the wider network”. In Paragraph 2.40, CD1/35 states “the plan shows these identified interventions”, however that plan does not show the second access route for the Parlington site. This appears to be another instance where LCC is proving that its SAP is not positively prepared, not effective and not justified – it is therefore UNSOUND. We contend that there will be congestion emanating from any junction built on Long Lane and would like the Inspectors to view the roads around the Parlington site. On page 74 there is no mention of “Modelling underway to identified schemes” for Junction 46 and no mention of modelling results for J47. In Paragraph 6.25, page number 129, states that model tests have been run containing the majority of the major interventions. M1 J47 and A63 Southern Garforth Bypass are listed in the Do Something Plus test, but no feasibility work has been undertaken. SPAG’s M17902-03 highlights that modelling work remains outstanding, and that conclusions cannot be drawn on this basis. This modelling work has neither been prepared (or formally produced) too late for consultees. Response The comments above refute this LCC statement. © BIESPC Response to LCC’s comments on EB9/35 & EB9/36 Page 3 of 13 September 2018 BARWICK IN ELMET AND SCHOLES PARISH COUNCIL’S RESPONSE TO LCC’S RESPONSE TO COMMENTS ON EB9/35 & EB9/36 - LEEDS SITE ALLOCATIONS PLAN EXAMINATION Comment: The level of impact predicted in the model is substantial and unsound 3. As highlighted in EX51 Appendix 3 it is considered that the model forecast increases in traffic associated with the SAP are highly likely to materially exceed actual impacts.
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