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

Home , Aberford, Garforth, Harewood (ward), Kirkstall, Leeds, Leeds City Council

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.

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.

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.

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. Past trends suggest lower increases as being most likely, linear with population increases. One reason behind this is that the models treat traffic levels as being proportionate to household numbers rather than population levels. The modelling represents a worst-case scenario only. This applies equally to the Garforth and East Leeds modelling;

We cross reference our response to this point to paragraphs 2.0 - 2.9 of SPAG’s M17902-03.

4. To date, the modelling does not take account of the significant investment in public transport taking place as part of the Leeds Public Transport Improvement Programme (LPTIP). These interventions are under development, as described in the IDP (EX51 Appendix 1). These interventions will act to reduce traffic demand across the District, although it is recognised that the impact in East Leeds may be more limited than in other corridors;

As stated above by LCC, the interventions in East Leeds will have little effect in mitigating the impacts of the Parlington and Stourton Grange sites – therefore we regard this statement as tautology - irrelevant in the ONE/OSE HMCAs.

The interventions referred to above in EX51 Appendix 1 that are physically close to Parlington are (listed in ranking order):

Rank Location/junction Description Schemes 41 A6120 (Ring Road)/A64 Barwick Road Constrained site roundabout ELOR 45 A6120 (Ring Road)/A64 York Road Constrained site/roundabout ELOR 55 A642/B6137 Very constrained/roundabout None listed by LCC

Rank 41. A6120 Ring Road/A64 Barwick Road. LCC expects that “the ELOR scheme will remove the traffic from this junction” (Page no 62 EX51).

BIESPC is concerned that ELOR will move the congestion further eastwards and introduce west bound delays. LCC already admits that ELOR will create delays on Leeds Road on the east side of the proposed roundabout with Barwick Road. The LCC statement that ELOR will remove traffic from this junction may be technically correct, but that doesn’t mean that traffic flows will be improved. BIESPC is so concerned about the detrimental effect of this roundabout it has requested LCC to replace it with an underpass or an overpass to prevent the traffic from backing up into Scholes.

We contend that this scheme will not mitigate the impacts of traffic generated from Parlington.

Rank 45. A6120 Ring Road/A64 York Road. LCC expects that “the ELOR scheme will remove traffic from this junction” (EX51 page no 63).

We contend that this will create a backlog of traffic in both directions east and west on the A64, with specific concern between the ELOR roundabout and J44 A1 (A1/A64 Bramham Crossroads). With this impact, the further impact will manifest as rat running traffic through Potterton, Barwick and Aberford.

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 has requested that the ELOR roundabout discussed in 41 above be replaced with an underpass or an overpass to prevent the traffic from backing up into Scholes.

We contend that this scheme will not mitigate the impacts of traffic generated from Parlington.

Rank 55. A642/B6137 Main Street, Garforth. This is a very constrained junction and LCC identifies that there is no mitigation and believes that this junction will remain constrained.

We therefore contend that the entire statement in this paragraph 4 is false and cannot be applied to the mitigation of impacts from MX2-39.

BIESPC delegates were in attendance when, in addition to the above, LCC’s officer Tim Harvey described to the Inspectorate at the EiP (11th July 2018), about LCC’s investment of £750 millions in highways. He described that new stations are emerging and that Park and Ride options are the best solution. Mr Harvey mentioned Leeds Council’s strategic plan yet none of the schemes he referred to will mitigate the impacts of the extra traffic sourced from Parlington. Clearly there is a lack of planning credibility emanating from LCC.

The above proves that LCC’s SAP policy MX2-39 is not positively prepared and is not effective. We contend, therefore, that MX2-39 is UNSOUND.

5. Nevertheless, it is considered that notwithstanding the delivery of planned transport schemes and mitigation, traffic congestion is likely to increase across the District as a whole as a result of allocations in the SAP (EX51 Appendix 3) and that this will apply equally in the Garforth and East Leeds area (EB9/35 and 36). As highlighted in the Transport Background Paper and its accompanying Hotspots Appendix (EX51 Appendix 3) the majority of congested junctions in Leeds are constrained in terms of available land to permit improvements to be carried out without significant land take and property impacts. Where land is available, improvements may still be restricted and equally may simply move the queue to the next bottleneck downstream (EX51 Appendix 3 para 6.43). This applies equally in the Garforth and East Leeds area.

LCC admits that traffic congestion will get worse “as a whole as a result of allocations in the SAP” – see above.

We stress to the Inspectors that this will apply around the Parlington site, exceptionally impacting Garforth, Aberford and Barwick in Elmet. LCC is relying on the M1 to mitigate the congestion from Parlington traffic but the M1 has congestion issues currently. This reliance becomes a significant weakness in LCC’s defence of its policy MX2-39.

At the closing session of the EiP on 3rd August 2018 Inspectors Sherratt and Gibbons requested site visits to certain SAP sites, and expressed the importance of a visit to the Parlington site specifically.

Herein BIESPC recommends that the Inspectors do take a guided tour of the roads, lanes and access routes that surround the MX2-39 site and inspect the same infrastructure that M & G and LCC are claiming will support MX2-39 (the M & G delegates are welcome to attend such a guided tour even though it is outside the site’s boundaries).

In addition to paragraphs 2.8 – 2.9 of SPAG’s report M17902-03 regarding trips including ‘education journeys’ . At the EiP on Friday 3rd August, LCC’s Mr McGrath discussed the education services that

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 would be available to residents of the Parlington site should MX2-39 be allocated. He referred to a reasonable percentage of children attending the John Smeaton School in Penda’s Fields. As the Inspectors know from the representations and the evidence proffered in the EiP there is no direct route from the Parlington site to John Smeaton School. The options for accessing this school from the Parlington site are either via Long Lane and through Barwick in Elmet or along Aberford Road (B1217), the long way around the Parlington site via Aberford, or along the A642 to the A642 / B6137 Main St, Garforth (signalled junction).

In each case the journey would require crossing or travelling on the ELOR. Such trips would impact the local road network as these need to be traversed to get to the ELOR. This has not been accounted for by the LCC traffic modelling.

We further iterate the contradictions regarding LCC’s preferred option detailed in paragraphs 3.8 – 3.10 of SPAG’s M17902-03. These contradictions prove that the plan is UNSOUND as it is not positively prepared and not effective.

6. Constraints on the main Leeds road network in the peak periods have over time resulted in peak spreading (as shown in the Transport Background Paper EX51 Appendix 3) and it is considered that this effect will continue into the future. Equally, greater numbers of drivers have switched to the minor road network, resulting in ‘rat running’. Given the constraints on the main roads this practise is also likely to continue into the future and both the city wide and the Garforth and East Leeds modelling reflects this.

The model results do not evidence suitable mitigation of traffic impacts. The statement “greater numbers of drivers have switched to the minor road network, resulting in ‘rat running’” is LCC’s admission that the existing road network is at capacity.

Disappointingly LCC has no solution for its current traffic congestion dilemma. This means that additional traffic will exacerbate what the SAVE PARLINGTON ACTION GROUP has referred to as the “capacity crisis”.

Furthermore, in line with paragraphs 3.2 – 3.7 of SPAG’s M17902-03, BIESPC refutes that these measures will provide signification mitigation.

7. The Council and its partners are working hard to deliver improved sustainable transport alternatives to the private car through the LPTIP and WYPTF workstreams. These ambitions are reflected in the high level targets in the West Yorkshire Transport Strategy (EB9/18) and the aim to double bus patronage as part of LPTIP (EB9/17).

The above so-called sustainable transport alternatives will not benefit any householders of the Parlington site. As the Inspectors know, the use of buses is naturally restricted by the narrow roads on the local network, the low Barwick Bridge on Long Lane, the single file Laverack Bridge and the constrained A642/B6137 Main Street, Garforth junction.

As LCC states, the alternatives are ambitions only and the evidence provided at the EiP showed nothing tangible for mitigation.

The point LCC tries to make about delivering “improved sustainable transport alternatives to the private car through LPTIP and WYPTF workstreams” is contradicted by the proposed clean air zone (“CAZ”). The proposed CAZ boundary follows the A6120 Ring Road around the west, north and

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 eastern sides of Leeds. It requires non-private cars (such as buses, taxis, commercial delivery vehicles) to pay a daily fee to allow travel within the CAZ. Private vehicles, such as owned by residents and non-residents of Leeds, will not be required to pay a fee.

The structure of this CAZ seems to contradict LCC’s statement about discouraging private car usage when the CAZ is encouraging the use of private vehicles.

Nevertheless, it will be up to individual drivers to make their own choice about how they travel and it has to be recognised that if they elect to drive there will be consequences in terms of increased traffic, congestion and rat-running. It is also acknowledged that additional highway capacity can, in congested conditions, generate traffic. There is inevitably a balance to be struck in delivering infrastructure enhancements. This is in part reflected in Core Strategy Spatial Policy 11 (CD2/1) which refers to targeted highway schemes to alleviate congestion for local and strategic orbital movement and the SRN.

BIESPC is amazed by the wording above. LCC offers no choices to commuters and travellers as it will not mitigate the current congestion never mind the future predicted congestion.

LCC appears to be encouraging private car usage from its:

- The lack of public transport alternatives; - The structure of the CAZ; - The substandard bus services that are inevitable due to the narrow, winding and undulating routes offered to get to and from the Parlington site; - Complete lack of supplying the requisite infrastructure for the site.

The point above shows that infrastructure does not form part of the SAP and this makes it not positively prepared and not effective. The SAP is therefore UNSOUND.

8. The Core Strategy housing targets include additional housing in the eastern side of the District in the East, ONE and OSE HMCAs. This represents around a 40% increase in households over the plan period1 compared with 22% across the District as a whole. Notwithstanding which sites are ultimately allocated there will be a resulting significant increase in travel demand in this part of Leeds and it is extremely optimistic of objectors to some of the proposed major sites in this area to assume that any alternatives will result comparatively in substantially reduced impacts across the wider network.

LCC is misrepresenting BIESPC and other objectors on this point. Our concern is the extra volume of traffic emanating from the specific site that will affect the road network around Garforth, Aberford and Barwick In Elmet. There is currently substantial overload – capacity crisis - on the roads that surround the Parlington site.

We don’t believe that LCC has complied with Legal Requirements and has not: 1. Reflected infrastructure requirements arising from future growth as recognised in the National Planning Policy Framework (NPPF) (CD3/1) Para 8: 2. Set the strategic priorities for the area of a Local Plan, including the provision of infrastructure” (Para 20). 3. Planned positively for the development and infrastructure required in the area to meet objectives, principles and policies.

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

9. Indeed, one of the principal benefits with allocating housing in major sites such as Parlington (MX2-39) and Stourton Grange Farm South (HG2-124) is that this facilitates the delivery of infrastructure that smaller sites would be unable to provide.

LCC hasn’t proved this for the Parlington site. It actually appears that the opposite has occurred and the large scale modelling required for the larger sites has not been carried out. This is as evidenced in our responses to the points in this document where LCC has not included all the relevant data known at the time the modelling was undertaken and on the insufficient detail that LCC has presented to the Inspectors.

Throughout the EiP it also became apparent that LCC has not evidenced a robust sustainability comparison of “major sites” with “smaller sites” and, as such, cannot prove that “smaller sites” would be unable to facilitate the same delivery of infrastructure.

Notwithstanding the above, BIESPC refers you to paragraphs 4.0 – 4.8 of SPAG’s M17902-03 with further regard to the credibility of the traffic modelling inputs, results and mitigation required.

Additionally, the proximity of both these sites to the rail network at Garforth represents an important element of encouraging sustainable travel.

Garforth train station is more than 3 miles from Parlington. This is not conventionally considered to be a close or feasible walking distance at the beginning and end of a working day and would therefore not contribute to encouraging sustainable travel. Previous representations made by residents of the Parish, and BIESPC, have also illustrated that car parking at Garforth station is impossible past 7:30am. Similarly, East Garforth station is not easily accessible and cannot support the Parlington site’s residents.

This option is simply not available to other locations in ONE HMCA and this is reflected in the very high levels of car commuting by residents of the Harewood and Wetherby wards which also have relatively low levels of bus provision and long journey times to Leeds city centre.

BIESPC is confused by this statement. Aberford and Potterton (part of BIESPC) in particular, which sit in the Harewood ward (Aberford is in the same parish as Parlington), are prime examples of locations with high levels of car commuting and low levels of bus provision and long journey times to Leeds city centre. Potterton in many ways could be a test case, albeit on a very small scale, for the way the Parlington site’s traffic will behave as it is a cul-de-sac hamlet with few access options.

This statement also appears to be another contradiction by LCC who has always referred to Parlington as being car dependent and dormitory. BIESPC notes that in the minutes of the Development Plan Panel, 10th January, 2017 it states; “In response to concerns raised about traffic generated by this large site which in all likelihood would be car based dwellers, officers responded that the site proposers would have to undertake more work in order to achieve a sound plan to present to the Inspector.” We wonder if this work has been carried out satisfactorily; the evidence shows that the residents of MX2-39 will in fact actually be car based dwellers.

10. The level of impact predicted in the model is neither substantial nor objectionably so. Similarly, the level of impact is not unsound.

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 The above statement is trivialising the issues that the house building in Parlington will create. The necessity for new access roads from Aberford Road and Long Lane are huge construction projects. The need to build the South Garforth Bypass is an enormous project on its own and, based on the development lead time of ELOR could take over 10 years before construction commences.

Paragraphs 5.0 – 5.8 of SPAG’s M17902-03 evidence the lack of clarity at this late stage in the SAP process proving that the Plan is not positively prepared or effective. We therefore conclude that this is UNSOUND.

Comment: The delivery of key transport infrastructure is unfunded and uncosted

11. Objectors have raised concerns about the timely delivery of the mitigation that has been identified and the fact that the tested schemes are un-costed. This situation applies equally across the whole District in terms of the WYPTF and LPTIP workstreams. It is simply not realistic or practical to assume that all necessary infrastructure to mitigate the impacts of both existing congestion and future traffic growth will be delivered on ‘day one’. Indeed, as already highlighted above the roll out of major highway improvements well before they are required is more likely to result in generated traffic.

LCC considers the Outer North East HMCA to be unique within the Leeds district and MX2-39 is a unique policy within Leeds SAP. LCC is obliged to evidence that MX2-39 is MORE SUSTAINABLE than alternatives so should therefore be required to design all mitigations at the earliest stages of consideration.

Paragraphs 6.0 – 6.17 of SPAG’s M17902-03 further evidences that the material provided by LCC to date does not provide sufficient detail to determine either the cost or viability of the proposals for MX2-39.

The clarity that does not exist at this late stage in the SAP process proves that the Plan is not positively prepared or effective. We conclude therefore that this is UNSOUND.

12. Additionally, where public funding is required to support these interventions the constraints of the funding and appraisal process laid down by government are such that only impacts from developments that are sufficiently progressed through the planning system are allowed to be considered. This is to prevent what is limited public funding being devoted to schemes that only appear value for money because they rely on future developments (that are far from certain to occur); this approach ensures a robust value for money business case is achieved. At a bare minimum, for funding to be available, sites giving rise to developments need to be allocated within an adopted local plan, though normally this is insufficient and only sites under construction, with planning permission or at pre-application stage are included in scheme appraisal3.

BIESPC agrees wholeheartedly with the sensible use of public funds, but argues strongly that a SAP policy of the magnitude of MX2-39 is so disruptive and impactful on the surrounding settlements – particularly BIESPC - that all its disruptions, impacts and consequences relating to it must be ascertained at the earliest stages – even before the EiP.

We also argue that having to dig out more and more information from LCC at the EiP is unsatisfactory. LCC’s lack of knowledge about the site and surrounding settlements and

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 infrastructure, the lack of tests and comparisons regarding alternatives compounded with the lack of compliance with LCC’s own Adopted Core Strategy and the NPPF is astonishing.

The Inspectors will recognise that the initial proposals for Parlington were to create a new garden village of 5,000 dwellings. The construction of a settlement of this size is unprecedented in recent times. We continue to argue that MX2-39 per se is an unsound policy and LCC’s lack of information about the infrastructure is worrying.

13. As stated in the Infrastructure Background Paper (EX51) the Council and its partners are embarking on an unprecedented programme of new and enhanced transport infrastructure. This will be delivered over the next decade and beyond as part of a rolling programme. As shown in the latest Infrastructure Delivery Plan some schemes have already been delivered (e.g. Apperley Bridge and Kirkstall Forge Stations, Rodley, Thornbury and M1 Jns 44 and 45 junction improvements, Elland Rd and Temple Green P&R), others are imminent (e.g. Outer Ring Road junction improvements and A65 SCOOT scheme) while others will not come forward for a number of years (EX51 Appendix 1). For the scheme appraisal reasons stated above, this process is essentially independent of the SAP, albeit adoption of the Plan would change this because schemes relating to major housing allocations (such as a Garforth bypass) demonstrate added justification in terms of supporting development (M7/1i/2 para 5.4).

We have commented on the points raised in 13 above elsewhere in this document. Hardly any of the schemes discussed anywhere in EX51 help mitigate the traffic and congestion issues created by MX2-39. The above (13) reads as though LCC is, once again, contradicting itself.

14. Nevertheless, a number of schemes have been identified as part of the assessment of the SAP, including Garforth southern bypass and M1 Jn 47 improvements (EX51 Appendix 3 para 6.27) and steps are already being taken where opportunities arise to ensure that these schemes are included in relevant evaluation workstreams of the WYCA and Transport for the North.

Please ask LCC, on behalf of BIESPC, what these steps are and what are the relevant evaluation workstreams. Have these workstreams commenced as yet?

15. It is acknowledged that a bypass for Garforth will take a number of years to progress and deliver and that development will commence in advance of that delivery (M7/1i/2). It is however considered that mitigation in the short term would be facilitated by the delivery of the Jn 47 interim scheme that involves fewer issues in terms of land assembly and funding (with funding being entirely provided by the MX2-39 and HG2- 124 developments). It is anticipated that delivery of the bypass would be led by the Council because of the requirements for third party land. Funding is expected to come from multiple sources (as confirmed in M7/1i/2). The allocation of HG2-124 offers up an opportunity to enhance the A63 at Garforth with significant improvements in traffic noise, severance and air quality on the existing road, as well as reduced congestion, due to the substantial reduction in traffic from the existing 23,000 vehicles per weekday.

It has been noted in our previous representations that mitigation for the current issues at Jn 47 have been planned, yet unfulfilled, for at least 3 years.

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 We are again surprised that funding for this can be guaranteed to be entirely provided by the MX2- 39 and HG2- 124 developments when this has yet to be costed.

16. It should also be noted that where significant developer funding is provided to support a scheme this not only reduces the demand upon the public purse but also improves the business case for securing public funding in that the value for money calculation is based upon the public sector contribution rather than the total scheme cost.

We have already tried to place costs on the two access roads into the Parlington site. Clearly these costs do not include the work needed on M1 J47. It’s unclear who will fund the junction onto Aberford Road; it is also unclear who will fund the junction on to Long Lane.

This confirms our contention that the Plan is not effective and has not been positively prepared.

17. As noted in EX41 no alternative site allocations have been modelled. The background to this approach has been reasoned. Not least, due to the sheer number permutations such a modelling methodology would have to consider and the impracticality of such an approach. It follows that mitigation for alternative allocations has therefore not been considered at the level of the modelling reported in EB9/35 and 36.

This confirms our contention as above that the Plan is not effective and has not been positively prepared.

Comment: The modelling shows a significant impact upon the M1, yet no specific mitigation has been identified

18. Some objectors have referred to the impact the allocations will have on the M1 and the fact that appropriate mitigation has not been determined at this stage. As addressed in the SOCG (STA 10) Highways England and the Council are continuing to work together on this issue. It is worth noting, that in common with much of the country4, traffic growth on Strategic Road Network motorways has been substantially greater than on urban A roads for many years. As highlighted in EX51 Appendix 3 traffic levels on A roads in Leeds District rose by 3% between 2001-17, while on the SRN motorways growth was 35% over the same period. (This includes the M1, where growth has been 36%, rising to 39% between Jn 46 and -47). So, the impact of traffic growth on the motorway network is far from being unique to Leeds, and is occurring regardless of the allocations. Nor is this impact necessarily generated by additional development.

We are still looking for the answer in the above text to the question proffered. Where is the mitigation? We believe that the mitigation discussed at the EiP only increases the problems on the road networks and that is not acceptable to residents that we have discussed this with. It is not acceptable to BIESPC.

19. The Council considers that the work completed to date on mitigation schemes, feasibility studies and scheme costing is entirely proportionate and appropriate at this stage in the process and is considered sufficient to adequately inform the soundness of the allocated sites (EX41).

We contend that the mitigation schemes only add more traffic burden to the local and strategic road network around Parlington. To date we have noted that the modelling uses incorrect data and the

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 mitigations are only part mitigations to relieve the additional problems caused by LCC’s SAP. Surely LCC’s text above is surely unprecedented in its lack of planning professionalism?

We believe that the plan has not been positively prepared and is not effective. It is therefore UNSOUND.

Comment: Development at Parlington (MX2-39) will have an unacceptable impact on local roads

20. With regards to the impact of MX2-39 Parlington on the local road network around Aberford, Scholes and Barwick it should be noted that the reports (EB9/35 and 36) clearly show that Parlington traffic (both from MX2-39 and BL1-42) makes up only a proportion of the additional vehicles using these roads. For example, in EB9/36 Tables 12, 18, 24 and 30 show the changes in peak direction traffic on Leeds Road west of Barwick; Tables 13, 19, 21 and 25 show the peak direction flows from and to Parlington (MX2-39) on Leeds Road east of Scholes (the same location). The overall increases in traffic from MX2-39 Parlington are marginal in all but the Barwick Link Road test (Test 4) and even then this represents at most 20% of the increase (see summary in Table 1 below).

We contend that LCC once again misses the point. The current local road network cannot cope with this increase in traffic. Added to the extra traffic are the impacts of ELOR which will slow the thoroughfare of traffic along the A64 and the additional housing in the ELE.

As LCC points out in its paragraph 11 “Indeed, as already highlighted above the roll out of major highway improvements well before they are required is more likely to result in generated traffic.” Over the period of construction and at the inauguration of ELOR the villages around Parlington anticipate an increase in through traffic without the traffic emanating from Parlington.

Notwithstanding this, we have no faith in the accuracy of the modelling as we have described and therefore conclude that the plan is not positively prepared, not effective and therefore is UNSOUND.

21. Equally, even with 1850 dwellings (MX2-39 and BL1-42), the overall increases in traffic from Parlington remains below 20% in all but the Barwick Link Rd test (Test 4) (see summary in Table 2 below).

Test 4 is the only option that overs the site requirements as set out by LCC. In this case the statement above is tautology as Tests 1, 2 and 3 are not compliant. Why has LCC written this answer?

22. As is also clear from the tables the impact of Stourton Grange Farm South varies between the two scenarios as does the total increase in traffic, which is greatest with the Broad Locations (BL1-40 and 42) elements of the Parlington and Stourton Grange Farm South sites included. In this situation it appears that the impact of the additional generations from these two sites elsewhere in the network is creating a situation where additional use of these minor roads occurs. This reinforces the point made earlier that in congested conditions an increasing element of traffic will start to use the minor road network. The impact of alternative site allocations to HG2-124 and MX2-39 is unlikely to result in a significantly different situation, and in some cases might worsen it.

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 Our concern is that the minor roads cannot cope with more traffic; Parlington’s location will force more traffic on to the minor roads as the residents avoid travelling along the A642 and the M1. The impact of alternative site locations will mean that there will be a significantly different situation and will, therefore, not worsen it.

23. While the provision of a secondary access to MX2-39 Parlington will result in increased traffic levels on these minor roads, this should be considered in the whole together with the benefits that the second access would attribute directly and indirectly, including the opening up of access to facilities (including schools) at MX2-39 Parlington to the residents of Barwick and Scholes, as well as allowing interaction between the residents of the communities maximising further community cohesiveness. The historic development of the villages to the east of Leeds has resulted in each being interconnected with each other brought about in part by the development of roads between them. For example, Barwick required access to and through Aberford and Scholes.

LCC is making ridiculous assumptions above. Mr Butler’s assessment of the build out rates at Parlington (EiP, Friday 3rd August) advised the Inspectors that the site will fall short of its target by a considerable number of dwellings by 2028 even at 792 dwellings.

It was also presented to the Inspectors that facilities in Parlington would not appear until there was a large critical volume of houses built. Residents of Barwick In Elmet have advised us that the distance to Parlington is not short enough to warrant visiting the facilities if they were minor facilities. In other words residents would prefer to travel to Garforth to shop at the supermarkets there rather than a small retail outlet in Parlington. Residents would prefer to travel to a large sports centre (Garforth, Thorpe Park, Crossgates) rather than visit a small amenity in Parlington (bear in mind also that Aberford and Barwick already have such amenities). And, of course, Garforth offers a larger medical facility than could be offered at Parlington and the distance to Garforth from either Aberford or Barwick is marginally greater. It is therefore unlikely that this interaction and cohesiveness will arise.

Notwithstanding this, we have no faith in the accuracy of the modelling as we have described and therefore conclude that the plan is not positively prepared, not effective and therefore is UNSOUND.

Comment: HS2 will negatively impact upon the delivery of mitigation schemes at Junction 47

24. Aberford Parish Council have referred to the impact of the proposed HS2 line at Jn 47 and the implications upon delivery of a mitigation scheme due the ‘development embargo’. However, the HS2 safeguarding guidance makes it clear that this relates specifically to applications for planning permission and obliges LPAs to consult with HS2 Ltd. This does not necessarily preclude development, although if HS2 Ltd objects to the application the Secretary of State can issue a direction restricting the granting of permission. There is no mention of highway schemes in the guidance, though clearly Highways England and Leeds City Council would need to engage with HS2 Ltd over any proposals for works at Junction 47 as indeed HS2 Ltd are already engaging with Leeds CC over their own proposals both during the construction period and on completion.

We have already commented in previous representations on the impact of HS2.