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Local Plan Pre- Publication Draft 2018 Summary of Consultation Responses

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Local Plan Pre- Publication Draft 2018 Summary of Consultation Responses Local Plan Pre- Publication Draft 2018 Summary of Consultation Responses ID Policy Obj/Supp/ Summary Respondent (name of individuals Comm removed) SS1: Delivering Sustainable Growth for York 4 SS1 Comm The evidence in the Transport Topic Paper indicates a substantial increase in Highways England pressure on the A64 leading to a need for physical mitigation in addition to sustainable transport measures. In the HE's response to the 2016 consultation it anticipated capacity issues on the A64 and at junctions with the primary road network 7 SS1 Comm The Spatial strategy is predicated on the delivery of 867 dwellings per year over the Hambleton District Council Plan period and post plan period to 2037/38. The housing need figure identified through the SHMA follows the same methodology as the assessment carried out for Hambleton District Council. It is considerably lower than the 1070 new homes per annum calculated using the proposed formula in the White Paper 'Planning for the right homes in the right places'. Therefore, depending on the outcome of the consultation, and progress on the City of York Local Plan, it may be necessary to consider reviewing the figure or providing more evidence to support it. 9 SS1 Comm Selby District Council notes the policy states that the plan will deliver a minimum of Selby District Council 867 dwellings per year but it needs to be confident that undertaking a policy-on approach to housing need would identify no more than this. Whilst Selby District Council believes that CYC is confident that it can realise the growth aspirations in the plan it is concerned that any increases in the 867 dwelling per annum as a result of the proposed methodology for the calculation of housing requirements set out ion the DCLG consultation on 'Planning for the Right Homes in the Right Places', which if taken forward would increase the housing requirement to 1070 dwellings per annum, could raise significant cross-boundary issues. Local Plan Pre- Publication Draft 2018 Summary of Consultation Responses ID Policy Obj/Supp/ Summary Respondent (name of individuals Comm removed) 42 SS1 Comm Clarification of bullet point three of Policy SS1. Locally significant nature Yorkshire Wildlife Trust conservation sites could be changed to 'locally designated Sites of Importance for Nature Conservation or SINC'. This should help to distinguish between SINC and SLI's. 145 SS1 Comm The housing supply makes an allowance for windfall sites of 169 dwellings per Home Builders Federation annum from year 4. This is evidenced by the Windfall Technical Paper. However, it is noted that the use of historic windfall in an area where there has been no adopted Plan may not provide the most appropriate basis for windfall development going forward. Policy SS1 states that where viable and deliverable, the re-use of previously developed land will be phased first. It is not clear how this will work in practice. The council's monitoring as set out in paragraphs 15.22 to 15.30 and Table 15.2 highlights risks including the non-delivery of sites, and sets targets in relation to the delivery of sites. The HBF recommends that specific monitoring triggers are introduced. It is not clear from the table how quickly action will be taken if targets are not met, and if the proposed solutions do not lead to targets being met how long it will be before the final resort of reviewing the plan is considered. Taking into consideration the timeframe for preparing the current plan it is considered that the production of a revised plan may not be a quick solution to the non-delivery of sites and may therefore not be an appropriate resolution. The HBF recommends as large a contingency as possible (circa at least 20%) to the overall housing land supply to provide sufficient flexibility for unforeseen circumstances and in acknowledgement that the housing requirement is a minimum not a maximum figure. Local Plan Pre- Publication Draft 2018 Summary of Consultation Responses ID Policy Obj/Supp/ Summary Respondent (name of individuals Comm removed) 187 SS1 Comm The Chambers' 2016 Representation comments remain relevant. The Local Plan York and North Yorkshire identifies a requirement for only 34 hectares of employment land over the 15-year Chamber of Commerce plan period plus the additional 5 years for the period 2033 to 2038. 192 SS1 Comm The colours in Figure 3.1 do not tally well with what it is depicting 238 SS1 Comm Suggested text amends to refer to both impact of location and scale of growth, and Historic England to recognise the contribution of the rural landscape to the special character and setting of the City, as follows: Para 3.5, "...are illustrated in Fig 3.1. However, the open countryside beyond the ring road also makes an important contribution to the wider rural setting of the historic city", and Policy SS1, "The location and scale of development through the plan...etc". 386 SS1 Comm Replace third bullet as follows: ‘Preventing any additional exceedences or increases York Green Party in illegal levels of air pollution’. 1299 SS1 Comm Supportive of spatial principles but concerned with how the strategy has been Spaworths on behalf of Lucienne interpreted in the Plan in particular the scale of growth and provision of new M Bleasdale dwellings over the plan period. The 867 annual dwelling figure is not based on evidence base and does not reflect national policy/guidance. 1498 SS1 Comm Acknowledge urban area will not support all growth required in York and that land Lichfields on behalf of Bellway Homes will need to remain out of green belt to meet housing requirements. Both types of development are equally important to achieve sustainable development. 2412 SS1 Comm Queries timeframes used to determine annual job growth figures (2017-2038) vs annual housing figures, which are apportioned across 15 year timeframe. 12655 SS1 Comm The policy should provide clarity that the development is specific to the York Local GVA on behalf of DIO Estates (MOD) Authority Area. 13408 SS1 Comm Better maps should be supplied to enable analysis against the factors which shape growth. Local Plan Pre- Publication Draft 2018 Summary of Consultation Responses ID Policy Obj/Supp/ Summary Respondent (name of individuals Comm removed) 13637i SS1 Comm CPRENY are concerned about the housing requirement set out in the Local Plan. CPRE - North Yorkshire This policy states CYC will deliver a minimum of 867 homes pa over the Plan period and up to 2038. The GL Hearn SHMA Addendum 2017 is of a concern on deliverability grounds. Recognising CYC should significantly boost the supply of housing (paragraph 47 of the NPPF) it is also recognised that this should be realistic and achievable. Housing targets have been amended over the various iterations of the Local Plan, the latest of which has been calculated at 867pa - this is a significant increase compared to the average that has been delivered. CPRENY are concerned this may not be achieved and a more realistic figure should be used. We welcome the Executive decision to not adopt a 10% uplift allowing for market signals as it does not give weight to the special character and setting of York and important environmental constraints. 13637i SS1 Comm Land supply across the York Housing market is discussed in paragraph 5.16 and is of CPRE - North Yorkshire concern to CPRENY as CYC has worked with all neighbouring authorities under the duty to co-operate as required by NPPF. It is welcomed that York does not need to make additional land available to address shortfall elsewhere. However, the impact of housing developments elsewhere will impact detrimentally upon the setting and infrastructure provisions of the City. Some population figures used by GL Hearn to provide the OAN may result in residents using York to commute elsewhere, CPRENY are concerned about potential double counting and an artificially high OAN has been produced, CYC should ensure this is not the case. Local Plan Pre- Publication Draft 2018 Summary of Consultation Responses ID Policy Obj/Supp/ Summary Respondent (name of individuals Comm removed) 13641 SS1 Comm Understands that CYC needs to identify more sites as part of the new proposed ID Planning housing methodology to meet demand. Site supports this. Paragraphs 3.4-3.12 identify development constraints around York, however hard to determine where a site/ constraints are located on map. Requests better quality maps. 42 SS1 Obj Support in principle to this policy, although the indefinite continued future growth Yorkshire Wildlife Trust of the city cannot be sustainable in the longer term. Local Plan Pre- Publication Draft 2018 Summary of Consultation Responses ID Policy Obj/Supp/ Summary Respondent (name of individuals Comm removed) 62 SS1 Obj The pre-publication draft states in various policies that the intention of the plan is Fulford Parish Council to meet the development requirements of the city in full within the York local authority area. CYC appears to have taken this policy position without any detailed consideration of the impacts of meeting development needs in full upon the setting and special character of the city. FPC contends that this approach is contrary to national policy. The NPPF sets out a two-stage approach, the first of which is to assess the development needs of the city, as is done in the SHMA and ELR. The second stage is to assess the impacts of meeting these needs and deciding whether the impacts are acceptable or not. There is no documentary evidence that CYC has carried out this second stage exercise. If it had done so it is likely CYC would have reached a different decision about fully meeting needs.
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