From: To: Site Allocations Plan Subject: PSE00455_Leeds Site Allocations Plan - Site MX2-39 Date: 20 March 2017 15:07:58

Mark Foster Elmwood House, 44 Main Street, Barwick In West LS15 4JQ

Dear Sirs,

Re: Leeds Site Allocations Plan – Site MX2-39

Please find below my comments on changes to the above plan, which I believe is evidence that the plan is, and always has been, UNSUSTAINABLE AND UNSOUND.

When considering the points below I have considered the findings by the Highway Authority that any increased traffic count and problems associated with such cannot be mitigated for a development in this location and so any reference to an issue which is caused by traffic is an issue which cannot be resolved in any way.

There is no evidence from in the new MX2-39 to disprove the expected 3,600+ private vehicles and 5,000+ daily journeys that will require access from MX2-39 to the other settlements around the Outer North East.

I comment, regarding the changes, as follows:

Parlington (MX2-39) residents would be reliant on using already overstretched local services – for instance, doctors’ appointments are currently only available in Aberford for 4 hours 4 days a week. In addition, they would also need to access these local services by car which would further increase traffic on local roads, over and above normal commuting and this problem cannot be resolved as the Highway authority has said that there is no way in which it can be mitigated.

I also infer from the conclusions reached by the Highway Authority that problems cannot be mitigated that no additional infrastructure can ever be built. Therefore LCC has not provided evidence that the site will ever be sustainable. When questioned at the Development Plans Panel 10/1/17, LCC Chief Planning Officer Tim Hill said “The local planning system cannot guarantee when amenities and infrastructure are delivered in stand-alone developments”. I therefore consider the plan for this supposed standalone site not to be and given its proximity to Barwick and Aberford and will not be a stand-alone site but, rather, an extension to the existing villages which more than doubles their sizes.

The plan shows only 1 route of access and the plan which has been made available has not been completed and so proper examination and consideration of the various effects of a secondary access cannot be considered when making this objection.

The only access point is on a derestricted road near a sharp corner with poor visibility and so is likely to cause accidents unless a substantial roundabout type junction is installed.

A secondary access to MX2-39 along Long Lane between Barwick and Garforth will be inadequate as there currently exists a single track bridge and a single track, listed railway underpass bridge at Garforth. This makes it unfeasible for traffic to drive from MX2-39 to Garforth and then to Leeds as traffic will have to go through Barwick. Further:

• The Junction in Garforth at the top of Main Street is inadequate to deal with more traffic coming from or turning into Long Lane.

• The Junction in Garforth cannot be developed or widened due to the proximity of buildings to the carriageway.

• The junction at Barwick is too small to cope with additional traffic and cannot be widened or developed due to the proximity of buildings to that junction.

• A 20mph speed zone through the centre of Barwick will be implemented during 2017 • Traffic heading to Barwick will then have to travel through Scholes and then through the John Smeaton/Whinmoor area posing dangers to significant pedestrians and school children in that area

• The current track from MX2-39 leading towards Long Lane is too narrow and development would mean that ancient woodland would have to be destroyed. The existing plan and Leeds City Council’s Core Strategy states that no development will occur within 50 metres of ancient woodland.

• Even if the track did not need to be widened its proximity to ancient woodland would mean that the need to install drains would interfere with the ancient woodland and/or surface run off would pollute the ancient woodland ruining it forever.

• Leeds’s own Core Strategy states: “Development which would result in harm to, or the loss of, Ancient Woodland and Veteran Trees will be resisted.” Parlington contains ancient woodland and veteran trees. The changes do not give enough protection to the ecology in Parlington and so the plan is still not sound.

A secondary access along Cattle Lane would be dangerous because Cattle Lane is far too narrow. Currently all drivers of motor vehicles are forced to stop when a bus approaches from the opposite direction. A bus has already left the road on Cattle Lane within the last 12 months and the banking along the road is dangerous for much of its course between Barwick and Aberford. The road is also undulating rising and falling over 40 metres along its course. Whilst there are opportunities to make this road safer it will require major roadworks for appropriate mitigation.

Within the last 12 months there have been numerous accidents where cars have left the road. Further:

• The bridge at the Barwick End is too narrow and involves sharp corners which will pose a hazard to road users.

• Traffic will have to pass through Barwick and/or Aberford and the roads in these villages cannot sustain any more traffic

• There is a tight and dangerous corner near the Gascoigne pub in Barwick where accidents regularly occur

• The Church in Barwick does not have adequate parking. This forces worshippers and visitors to park on the roadside making the road even more hazardous even with the volume of motor car and cycle traffic which exists at present.

• The above factors about the risks posed by traffic from Long Lane having to pass through Barwick and Scholes and Whinmoor area will all still apply.

• As the plan does not demonstrate where the link onto Cattle Lane would be situated I cannot comment further except insofar as to say that almost everywhere along the road forward visibility is poor and a junction situated anywhere along Cattle Lane is likely to cause even more accidents.

A secondary access directly into Aberford would be unsuitable because if 90% of the residents are expected to travel to Leeds for work this will have the effect of almost all vehicles heading either to the B1217 near the Wind Farm to then head toward Leeds. This would defeat the point of the secondary access. The alternative is traffic moving along Cattle Lane through Barwick to Leeds with the problems identified above. Further:

• Aberford Main Street is too narrow to cope with additional traffic.

• Additional traffic through Aberford would affect the village and its character and atmosphere, which should not be allowed. If Leeds City Council intends MX2-39 to be a stand-alone housing complex it should, by definition, not affect surrounding villages and towns.

• The junction in Aberford offers only poor visibility as a result of the on-street car parking between Cattle Lane and Bunker’s Hill (Aberford). The volume of traffic which is likely to use such a route to access the A1 North and vice versa will mean that any such junction would require significant development and road widening to allow a lane for cars turning right. Due to the proximity of buildings to the carriageway in Aberford this would not be possible.

• In light of the volume of traffic which will use the secondary access route and the level of pedestrian activity in the centre of Aberford, additional traffic will be dangerous and will be likely to cause a significant number of accidents with pedestrians. There is no evidence in the new MX2-39 that Leeds City Council recognises any added burden to the highway infrastructure coming from the known increased car traffic from settlements east of MX2-39. These settlements include Sherburn, Lotherton, and Tadcaster plus others and the Highways Agency has concluded that nothing can be done to mitigate these issues which is evidence that a stand-alone development of this size in this location is not and never can be sustainable.

Leeds City Council has stated that the B1217 alone cannot support MX2-39. In light of the comments above no other access road would be appropriate or could cater for the expected volume of traffic. If a secondary access road was intended to cater for residents’ vehicles this is in direct contradiction to Officers’ comments at the drop in session in Aberford on 20 February 2017 stating that the second access road may be for bus/emergency vehicles only. The Highways agency has concluded that the issues caused by additional traffic cannot be mitigated and LCC has not provided any information that shows how existing infrastructure can support the proposed development.

There is no evidence provided in the changes to MX2-39 of how Leeds City Council intends to improve the highways infrastructure to cope with the large volume of traffic coming from the new MX2-39. Indeed the Highways Agency has concluded that nothing can be done to cope with the increased traffic and, in the absence of any indication about what changes could or will be made, I can only conclude that nothing will be done to cope with the added burden from the certain large increases in volumes of car based commuter traffic from the settlements to the east as a result of their large scale house building projects.

No data have been provided or even considered about the level of harm that the increased traffic will inflict on nearby settlements and wildlife.

There is no evidence from the changed MX2-39 that commuters from the east of MX2-39 will not elect to travel via Aberford, Barwick and Micklefield into Leeds rather than by the B1217 and MX2-39 will create a large barrier to their timely commute into Leeds as well as to other places of work and leisure along the M1 and M62 only encouraging them to use the alternative routes through the villages mentioned above.

The peak time traffic from MX2-39 will add increased traffic on B1217 along its entire length and, as no mitigation works on B1217 and adjoining highways is possible, it is also likely that a significant proportion of road users will elect to drive straight through Garforth to the A63 roundabout. The entire length of this road through Garforth is too narrow to cope with more cars. The junctions do not include adequate right turn lanes and they cannot be developed to include such because of the proximity of buildings and private land to the carriageway exacerbating the traffic flow problems.

Leeds Ring Road from Colton to Crossgates is already overburdened with traffic and does not flow well. The motorway junction at Colton and the junction between the Thorpe Park estate and the shopping estate from Bullerthorpe Lane will need significant development to allow the flow of increased traffic both into and out of Leeds. LCC has provided no evidence as to how this might be achieved without inhibiting traffic travelling out of Bullerthorpe Lane and Thorpe Park. The Highways Agency has already stated that mitigation will not be possible. he road from the roundabout between Colton Village and Halton, which runs past the Brown Cow and , will need significant development to allow the flow of traffic into and out of Leeds along that route. Measures will be needed to protect pedestrians in the shopping areas along that road. The required modifications and road improvements will not be feasible in light of the proximity of buildings to the carriageway

The Ring Road through Crossgates to the A64 will need to be improved, with better junctions and measures to help the traffic flow through that area as the proposed outer ring road from Colton to the A64 near will not be in the right direction for the 90% of people heading to Leeds from MX2-39. LCC has provided no evidence to demonstrate how this can be achieved whilst still affording pedestrians safe means to cross the roads from the housing area in Crossgates towards Road where the shops are located and vice versa for people to reach the library and other facilities on that side of the road from the Austhorpe Road side

Leeds City Council has offered no information about the nature and extent of the second access. Without full information, there is no way to comprehend, assess and attach weight to the harmful effects of the highway infrastructure to the north, south, east and west of the site.

A shuttle bus service, whether frequent or not, to Garforth train station(s) would not be utilised or of use and the combined impact of traffic from both the development in Parlington and other developments in the East Leads area East of Garforth would dwarf any relief that any bus service would provide. The plan is unsustainable. LCC has not provided enough justification for the site to be changed from Greenbelt to allow house building on this scale. There are many points that cannot be commented on as LCC has not provided the necessary information to achieve any understanding as to how the Board could pass the plan when the detailed ecology of the site was not available until after this pre-submission consultation. LCC has provided little information to show that this SAP is not being rushed and pre- determined. As detailed site requirements have not been provided and appropriate mitigation has not been identified it is not known if mitigation is achievable. Therefore the plan remains unsound.

A significant proportion of the proposed house building will now be on the fields above Throstle Nest Farm along Parlington Lane. This is currently not screened by trees and is visible from Long Lane. This is a rising ground so it will be extremely difficult to ‘enhance’ tree planting in this area in such a way that it screens the development. As it stands currently, Parliigton has one of the best woodland in the north of (CPRE) and improving that will not be possible in the light of this proposed huge house building project. This point is proven further by the fact that the changes include Biodiversity buffers ‘along the boundaries of the site’ but do not include other buffers recommended by The Woodland Trust, which would be inside the site. Such recommendations include 100m buffer for Ancient Trees and 15m/3 x diameter (whichever is the greater) for the 3 notable trees. There is still not enough ecological protection and therefore the plan is still unsound.

The original plan has been changed From “The site is in the setting of a Listed Building” to “Parts of Phase 1 are in the setting of Listed Building(s)”. This is because the original statement considered only a singular listed building and this is incorrect. The proposed development still impacts the environment of a number of listed buildings and structures. These are The Triumphal Arch, The Gardens House and the Stallion Pens [Listing pending]. However, the estate encompasses many structures which whilst not listed represent the character of the estate. Therefore, it is reasonable to add the Keeper’s Cottage, the estate walls and entrance gateways which are to some extent a continuum of the Gardens House Walls (also listed), and the two ponds which are a balancing mechanism for the Crow River, situated either side of Parlington Lane. The new proposed access roadway, as shown on the LCC diagrams, now directly bisects the aforementioned structures and ponds, destroying the context of the centre of the estate.

The site has not been properly compared with other sites. LCC has not carried out a comprehensive review of all the Green Belt in Leeds which is in direct contravention of the requirements of the Inspector who examined the Core Strategy. In fact the performance of the Green Belt for the original MX2-39 has only been compared with the Green Belt site at Becca and no other sites in the wider area and been considered alongside it. LCC has provided no evidence to suggest to the contrary. LCC therefore has not fairly and objectively assessed the performance of the Green Belt at Parlington in comparison with all the other sites in and around Leeds. This plan has therefore still not been Positively Prepared.

LCC states that there will still be 800 houses built at Thorp Arch and that no more can be built because of the cost of developing the infrastructure surrounding that site would be too great. LCC has provided no evidence to show that if 800 houses are to be there, it wouldn’t make more sense to use up that space and build a further 1800 or more houses in that area. This would provide the developer with capital to develop any infrastructure all in the same place without damaging as much greenbelt. The Thorp Arch site is already better located for access to the A64 and the A1 and M62. Further building at Thorp Arch would allow existing businesses to prosper, would allow funding for construction of both a primary and secondary school in that location and would provide better access to towns such as and Tadcaster for employment purposes.

Both and Tadcaster Grammar are currently over-subscribed. Now the plan does not include a secondary school in Phase 1, secondary school age children living in Aberford and Barwick are at risk of being displaced by children moving to Parlington. In line with LCC’s schools admission policy, Garforth Academy will prioritise children living at Parlington ahead of those in Aberford and Tadcaster Grammar will prioritise them ahead of children living in Barwick. LCC has provided no evidence to show that the children of Barwick and Aberford would not be penalised by the building of houses at MX2-39;

The change to the size of MX2-39 will make minimal difference to areas of high sensitivity with regards to heritage and conservation. Grade II Listed Buildings and Scheduled Monuments are in the category of designated heritage assets of the highest significance. The Triumphal Arch, The House at Parlington Gardens and Hook Moor Lodges are all Grade II Listed and whilst not in the area of house building for Phase 1, the landscape and environment that they sit within all play a part in their importance and heritage. Furthermore, the new access road as detailed on the plan runs adjacent to Park House Farmhouse which also Grade II listed;

I do not believe that the change to the boundary successfully addresses the significant concerns of statutory body Historic England with regards to Parlington Estate itself and the surrounding villages. Harm to the historic environment has not been mitigated by this change and therefore the Plan is inconsistent with the NPPF and Unsound.

I would finally like to state that MX2-39 has not been Positively Prepared because, none of the details about secondary access or likely impact on greenbelt have been considered fully.

• Nor has proper consideration of the full implications of a development of this size in this location been considered.

• Further as the Highways agency has found that no mitigating works are possible to deal with the increased traffic levels and as this conclusion was only reached AFTER the plan was formed the plan cannot by definition have had proper consideration of all relevant factors. It remains an incomplete plan and lacking in details which means that it cannot meet objectively assessed development and infrastructure requirements.

• The impact of MX2-39 in this situation would be harmful to the nearby villages and the wider area to the East of Leeds.

• A stand Alone Development should be just that – a development which is self-sufficient and is not so close to other villages and communities that it harms those communities. MX2-39 is not self- sufficient. It does not have adequate infrastructure to provide for the expected levels of traffic and no developments can occur without harming nearby villages and/or causing further destruction of Greenbelt Land.

Yours faithfully,

Mark Foster

Mark Foster Director t m e

4 Carrwood Park, Swillington Common Farm, Selby Road, Leeds LS15 4LG

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