Settlement Network

Chapter 3 – Settlement Network

Paragraph 3.1 ...... 2 Table 1 ...... 3 Paragraph 3.2 ...... 4 Paragraph 3.3 ...... 4 Paragraph 3.6 ...... 6 Paragraph 3.7 ...... 9 Paragraph 3.8 ...... 10 Paragraph 3.10 ...... 11 Paragraph 3.11 ...... 11 Locating Development - Revised Policy SS2 ...... 13 Figure 2 - Revised East Riding Settlement Network ...... 41 Question 2 ...... 41 Paragraph 3.12 ...... 151 Paragraph 3.13 ...... 151 Paragraph 3.14 ...... 152 Paragraph 3.15 ...... 152 Paragraph 3.16 ...... 153 Paragraph 3.17 ...... 154 Paragraph 3.18 ...... 155 Paragraph 3.19 ...... 156 Paragraph 3.20 ...... 156 Paragraph 3.21 ...... 158 Paragraph 3.22 ...... 159 Paragraph 3.23 ...... 160 Development in Hinterland Villages, Rural Villages and the Countryside - Revised Policy SS3 ...... 160 Question 3 ...... 194

Consultee/Agent ID Nature Of Response Officer Comments Response:

Paragraph 3.1

Mr Tom Cook, ID CSFC/195 Support In 3.1 the Council acknowledge that they are listening to Comments noted. Planning on behalf comments made previously in that they need to ensure that of Landmark "housing and jobs are provided together". Such an approach, i.e. Development that new jobs are linked to the delivery of new homes within the Projects District is wholly welcomed by my client. Mr Tom Cook, ID CSFC/197 Support In 3.1 the Council acknowledge that they are listening to Comments noted Planning on behalf comments made previously in that they need to ensure that of Key Growing "housing and jobs are provided together". Such an approach, i.e. Limited that new jobs are linked to the delivery of new homes within the District is wholly welcomed by my client. Mr Tom Cook, ID CSFC/205 Observations It is important to acknowledge that new jobs and homes should Comments noted. The Draft Stratgey Planning on behalf be provided together wherever possible. Furthermore, Document places sustainable of Landmark recognition should be given in respect of the need to support development at the heart of the Local Development existing employment locations where further development, of Plan. Projects both additional commercial floor space, new residential properties and local amenities (in order to create a thriving community) would assist in ensuring that these existing communities and business locations became more sustainable.

The Local Authority should therefore promote development opportunities that are seen to be consistent with Planning Policy Statement 1 `Delivering Sustainable Development' in respect of supporting and enhancing existing communities. Mr Tom Cook, ID CSFC/207 Observations See response to CSFC/205 See officer comments to CSFC/205 Planning on behalf of Key Growing Limited Consultee/Agent ID Nature Of Response Officer Comments Response:

Table 1

Mr Graham Alcock CSFC/58 Other Swinefleet meets all the listed criteria to be classified as a Swinefleet does meet the criteria for a Hinterland Village and yet it is not listed as one. The village is in Hinterland Village (now known as desperate need of investment as it is calssified as one of the most Primary Villages) but was not identified deprived areas in the East Rding. We are of course on the fringe through the Further Consultation due rather than near the centre. Our village has improved over the to the assessment of flood risk as set last 30 years since I have been living here. out in the Level 1 Strategic Flood Risk Assessment (SFRA). The Level 1 SFRA We have three public houses, a primary school, village hall, bus shows shows a significant proportion of service,church,playing field, village shop with petrol station Swinefleet is within the “Danger to All” (recently under new ownership and thriving), care hazard zone. On this basis, it is not felt home,hairdressers, sheltered housing estate and a visiting mobile appropriate to identify it as a Primary library. Importantly we are under 5 kilometers from Goole. Village. Infact we are about 3 kilometers from Old Gole where there is a chemist, two supermarkets and a doctor's surgery.

We are now also protected by a new £11000000 flood defence scheme which means we are on a ratio of 1:2000 year likelyhood of flooding. This has reduced the flood category of this village to the lowest category. I contend then that this village should be classiified as a Hinterland Village. This village is indeed in need of reinvestment. N Rowland, Savills CSFC/410 Observations It is not clear whether Table 1 is to remain and to be Table 1 sets out the Settlement reproduced in the submission version of the Core Strategy. If it Network as identified through the is to be included then we suggest that the Settlement Network previous consultation – the Preferred needs to set out that Hinterland Villages are now included within Approach. Policy S3 of the Draft the hierarchy of settlements which are anticipated to Strategy Document sets out the revised accommodate some development. Accordingly the table should Settlement Network which includes be amended to include the Hinterland Villages. Primary Villages (including previously identified Hinterland Villages). Consultee/Agent ID Nature Of Response Officer Comments Response:

Paragraph 3.2

Mrs Margaret CSFC/23 Observations Development in North Cave should not include Everthorpe Lane Comments noted. The development of Jacqueline as this would effect the rurality of the village. Future housing specific sites is considered through the Whitlock development should be between Station Road and Low Mill Lane Allocations Document. at the South Side of the Village. The issues identified are part of the Housing should be a mixture of private, social and sheltered process in identifying specific sites for housing with designated parking and play areas for children. development. Trees must be included in Landscaping

Hedgerows and trees should be maintained

Transport infra structure should be such to accommodate working, schools and the elderly.

Health Service infrastructure must be included in development

Paragraph 3.3

Mr Graham Alcock CSFC/60 Other Development in rural villages should be allowed without the Comments noted. Policy S4 of the Draft need for a sequential test otherwise these villages will no longer Strategy Document has been developed be able to support their existing services and meet the to support the development of reasonable desire of their residents to contine their lives within individual plots in Villages. Development the community in which they were born into and attended will still need to comply with policies school in perhaps. This change proposed by me, would not be a regarding flood risk. threat as only one house per plot would be allowed and I agree with this. If the odd house is allowed villagers will be able to live/stay in and also contribute to their sustainability without threatening the character of the architectural layout and style of the properties by over development. I say this so long as the new plot is already within the building limits drawn around that community/village. Consultee/Agent ID Nature Of Response Officer Comments Response:

In allowing for this small change you will gaurentee the survival of our rural small schools, public houses, village halls and continue to contribute towards the survival of Englands most basic small communty, namely the village and village life. It is in my opinion one of our most valued social assets. Allowing for this small scale grouth will ensure the viability and continuity of our smallest communities. Do not allow the irecting of all development towards bigger centres be the only option. Mr James Fielden CSFC/73 Object The substantial increase in the target figure for hinterland and A pragmatic approach has been taken in rural villages from a figure of 607 in the 2010 consultation to a the Draft Strategy Document, figure of 3060 represents a seismic shift and needs to be justified. recognising the rural nature of the East The numbers for many villages has been reduced putting further Riding and the need to support pressure on those villages now included as hinterland villages. proposals in villages which help sustain village life. It proposes a revised figure of 1,149 over the plan period and now excludes Hinterland Villages. These have a specific housing requirement and have been classified as Primary Villages and grouped with the (formerly known) Secondary Rural Service Centres. Mrs S Farrar CSFC/136 Object The listing and naming of Hinterland villages should be removed. Comments noted. Policy S4 of the Draft All development in rural villages should be considered individually Strategy Document has been developed on merits of design to blend within the village. Preference should to support the development of be given to development on previously developed land and the individual plots in Villages.It prioritises village development limits should be the deciding factor. I the re-use of previously developed land wholeheartedly agree with the comments made by Mr Alcock. If and reinforces the use of development one off small scale development is not allowed, villages will die. limits to guide planning decisions. Not everyone wants to live in the urban centres and the sequential test should be scrapped. This county is surrounded by Policy ENV6 of the Draft Strategy rivers. Why should development be allowed in flood risk areas Document sets out the approach for wthin the larger urban centres but not in villages. There should considering development in flood risk be no villages where development is absolutely banned - please areas. The economic viability of Consultee/Agent ID Nature Of Response Officer Comments Response: treat each application on it's merits. If withn the development managing flooding has been considered limit of the village and the design blends well with no local in developing the overall housing objections then the nucleus of the village will remain in tact and requirement for different settlements. existing village services and community life will be supported. Don't kill our villages just because they are not within 2 miles of a town or on a bus route. Bus routes are being slashed because of lack of use - limited housing is not going to vastly affect global warming. New development however be as eco friendly as possible

Paragraph 3.6

Joanne Hodgson, CSFC/491 Observations There doesn’t appear to be any ecological assessment for the Comments noted. The Strategy Yorkshire Wildlife proposed rural service locations. Bubwith and Melbourne are Document is subject to a Sustainability Trust both very close to the Lower Derwent Valley SPA and Ramsar Appriasal and Habitats Regulation site and both Leven and Stamford Bridge have SSSIs nearby. We Assessment. So far, these have not also have a nature reserve near to North Cave. The ability of revealed any significant detrimental these areas to support the desired level of growth without impacts from the policy approach having a detrimental effect on these important ecological areas proposed in the rural areas and the should be considered. Even small scale development could have a villages identified. detrimental effect if located inappropriately. The impact of the development of individual sites is considered through the Allocations Document process.

After that, a planning application will also be required to consider the ecological impact of development. Lyndsey Fielding, CSFC/533 Object 3) 3.6 states most SRSC do not have significant constraints. Parts Comments noted. The Strategy South Cave Parish of South Cave are in Flood zone 3 and all surface water drains Document requires run-off to be Council through the area to a constrained drain under the A63. All restricted on new development to development will impact on this situation. The Council's greenfield rates, or on previously infrastructure study para 2.3 ii) states that; South Cave is developed land to reduce run-off by a Consultee/Agent ID Nature Of Response Officer Comments Response: considered to be at capacity and likely to require minimum of 30% or to greenfield rates. investment/improvements if it is not possible to achieve New development should therefore not Greenfield run-off rates. Potential costs of improving drainage exacerbate flood risks within the village. could be in the region of £1m. The Study admits that the surface Hydraulic modelling is ongoing for the water drainage risk that presents a potential constraint to new village to understand the different development in these settlements is not fully understood. GP's sources of flooding and work up flood are at capacity and again the study at states at section 4.2 (pge51) alleviation solutions. The proposed NHSERY is aware of potential issues with GP capacity in South development sites identified in the Cave and Brough. and shows a requirement currently for Allocations Document for South Cave between 4.3 and 4.6 full time GP's (the report, mistakenly not have been overseen by the Council's accounting for branches, doesn't state existing Nr of FTE GPs) flood risk officers and provided that Pressures of new housing in Brough will exacerbate the situation surface water run-off can be restricted in South Cave. The study in section 6.2 (page 77) indicates an in line with policy, their development existing small deficit in provision of indoor courts in South Cave should not increase flood risks in the which by 2026 will require investment of £496,743. We refer village. you to our previous comments on this subject which still remain to be addressed. The Infrastructure Study 2011-2026 took GP figures for the main surgeries only as it was not possible to establish how many of these GPs practised at the branch surgeries and for how long to get reliable figures. The NHS were aware of potential issues with GP provision in the village but were happy that provision across the East Riding as a whole at the moment is about right.

As the Study states the minor deficit in indoor court provision within the catchment is mitigated by the fact that the catchment overlaps with both Beverley and Haltemprice Leisure Centres catchments within which there is a theoretical surplus of courts. Consultee/Agent ID Nature Of Response Officer Comments Response: R J Kingdom, South CSFC/559 Object 3) 3.6 states most SRSC do not have significant constraints. Parts Comments noted. The Strategy Cave Active of South Cave are in Flood zone 3 and all surface water drains Document requires run-off to be Residents through the area to a constrained drain under the A63. All restricted on new development to development will impact on this situation. The Council's greenfield rates, or on previously infrastructure study para 2.3 ii) states that; South Cave is developed land to reduce run-off by a considered to be at capacity and likely to require minimum of 30% or to greenfield rates. investment/improvements if it is not possible to achieve New development should therefore not Greenfield run-off rates. Potential costs of improving drainage exacerbate flood risks within the village. could be in the region of £1m. The Study admits that the surface Hydraulic modelling is ongoing for the water drainage risk that presents a potential constraint to new village to understand the different development in these settlements is not fully understood. GP's sources of flooding and work up flood are at capacity and again the study at states at section 4.2 (pge51) alleviation solutions. The proposed NHSERY is aware of potential issues with GP capacity in South development sites identified in the Cave and Brough. and shows a requirement currently for Allocations Document for South Cave between 4.3 and 4.6 full time GP's (the report, mistakenly not have been overseen by the Council's accounting for branches, doesn't state existing Nr of FTE GPs) flood risk officers and provided that Pressures of new housing in Brough will exacerbate the situation surface water run-off can be restricted in South Cave. The study in section 6.2 (page 77) indicates an in line with policy, their development existing small deficit in provision of indoor courts in South Cave should not increase flood risks in the which by 2026 will require investment of £496,743. We refer village. you to our previous comments on this subject which still remain to be addressed. The Infrastructure Study 2011-2026 took GP figures for the main surgeries only as it was not possible to establish how many of these GPs practised at the branch surgeries and for how long to get reliable figures. The NHS were aware of potential issues with GP provision in the village but were happy that provision across the East Riding as a whole at the moment is about right.

As the Study states the minor deficit in indoor court provision within the Consultee/Agent ID Nature Of Response Officer Comments Response: catchment is mitigated by the fact that the catchment overlaps with both Beverley and Haltemprice Leisure Centres catchments within which there is a theoretical surplus of courts.

Paragraph 3.7

Mr Roy Hunt CSFC/1069 Object Twinning The effect of ‘twinning’ Gilberdyke and The concept of twinning is a good one because it accepts that Newport is to actually reduce the scale two adjacent settlement areas that between them have the of development proposed there. Each facilities and infrastructure to support more development could settlement meets the respective criteria be identified. However, the rationale for deciding why for Primary and Secondary Rural Service Gilberdyke and Newport should be twinned seems to be illogical, Centre status (now Rural Service but twinning of other villages where there would appear to be Centre and Primary Village). good reasoning is not not made. Again, some examples: Considering them independently would • Gilberdyke and Newport are linked with the effect that mean seeking to provide 255 (170 + 85) together they will need to support greater development for the houses over the plan period. The stated reason that it “needs to respond to the need to manage Further Consultation and more recent the scale of development against the risk of flooding”. So, Draft Strategy Document require a because this area is a high flood risk area they will be combined figure of 170 dwellings for Gilberdyke together so that more houses will be built there than otherwise. and Newport cumulatively. This surely is totally illogical, in particular when you look at Rawcliffe where it is proposed that planned development will be Comments regarding North Cave and substantially lower than otherwise because it is in a flood risk South Cave noted. South Cave’s area. proximity to Elloughton cum Brough • North Cave and South Cave are next to each other and have means it is considered in a different excellent facilities and infrastructure compared for instance with context to Gilberdyke and Newport Gilberdyke and Newport. The Caves have better road and rail which are further away from the nearest access, far better shopping facilities, better access to Town (higher up in the Network). supermarkets, closer proximity to places of work, they have a library, a high street bank, two sports centres, a golf course and Barmby Moor was considered as a an excellent health centre etc. etc. Yet these are seen as Hinterland Village through the Further Secondary Centres compared with Newport that becomes part Consultation as a result of its proximity Consultee/Agent ID Nature Of Response Officer Comments Response: of a Primary Centre. Those facilities marked in bold do not exist to Pocklington. It has been removed as at all in Newport or Gilberdyke. It seems that there is an it no longer meets the criteria required. overwhelming argument to twin North Cave and South Cave, and even without twinning, the facilities and infrastructure that South Cave enjoys is far superior to that in Gilberdyke and Newport combined. • Barmby Moor is situated just outside of Pocklington that has excellent facilities and infrastructure. Barmby Moor however is defined as Hinterland even though it has immediate access to far better facilities and infrastructure than Newport, Gilberdyke, North Cave and South Cave combined. So, why is there no decision to twin Barmby Moor with Pocklington? Incidentally, some parts of towns such as Beverley are so far from the centre, where most of the facilities exist, that they are in practice more remote than Barmby Moor. Twinning is in principal a good concept because it allows planners to look outside the boundaries of a settlement area. It is unfortunate however that the only villages to be twinned are two where, because of flood risk and therefore the same argument put forward for Rawcliffe, they should be downgraded probably to Hinterland areas than upgraded to Primary Centres.

Paragraph 3.8

Cllr John Whittle CSFC/177 Observations In detail, I feel rather sorry for Rawcliffe. I would have thought Comments noted. The Draft Strategy that if it was considered to be a Service Centre previously, it Document re-introduces Rawcliffe as a should not be ignored, but given a flood planning status that Primary Village (formerly Secondary would ensure all developments there are flood resilient/proof. Rural Service Centres) in terms of its function but does not promote the allocation of sites for housing on flood risk grounds. Consultee/Agent ID Nature Of Response Officer Comments Response:

Paragraph 3.10

N Rowland, Savills CSFC/405 Object We object to the absence of any reasoned justification for the Comments noted. The growth scenario on behalf of British upper and lower thresholds which have been selected for the recognises their role and function in the Heart Foundation PRSCs. Some settlements are able to accommodate development overall Settlement Network. It also more readily than others and to restrict growth to 10 dwellings supports the overall emphasis on per annum or 'whichever is lower' is seeking to impose an directing large scale development to inflexible restriction across all villages regardless of larger higher order settlements where circumstances. Applying a blanket approach to the PRSCs risks there are more services, facilities and not having providing the CS to allow sufficient flexibility to employment opportunities. respond to changing circumstances that occur over the plan period. This is contrary to PPS12 advice and the Council is at risk of having the plan found unsound on this basis.

Paragraph 3.11

Mrs Elizabeth CSFC/15 Observations Even these proposed development targets may be too high for Comments noted. The Infrastructure Rogers some villages where the existing infrastructure is already Study provides a good basis for overloaded. Transport networks, roads, traffic flows and considering these aspects. drainage issues are major factors to be considered. Mr Ian Owston CSFC/80 Object Development should not take place "to support existing facilites Comments noted. The Strategy and services". There should be adequate employment Document will seek to provide homes, opportunites in SRSCs for the people who will occupy the jobs, services and facilities together as proposed additional houses. Otherwise, development will simply far as possible. However, the rural encourage further commuting to areas of employment. nature of the East Riding also needs recognising and that housing need and demand is relatively widespread. The Strategy Document will also support economic development in the Primary Villages (formerly Secondary Rural Service Centres). Lyndsey Fielding, CSFC/534 Object 4) 3.11 states SRSC do not have the same role as PRSC but does Comments noted. To aid the Consultee/Agent ID Nature Of Response Officer Comments Response: South Cave Parish not define it. The failed dispersed polices have shown house understanding of their role, Secondary Council building does not support existing services and facilities. If it Rural Service Centres have been does, then please state the empirical evidence. renamed Primary Villages, in recognition that they are not necessarily service centres for a catchment. Instead, they are some of the East Riding’s larger villages with a good range of services and facilities which support the community.

The approach proposed in the Further Consultation, and followed through into the Draft Strategy Document, is much more focussed than the previous Humberside Structure Plan and Beverley Borough Local Plan. Lyndsey Fielding, CSFC/535 Object 5) 3.11- Levels of 10 % or 5 dwellings are not justified and are Comments noted. The growth scenario South Cave Parish simply proposed as is the 20% or 10 dwellings in 3.10 for PRSCs. recognises their role and function in the Council Evidence is required to support such "non- strategic" levels. overall Settlement Network. It also supports the overall emphasis on directing large scale development to larger higher order settlements where there are more services, facilities and employment opportunities. R J Kingdom, South CSFC/561 Object 4) 3.11 states SRSC do not have the same role as PRSC but does Comments noted. To aid the Cave Active not define it. The failed dispersed polices have shown house understanding of their role, Secondary Residents building does not support existing services and facilities. If it Rural Service Centres have been does, then please state the empirical evidence. renamed Primary Villages, in recognition that they are not necessarily service centres for a catchment. Instead, they are some of the East Riding’s larger villages with a good range of services and facilities which support the Consultee/Agent ID Nature Of Response Officer Comments Response: community.

Locating Development - Revised Policy SS2

Mr Tony Deakin on CSFC/61 Support I wish to register my support for the Core Strategy currently Support noted and welcomed. behalf of Client under consultation and in particular Policy SS2 'Locating Unknown, Development'. I am an Architect with several clients in Flamborough wishing to develop within the defined settlement and they are eagerly awaiting the Adoption of the Plan. Ms Rachael Martin, CSFC/576 Observations The points on Urban extensions to the City of Hull are noted in Comments noted. East Riding of Colliers relation to their Core Strategy publication version. However, the Yorkshire Council will continue to work International on Core Strategy is yet to be considered by an independent with Hull City Council (and other behalf of Mr Peter Inspector and the policies relating to Development priorities and neighbouring authorities) to ensure that Garrett, KeyLand Housing provision have each received 20 comments stating that strategies are relatively aligned and Developments the Strategy is Unsound. The Hull Strategy is based on the support good spatial planning overall. identification of sites within identified regeneration and renewal Consultee/Agent ID Nature Of Response Officer Comments Response: areas. Given the lack of development of these areas to date, the deliverability and achievability of them to deliver the required new housing is questioned and the Strategy is not robust in considering alternative approaches to satisfy the evidence base.

If the Hull Core Strategy is found to be unsound it is likely that the urban extensions on land within the East Riding will need to be considered. It is therefore considered that the potential for urban extensions to Hull over the plan period are addressed within Core Strategy policy SS2 and SS8. Mr Paul Forshaw, CSFC/975 Support with CSL does not object to the approach set out in Policy SS2 of Comments noted. Policy S4 of the Draft BNP Paribas Real conditions locating the majority of housing and employment development in Strategy Document provides the Estate on behalf of the Major Haltemprice Settlements. framework for development in rural Centrica Storage areas and reference is made to energy Limited (CSL) However, it is requested that Policy SS2 recognises that some generating development and forms of development by their nature cannot be suitably located infrastructure. within the main urban areas and require rural locations. In particular, energy generating development and infrastructure may require rural locations for operational reasons.

CSL therefore requests that Policy SS2 provides the flexibility for the development of, and extensions to such uses in rural areas. It is therefore requested that Part H of Policy SS2 is amended as indicated to allow for the development of essential infrastructure, such as energy infrastructure, in the Rural Service Centres and rural / countryside areas.

Suggested Revision -

"1. Residential development……

2. New and/or enhanced local services……

3. Economic development appropriate…… Consultee/Agent ID Nature Of Response Officer Comments Response:

[4. Energy development and associated infrastructure and other essential infrastructure (additional text)].” Mr Milner Edward CSFC/6 Observations Why set limits be as flexible as possible to meet local peoples Comments noted. A ‘strategy’ approach needs and wishes is necessary to ensure that the plan promotes and supports sustainable development overall. Mr Ian Owston CSFC/81 Object Allocations for housing in SCRCs should not be based on the Comments noted. A consideration of proposed formulaic approach, but should relate much more employment opportunities within closely to employment opportunities available in that settlement. villages formed part of the identification Otherwise, yet more commuting will be encouraged. Specifically, process for (previously referred to) in the case of Wilberfoss, there seems to be little possibility of Primary and Secondary Rural Service increased employment in the plan period. An increase of 75 Centres. The Strategy Document will dwellings will simply add to further commuting traffic on the also support economic development in already dangerously overloaded A1079. The Council's wish list these villages. for relief measures on the A1079 may not be realised. Gemma CSFC/352 Observations Settlement Status and Profile – Driffield and Little Driffield Comments noted. Edwardson, Edwardson The proposed “Settlement Network” defines Driffield as a Associates on “Principle Town” which will provide ‘the main focus of growth in behalf of S Griffin, East Riding of Yorkshire’. The status of Driffield is strongly supported and it is essential that this Principle Town provides the centre of both economic development and housing development in the area.

The revised version of the Core Strategy ‘Further Consultation’ dated October 2011 states that the figures previously outlined in the Preferred Approach Core Strategy are too low and there is a higher level housing demand than expected.

This means that the previously suggested figures of 1821 dwellings required up to 2026 has now been increased to 2,423 Consultee/Agent ID Nature Of Response Officer Comments Response: dwellings to 2028. In effect the numbers of dwellings required has increased by over 30%. In the light of this information, it is considered crucial that sites providing infill opportunities are even more important to reduce the impact of development in to the countryside on the edge of towns and settlements. Mr Wayne Low, CSFC/411 Object Core Strategy Further Consultation October 2011 Comments noted. The Strategy Richmond Document supports growth. The Properties on Policy SS2 Locating Development The Settlement Network Further Consultation, and the behalf of Mr David subsequent Draft Strategy Document, Watts We object to Policy SS2, Locating Development - The promotes a higher housing requirement Settlement Network. South Cave should not be designated as a and identified more land for economic supporting village or Secondary Rural Service Centre. This development than the Preferred designation has persisted through several drafts of the Core Approach Core Strategy previously Strategy, and does not properly take account of the range of consulted on. services and facilities in South Cave and therefore underestimates its sustainability. This policy does not reflect the The growth scenarios recognise the government’s aspirations to achieve economic growth. The role and function of Rural Service governments “Planning for Growth” agenda and the draft Centres and Primary Villages (formerly National Planning Policy Statement encourage development to Primary Rural Service Centres, secure economic growth. Policy SS2 which proposes to limit Secondary Rural Service Centres and development in South Cave to an increase in size of 10% over Hinterland Villages) in the overall the plan period is contrary to the government’s direction of Settlement Network. The ‘caps’ support travel of planning policy and will limit economic growth in a the overall emphasis on directing large sustainable location. scale development to larger higher order settlements where there are South Cave has a population of over 4,500 people which is more services, facilities and employment significantly bigger than the other Secondary Rural Service opportunities. Centres. It has an excellent range of services which are sustainably located in the centre of the village where they are Rural Service Centres (formerly Primary within easy walking distance of many homes. These services and Rural Service Centres) have been facilities include a primary school, doctor’s surgery, dentists, identified on the basis that they provide church, and sports club. The shops and other amenities include a a service centre role in rural locations chemist, bank, newsagent, supermarket, butchers two pubs, and and provide a well distributed spread post office. across the East Riding. In the area Consultee/Agent ID Nature Of Response Officer Comments Response: between Elloughton/Brough and There are a significant number of jobs in South Cave, the Howden, Gilberdyke/Newport is best Settlement Profile identifies 1,246 jobs in the Parish. This is more suited to fulfil the role of a Rural Service jobs than are present in the majority of Primary Rural Service Centre. Other suitable villages within Centres. the area have therefore been identified as Primary Villages (formerly Secondary South Cave should therefore be recognised higher in the Rural Service Centres and Hinterland settlement hierarchy of East Riding at the level of Primary Rural Villages). Service Centres or Local Service Centres. It is not appropriate for South Cave to be subject to the same planning policies on growth as a much smaller village such as Melbourne and it is in a much better position to accommodate growth.

The proximity of South Cave to Elloughton/Brough which is a Local Service Centre provides an opportunity for development in South Cave and Elloughton/Brough to be clustered in an area where there is a good range of facilities. Without growth to support their services and facilities, and to provide affordable housing the impact of falling household sizes effectively means that rural populations will fall over time. With significant restrictions being imposed on development in smaller villages it is important that to maintain services in rural areas that development is undertaken in sustainable locations such as South Cave at greater levels than is set out in the Core Strategy consultation document.

The draft National Planning Policy Framework sets out in paragraph 107 that the government’s objective is to increase significantly the delivery of new homes. The Framework states that in rural areas local planning authorities should be responsive to local circumstances and plan housing development to reflect local requirements. The inclusion of South Cave in the category of Secondary Rural Service Centre clearly does not meet the aims of the draft Framework as the opportunity will be missed to Consultee/Agent ID Nature Of Response Officer Comments Response: develop a sustainable centre and to deliver homes and facilities.

The position of South Cave in the settlement hierarchy is not logical given its sustainable level of facilities. South Cave should be recognised as a Primary Rural Service Centre or Local Service Centre. This would better reflect its facilities and its capacity for development. Without this change the Core Strategy will not be sound as it will not be founded on a robust and credible evidence base and will not be the most appropriate strategy. Joanne Hodgson, CSFC/492 Observations Given that many of the proposed locations have areas which are Comment noted. The Draft Strategy Yorkshire Wildlife important for biodiversity nearby, section C should include a Document includes a policy on Trust statement to say that development should not adversely affect biodiversity value and the Plan should be areas of high biodiversity value. read as a whole. Lyndsey Fielding, CSFC/537 Object 7) Revised policy B states Haltemprice settlements and principle Comment noted. Policy S3of the Draft South Cave Parish towns will be the main focus of growth, however proposed Strategy Document has been amended Council growth as set out in SS4 is only slightly more than the PRSC, to note that the Major Haltemprice SRSC and Rural areas in percentage terms, and Haltemprice Settlements, Principal Towns and Towns settlements will provide for less dwellings than local service will be the main focus for growth in the centres in what way does this constitute a "main focus" East Riding.

In Policy S5 of the Draft Strategy Document, the Major Haltemprice Settlements and the Principal Towns account for over 60% of the authority’s whereas the Rural Service Centres, Primary Villages, Villages and the Countryside account for just over 17%. Lyndsey Fielding, CSFC/538 Object 8) Revised policy B states SRSC will provide for more limited Comment noted. The preliminary South Cave Parish development (85 dwellings for South Cave) to sustain and meet findings from the Strategic Housing Council the needs of rural areas. As in our original submission South Market Assessment/Housing Needs Cave only meets its own dormitory needs. There is little rural Survey shows a relatively high level of hinterland which is served by South Cave. b The only local need housing requirement in South Cave. Consultee/Agent ID Nature Of Response Officer Comments Response: is for affordable housing. South Cave’s own parish survey also demonstrated significant difficulties for existing residents purchasing properties in the village.

Policy S3 of the Draft Strategy Document notes the role of Rural Service Centres and Primary Villages as ‘…complementing the roles of Towns in meeting some of the basic needs outside of the Major Haltemprice Settlements, Principal Towns.” Lyndsey Fielding, CSFC/540 Object 9) Revised policy G, In what way does 85 dwellings meet local Comment noted. The preliminary South Cave Parish community needs and what hinterland does South Cave further findings from the Strategic Housing Council serve the "basic needs" in "more remote areas". Market Assessment/Housing Needs Survey shows a relatively high level of housing requirement in South Cave. The South Cave Parish Council survey in 2010 recorded 21.5% of households (extrapolated to 356 households) having difficulty finding an affordable home locally in the last 5 years – 97% of which were seeking owner-occupied tenure.

Policy S3 of the Draft Strategy Document notes the role of Rural Service Centres and Primary Villages as ‘…complementing the roles of Towns in meeting some of the basic needs outside of the Major Haltemprice Settlements, Principal Towns.” Lyndsey Fielding, CSFC/541 Object 10) South Cave cross roads Market place/church Street/Beverley Comments noted. It is agreed that South Cave Parish Road is 4.86km from the centre of Brough, a Local Service South Cave should be considered as a Consultee/Agent ID Nature Of Response Officer Comments Response: Council Centre (as per draft Town centre plans). How does this Hinterland Village (now known as constitute "remote" when it falls within the "Hinterland Village" Primary Village) due to its proximity to distance. We can find no definition of "remote" within the core Elloughton cum Brough. strategy. Lyndsey Fielding, CSFC/542 Object 11) Revised policy H Percentages and dwellings per annum are Comment noted. The Local Plan, and South Cave Parish arbitrary (but at least the issue of overdevelopment is recognised the Strategy Document in particular, Council however the development level is too high). JSP clearly indicates replaces the Joint Structure Plan (and that settlements under D3 level are not strategic in nature, Policy DS3). The scale of development something which this policy still ignores. proposed in the (now) Rural Service Centres and Primary Villages is not strategic, especially as it is split between numerous settlements (12.6%). The proposed approach for housing development in South Cave represents 0.36% of the overall housing requirement. R J Kingdom, South CSFC/564 Object 7) Revised policy B states Haltemprice settlements and principle Comment noted. Policy S3of the Draft Cave Active towns will be the main focus of growth, however proposed Strategy Document has been amended Residents growth as set out in SS4 is only slightly more than the PRSC, to note that the Major Haltemprice SRSC and Rural areas in percentage terms, and Haltemprice Settlements, Principal Towns and Towns settlements will provide for less dwellings than local service will be the main focus for growth in the centres in what way does this constitute a "main focus" East Riding.

In Policy S5 of the Draft Strategy Document, the Major Haltemprice Settlements and the Principal Towns account for over 60% of the authority’s whereas the Rural Service Centres, Primary Villages, Villages and the Countryside account for just over 17%. R J Kingdom, South CSFC/565 Object 8) Revised policy B states SRSC will provide for more limited Comment noted. The preliminary Cave Active development (85 dwellings for South Cave) to sustain and meet findings from the Strategic Housing Consultee/Agent ID Nature Of Response Officer Comments Response: Residents the needs of rural areas. As in our original submission South Market Assessment/Housing Needs Cave only meets its own dormitory needs. There is little rural Survey shows a relatively high level of hinterland which is served by South Cave.b The only local need is housing requirement in South Cave. for affordable housing. South Cave’s own parish survey also demonstrated significant difficulties for existing residents purchasing properties in the village.

Policy S3 of the Draft Strategy Document notes the role of Rural Service Centres and Primary Villages as ‘…complementing the roles of Towns in meeting some of the basic needs outside of the Major Haltemprice Settlements, Principal Towns.” R J Kingdom, South CSFC/566 Object 9) Revised policy G, In what way does 85 dwellings meet local Comment noted. The preliminary Cave Active community needs and what hinterland does South Cave further findings from the Strategic Housing Residents serve the "basic needs" in "more remote areas". Market Assessment/Housing Needs Survey shows a relatively high level of housing requirement in South Cave. The South Cave Parish Council survey in 2010 recorded 21.5% of households (extrapolated to 356 households) having difficulty finding an affordable home locally in the last 5 years – 97% of which were seeking owner-occupied tenure.

Policy S3 of the Draft Strategy Document notes the role of Rural Service Centres and Primary Villages as ‘…complementing the roles of Towns in meeting some of the basic needs outside of the Major Haltemprice Settlements, Principal Towns.” Consultee/Agent ID Nature Of Response Officer Comments Response: R J Kingdom, South CSFC/567 Object 10) South Cave cross roads Market place/church Street/Beverley Comments noted. It is agreed that Cave Active Road is 4.86km from the centre of Brough, a Local Service South Cave should be considered as a Residents Centre (as per draft Town centre plans). How does this Hinterland Village (now known as constitute "remote" when it falls within the "Hinterland Village" Primary Village) due to its proximity to distance. We can find no definition of "remote" within the core Elloughton cum Brough. strategy. R J Kingdom, South CSFC/569 Object 11) Revised policy H Percentages and dwellings per annum are Comment noted. The Local Plan, and Cave Active arbitrary (but at least the issue of overdevelopment is recognised the Strategy Document in particular, Residents however the development level is too high). JSP clearly indicates replaces the Joint Structure Plan (and that settlements under D3 level are not strategic in nature, Policy DS3). The scale of development something which this policy still ignores. proposed in the (now) Rural Service Centres and Primary Villages is not strategic, especially as it is split between numerous settlements (12.6%). The proposed approach for housing development in South Cave represents 0.36% of the overall housing requirement. Gemma CSFC/831 Object COMMENTS RELATING TO ROOS VILLAGE – ROO1 Comment noted. The development of Edwardson, specific sites will be considered through Edwardson INTRODUCTION the Allocations Document. Associates on behalf of Client The comments detailed below are made in response to the The growth scenarios recognise the Unknown, proposed policy and changes to the Core Strategy since the last role and function of Rural Service public consultation. This submission relates specifically to the Centres and Primary Villages (formerly previously defined Supporting Village Roos, now proposed to be Primary Rural Service Centres, allocated as a Secondary Rural Service Centre (Revised Policy Secondary Rural Service Centres and SS2 : Locating Development). Hinterland Villages) in the overall Settlement Network. The ‘caps’ support ROOS SETTLEMENT the overall emphasis on directing large scale development to larger higher The proposed structure of the Settlement Network and order settlements where there are additional categories including Hinterland Villages and Rural more services, facilities and employment Consultee/Agent ID Nature Of Response Officer Comments Response: Villages is generally supported. opportunities.

The classification of Roos as a Secondary Rural Service Centre is The availability of land (and the impact also supported and essential to “sustain the overall vitality of of development on the environment and rural areas”. infrastructure) is a factor for consideration but this needs to be Residential development should be allocated in the most balanced against other policy objectives. appropriate locations but the proposal to limit any future growth Therefore a guide for how much to a maximum of 10% of the size of the village over the plan housing should be provided is required. period for Secondary Rural Services Centres, or 5 dwellings per annum, whichever is lower (Policy H, Revised Policy SS2: The Strategy Document needs to Locating Development) is strongly resisted. provide the overall framework for deciding how much development will This suggested policy approach centres on applying an across the take place in different locations. Such board ‘formula’ taking no account of the overall characteristics decisions cannot be devolved to other and needs of the settlement of merits of individual sites. Some documents such as the Allocations settlements may have the capacity to accommodate more houses Document. without undue detriment as there are several sustainable sites available whilst others may have few opportunities for housing The phasing of housing delivery may not without seriously impacting on its essential character. The be necessary and may provide additional detailed site assessment and allocation process may well reveal restrictions on development in difficult that releasing more land through allocating sustainable sites in economic times. Reference to phasing some of the Rural Service Centres will avoid the need to allocate has been removed from Policy S5 of the far less suitable sites elsewhere, to the benefit of the overarching Draft Strategy Document. objectives underpinning good planning. Development proposed in Primary and The detailed analysis of sites at the allocations stage may also Secondary Rural Service Centres is not indicate that the smaller settlements can offer a more sustainable meant to be restricted on a per annum development option than simply expanding the major settlements basis. The document provides an annual and principal towns onto peripheral green field sites. Being able figure for illustration prurposes only. to walk into a smaller settlement to use and support the various services and facilities in the village is likely to often prove more To aid clarity, Policy S5 of the Draft sustainable than people living on housing developments remote Strategy Document refers to total from a town centre where all services are only realistically housing provision over plan period and Consultee/Agent ID Nature Of Response Officer Comments Response: accessible by private car. It is suggested, therefore, that the reference to annual delivery has been proportion of new houses to be provided for in the various removed. settlement categories should not be prescribed at this stage but would best be determined following the more detailed A low figure of existing planning assessment of the comparative benefits of developing the many permissions in the village could equally housing land options/sites available across the area. reflect low demand rather than high demand. This proposed policy has in effect reduced the settlements’ growth projections from 85 in total to 2026 to 2.1 dwellings per annum. In total only 35 dwellings will be allocated up to 2028 in Roos.

It is considered that this proposal will significantly affect the future viability of housing growth in the settlement and will potentially detract developers bring land forward during the plan period.

NATIONAL PLANNING POLICY CHANGES

The amendments to PPS3 including the downgrading of garden land to greenfield status and the relaxation of high density thresholds means that the potential for windfall housing is significantly reduced in rural settlements. In the light of these National Planning Policy changes it is therefore nonsensical to slash the future housing allocations of a settlement such as Roos so significantly.

The application of a restrictive numerical policy to all settlements within this category does not consider the settlements identity, requirements or likely future prospects. This proposed change is strongly resisted. Each settlement should be considered individually, as previously assessed in order to establish future levels of growth for example; the services such as primary schools, infrastructure and housing demand should not be Consultee/Agent ID Nature Of Response Officer Comments Response: ignored.

PHASING OF DEVELOPMENT

There is a clear demand and need for housing in rural areas. The East Riding of Yorkshire is the largest rural Local Authority in the country and it must be acknowledged that economic and residential growth needs to be allocated to rural settlements. A significant “pull” or attraction to those who wish to live in the area is the rural nature of the Local Authority and if the area is to act upon this demand, housing needs to be provided for in those areas.

The phasing of development is essential and perhaps more relevant to large growth projections in the Principal Towns and Major Haltemprice Settlements. In smaller rural settlements, such as Roos, the housing market is led by demand. This means that, in effect specifying a 2.1 per annum growth rate is too restrictive and specific in rural settlements such as this. The proposed cut in settlement growth from 85 dwellings to 35 in effect is a 60% reduction in growth. We strongly object to this proposed change and request that the former more beneficial growth is restored.

The figures provided in the latest Site Assessments stated that as at 1 January 2010, there were only 7 dwellings in Roos which had planning permission and had not yet been built. This figure is low, particularly when compared to other larger settlements in the area. This evidence suggests there is a demand for housing in Roos, and as and when planning permission is obtained, development does come forward.

The restrictive approach proposed (to cap growth to 10% of the current housing unit numbers) might prevent landowners Consultee/Agent ID Nature Of Response Officer Comments Response: bringing land forward for development if planning policy is too limited. For example, the project will need to be financially viable and infrastructure costs will be taken into account at the outset. If development is restricted to 2 dwellings per annum, there is a danger that no applications will be submitted or development started until a significant time has elapsed to allow a larger development to come forward without exceeding the overall “target” figures for the settlement? In addition, planning fees and the costs associated with submitting an application will be proportionately high and off putting if this policy is adopted.

The future of the settlements’ short term 5 year housing supply could be therefore restricted if the 10% cap on development is adopted.

CONCLUSIONS

It is hoped that this response (which supports and objects) to the proposed changes in “Locating Development Policy SS2” is considered by officers in relation to the Further Consultation.

The proposed changes in the level of growth in Roos are a particular concern. This settlement will be disadvantaged considerably as a result and the aim to sustain the overall vitality of rural areas is at risk of being lost if the revised approach is adopted.

Each settlement should be assessed individually and judged on its own merits rather than the application of a percentage growth restriction which will in effect ignore the future sustainability of the village. It is therefore important to clearly state that the former approach to allocating housing growth within Roos village is supported and the proposed 10% growth restriction is strongly resisted by the landowner concerned. Consultee/Agent ID Nature Of Response Officer Comments Response: Gemma CSFC/864 Support LAND TO THE REAR OF WESTGATE (39C), NORTH CAVE, Comment noted. The development of Edwardson, HU15 2NG ON BEHALF OF MR J CLARKE specific sites will be considered through Edwardson the Allocations Document. Associates on INTRODUCTION behalf of Mr J Clarke We are acting on behalf of the owners of the parcel of land as identified on the enclosed plan. The land is located within the settlement of North Cave and is submitted for consideration as a live-work site for the location of a small rural business and combined residential property.

SUMMARY

The proposal site is considered entirely appropriate to warrant a formal allocation for a home-based rural business due to its village location. The site is currently occupied by the owner and has previously been used as a private equine facility.

As outlined below, the site could be developed without giving rise to any unacceptable harm and therefore could achieve the role of the Secondary Rural Service Centre – to sustain the overall vitality of rural areas.

The allocation and consideration of this type of land holding for a low-key home based rural business and home (live-work) unit is in line with the proposed “forms of development” that will be supported:

1. Residential development, commensurate with the scale, role and character of the village.

2. New and/or enhanced local services and facilities: or

3. Economic development appropriate to the scale of the village. Consultee/Agent ID Nature Of Response Officer Comments Response:

It is considered that land panels, particularly located adjacent to existing settlements (and within walking distance of the facilities and services) such as this should be considered acceptable for the location of live-work units.

SETTLEMENT STATUS – NORTH CAVE

The Preferred Approach Core Strategy identified North Cave as a “Supporting Village”. The Core Strategy Further Consultation (October 2011) reviews this category and redefines the settlement as a “Secondary Rural Service Centre” (Revised Policy SS2).

The allocation of North Cave as a Secondary Rural Service Centre is considered appropriate as the village has a full range of services which are currently supported by the local community.

The settlement has good transport links to Beverley, Hull City Centre, Wyke College, Goole and the Major Haltemprice Settlements including Anlaby, Hessle, Willerby and Kirkella via EYMS bus routes (143, 151, 153, 155-156, 160/162, 930).

Gilberdyke railway station is within 4 miles and the A63/M62 is within less that a mile – making it readily accessible to the main motorway links.

The village has a full range of services including North Cave Primary School, North Cave Sports and Social Club, North Cave Indoor Bowls Centre, White Hart Public House, Yorkshire Law Solicitors, Londis supermarket, Post Office, Black Swan Public House, 2 Hairdressers, North Cave Village Hall and Petrol Station (A63).

Consultee/Agent ID Nature Of Response Officer Comments Response: The proposed Secondary Rural Service Centre status for North Cave is supported and both economic and residential development allocations are essential for the future.

The strong transport links between North Cave and the Major Haltemprice Settlements, Principal Towns and Local Service Centres mean that the settlement is suitable for both rural businesses (which are appropriate in village locations) and residential developments. Live-work units will provide an additional balance that is ideal for North Cave – and land parcels located adjacent to the existing development limit and within walking distance of the services, - such as this, -should be considered for this type of use. Gemma CSFC/866 Object The Preferred Approach Core Strategy to 2026 previously Comment noted. Edwardson, anticipated 85 dwellings up to this period for North Cave. As at Edwardson 01/01/2010, there were only 7 dwellings with planning The growth scenarios recognise the Associates on permission which had not been built – suggesting there is a role and function of Rural Service behalf of Mr J demand for housing in this area. Centres and Primary Villages (formerly Clarke Primary Rural Service Centres, The Revised Core Strategy limits the total number of dwellings Secondary Rural Service Centres and to the period up to 2028 to 59 dwellings. Hinterland Villages) in the overall Settlement Network. The ‘caps’ support Residential development should be allocated in the most the overall emphasis on directing large appropriate locations but the proposal to limit any future growth scale development to larger higher to a maximum of 10% of the size of the village over the plan order settlements where there are period for Secondary Rural Services Centres, or 5 dwellings per more services, facilities and employment annum, whichever is lower (Policy H, Revised Policy SS2: opportunities. Locating Development) is strongly resisted. The availability of land (and the impact This suggested policy approach centres on applying an across the of development on the environment and board ‘formula’ taking no account of the overall characteristics infrastructure) is a factor for and needs of the settlement of merits of individual sites. Some consideration but this needs to be settlements may have the capacity to accommodate more houses balanced against other policy objectives. without undue detriment as there are several sustainable sites Therefore a guide for how much Consultee/Agent ID Nature Of Response Officer Comments Response: available whilst others may have few opportunities for housing housing should be provided is required. without seriously impacting on its essential character. The detailed site assessment and allocation process may well reveal The Strategy Document needs to that releasing more land through allocating sustainable sites in provide the overall framework for some of the Rural Service Centres will avoid the need to allocate deciding how much development will far less suitable sites elsewhere, to the benefit of the overarching take place in different locations. Such objectives underpinning good planning. decisions cannot be devolved to other documents such as the Allocations The detailed analysis of sites at the allocations stage may also Document. indicate that the smaller settlements can offer a more sustainable development option than simply expanding the major settlements A low figure of existing planning and principal towns onto peripheral green field sites. Being able permissions in the village could equally to walk into a smaller settlement to use and support the various reflect low demand rather than high services and facilities in the village is likely to often prove more demand. sustainable than people living on housing developments remote from a town centre where all services are only realistically accessible by private car. It is suggested, therefore, that the proportion of new houses to be provided for in the various settlement categories should not be prescribed at this stage but would best be determined following the more detailed assessment of the comparative benefits of developing the many housing land options/sites available across the area.

It is also suggested that the positive allocation of sites such as this can positively contribute to housing needs whilst providing new opportunities for small rural businesses to be established from sustainable settlements.

THE SITE

The site comprises of 2.469 ha (6.027 acres) of land and buildings located to the South of Westgate, North Cave. The land has a modern building group within the north-east corner of the site which includes a large range of stables constructed of block work Consultee/Agent ID Nature Of Response Officer Comments Response: and steel profile sheeting, a timber stable and a ménage.

The site has been used for private equine facilities and is outside the village’s Conservation Area.

Access is unrestricted and via a private road from Eastgate. This is not owned by the landowner.

Buildings and residential properties are located directly to the north of the land parcel.

The land is not within an area identified by ERYC’s Strategic Flood Risk Assessment – as other large areas of North Cave do fall within a High Risk Flood Area.

There are no known archaeological interests such as Scheduled Ancient Monuments – however, a dismantled railway is located outside the holding to the far south of the site. It is considered that any development would however occur to the north of the site, adjacent to the existing built form.

A public footpath runs through the middle of the land and this would not be affected by a single live-work unit.

The site is within walking distance of all North Caves’ services and facilities and in considered within the existing built form of the village and within a residential and rural business location.

***Please see hard copy of the response for map showing the location of the site concerned*** Gemma CSFC/867 Object ASSESSMENT – LIVE/WORK POLICY Comment noted. The explanation text Edwardson, alongside Policy S4 of the Draft Strategy Edwardson Live-work units are becoming a sustainable way of providing Document refers to and supports live- Associates on rural homes and business opportunities together. work units. Consultee/Agent ID Nature Of Response Officer Comments Response: behalf of Mr J Clarke East Riding of Yorkshire Council have more recently approved live-work schemes for both new build live-work schemes and the conversion of buildings for this type of use.

A new-build scheme was approved in Walkington as it provided “genuine sustainable homes” despite being contrary to the Development Plan.

Live-work units are a relatively new form of development so the current Development Plans do not fully cover the concept.

Recent planning consents issued by ERYC provide reasons for approval including development meeting local needs and contributing towards sustaining the role of the settlement and general support for diversification in the countryside.

The Local Development Framework and Core Strategy in particular provides the opportunity to produce a policy that specifically relates to the provision of live-work units in appropriate locations.

Live-work units should be supported where either existing buildings can be converted, or single new build units in sustainable locations, such as adjacent to or within walking distance of settlements including Rural Villages, Hinterland Villages, Secondary and Primary Service Centres and Local Service Centres.

Local Authorities across England have supported the provision of live-work developments. In particular, Andrew Fore (Senior Planning Officer at Wyehaven District Council) hosted a seminar supported by the RTPI in relation to rural live-work areas.

Consultee/Agent ID Nature Of Response Officer Comments Response: The seminar revealed some of the benefits live-work opportunities in the countryside and are summarised below:

• Reduction in commuting • Growth of micro-business environment • In rural areas whose vitality is under threat, the daytime economy can benefit • Rural diversification role

Live-work buildings also provide the opportunity for high quality design which can deliver sustainable developments in rural areas.

It is important that Live-work developments should not threaten allocated employment sites (which are normally located in the larger towns). The provision of live-work units outside of the Principal Towns will prevent this threat.

The seminar concluded that there is a clear demand for live- work in rural areas. The East Riding would benefit significantly due to its high percentage of small businesses based in its rural- dominated area.

The South Worcestershire Development Plan (September 2011) has, for example, acknowledged the benefits of home-work/live- work arrangements in rural areas through its DPD:

“Home working accounts for over 11% of all employment in South Worcestershire. There is a need to continue to diversify the local economy to create wider employment base so that South Worcestershire is less vulnerable to international and national economic changes”.

This Local Authority is also predominantly rural and is similar to the East Riding. It has included within proposed policy SWDP22: Consultee/Agent ID Nature Of Response Officer Comments Response: Rural Employment the following live-work proposal:

Definition of Live/Work Units: A purpose designed unit or group of buildings to enable occupiers to live and work within the premises.

“Policy SWDP 22: The provision of rural based workspace and live/work units will be permitted providing the proposals are small scale and that they are appropriated to the existing character of the area. In all cases the preference will be for conversion of existing buildings. However, proposals for new development should be located in accordance with the settlement hierarchy as set out in SWDP1 and should have reasonable access to services and facilities.

All proposals for employment related development within the rural areas will need to demonstrate that they have taken full account of the relevant criteria as set out in Policy SWDP3”.

The inclusion of such a policy, or similar within the East Ridings Core Strategy DPD is considered an important addition. It is requested, therefore that a live/work policy is included as either a separate policy or within the Revised Policy SS2 and Revised Policy SS3.

CONCLUSIONS

The allocation of appropriate sites such as this land parcel for small scale, single live-work development would assist with maintaining the vitality of Rural Service Centres and smaller rural settlements such as North Cave.

The provision of housing sites alone is also important – but live/work units provide employment and residential opportunities Consultee/Agent ID Nature Of Response Officer Comments Response: in a home working environment which is already a popular concept in rural areas including the East Riding.

At present, the Revised Core Strategy does not specifically allocate appropriate sites for this type of development. It also does not provide policy for live/work developments. It is considered, that a large rural authority should include a live/work policy that supports small rural businesses close to or adjoining the Local Service Centres, Primary and Secondary Rural Service Centres, Hinterland Villages, and Rural Villages. They offer combined employment and residential solutions to demand and are entirely appropriately located in sites such as this parcel of land to the rear of Westgate, North Cave.

The small scale single live-work use of this parcel of land would provide a rural business opportunity with a home that will be low-key and will support North Cave’s services and facilities such as the Post Office.

The inclusion of North Cave in the Settlement Network as a Secondary Rural Service Centre (Revised Policy SS2) is supported; however, the provision of live-work opportunities is not included. Support for this type of development is considered entirely appropriate in this location and given the rural nature of the East Riding; the policy should be included to support it. Gemma CSFC/868 Object RESPONSE AND FURTHER COMMENTS IN RELATION TO Comment noted. The development of Edwardson, LAND AT KILHAM - REFERENCES KIL7 AND KIL8 specific sites will be considered through Edwardson the Allocations Document. Associates on INTRODUCTION behalf of Client The growth scenarios recognise the Unknown, role and function of Rural Service The comments detailed below are made in respect of the Centres and Primary Villages (formerly proposed changes and emerging policy in the Core Strategy since Primary Rural Service Centres, the last publication. This submission relates specifically to the Secondary Rural Service Centres and Consultee/Agent ID Nature Of Response Officer Comments Response: settlement of Kilham and potential future housing development Hinterland Villages) in the overall in the light of the revised policy although some of the points Settlement Network. The ‘caps’ support being made are relevant to the overarching approach set out in the overall emphasis on directing large the consultation document. scale development to larger higher order settlements where there are We are making a joint submission having been instructed by the more services, facilities and employment owners of the parcels of land KIL7 and KIL8 to act on their opportunities. behalf. Whilst this submission should not be regarded as in any way ruling out the possibility that parts of the total area could be The availability of land (and the impact developed separately on their own merits, it is considered that of development on the environment and the inter-relationship of the sites is such that a coordinated infrastructure) is a factor for approach to the development of the whole of this land parcel consideration but this needs to be represents the most beneficial option for housing development. balanced against other policy objectives. This approach will maximise the benefits to the settlement in Therefore a guide for how much terms of the efficiency in providing for the new housing required housing should be provided is required. whilst also minimising any adverse impacts in meeting this requirement. A combined approach will better ensure the The Strategy Document needs to efficient use of infrastructure whilst also enabling locally provide the overall framework for important features to be protected and enhanced, such as the deciding how much development will public rights of way and views through to the Church. take place in different locations. Such decisions cannot be devolved to other Please regard this submission as also comprising updated documents such as the Allocations information in support of the current land bids in respect of KIL7 Document. and KIL8.

POLICY APPROACH

The Core Strategy Further Consultation proposes that the status of Kilham as a Rural Service Centre be adjusted to become a Primary Rural Service Centre. This is considered appropriate and is, therefore, supported but it is not felt that this should be accompanied by a severe reduction in the level of new housing considered needed over the plan period.

Consultee/Agent ID Nature Of Response Officer Comments Response: The amendments to PPS3 including the downgrading of garden land to greenfield status and the relaxation of high density thresholds means that the potential for windfall housing is significantly reduced in rural settlements. In the light of these National Planning Policy changes it is therefore inappropriate to radically reduce the level of future housing allocations in a settlement such as Kilham and this change is strongly resisted.

The revised policy approach centres on applying an across the board ‘formula’ based on a maximum number of units per annum of 10 or a maximum 20 percent increase in village size over the plan period. Such a simplistic approach takes no account of the overall characteristics and needs of the settlement or the merits of individual sites. Some settlements may have the capacity to accommodate more houses without undue detriment as there are several suitable sites available whilst others may have few opportunities for housing without seriously impacting on its essential character. At this stage in the LDF process it may be more appropriate to set an approximate threshold for the number of houses to be provided in the settlement category as a whole (e.g.: for all the Primary Rural Service Centres) but to leave the final figures for the various categories and for the individual settlements until a more complete review of the various sites put forward across the whole of the Council area has been thoroughly assessed as part of the allocations process. The detailed site assessment and allocation process may well reveal that releasing more land through allocating suitable sites in some of the Primary Rural Service Centres will avoid the need to allocate far less suitable sites elsewhere, to the benefit of the overarching objectives underpinning good planning.

The detailed analysis of sites at the allocations stage may also indicate that the smaller settlements can offer a more sustainable development option than simply expanding the major settlements Consultee/Agent ID Nature Of Response Officer Comments Response: and principal towns onto peripheral green field sites. Being able to walk into a smaller settlement to use and support the various services and facilities in the village is likely to often prove more sustainable than people living on housing developments remote from a town centre where all services are only realistically accessible by private car. It is suggested, therefore, that the precise proportion of new houses to be provided for in the various settlement categories should not be prescribed at this stage – the figure should be a rough guideline only which can be subject to change following the more detailed assessment of the comparative benefits of developing the many housing land options/sites available across the area.

THE BENEFITS OF THE COMBINED SITE

The land comprising KIL7 and KIL8 is well located in relation to the existing built form of the village and general pattern of residential development. A comprehensive approach to the development of the land as a whole will bring significant gains in terms of infrastructure and service provision as well as providing the opportunity to plan the site so as to minimise impacts on the village and maximise potential benefits. It is of a size capable of providing for a variety of general benefits together with a good mix of house types to meet the potential needs of the settlement.

The owners of the total site also own adjoining land such that the boundaries could be enlarged/amended if considered appropriate, for example if areas are given over to public uses/walks or kept free of housing to maintain important views, etc.

This site offers particular benefits when looked at as a whole. For example, the whole parcel could be developed off a single safe Consultee/Agent ID Nature Of Response Officer Comments Response: access onto what appears to be the most suitable highway in the village and without the need for vehicular access/traffic to be taken through the main body of the settlement. Land in the same ownership can be utilised to provide a full hydro-brake and surface water storage system to ensure the development does not give rise to any flooding issues. It is also probably unique in being capable of development without connecting into the sewage network running through the village which is already struggling to cope with current flows. A direct connection via land in the same ownership will provide the requisite housing without having the cost and disruption of renewing drainage infrastructure through the settlement, this being a major disadvantage in respect of other possible sites.

The small part of the total land parcel at potential risk of flooding is closest to the main body of the village and could be retained as open space serving as something of a ‘buffer’ which could be added to if appropriate to retain views across to the church. The existing public footpaths can be fully provided for as part of a larger scheme in a way to ensure they remain attractive to users.

The site does not suffer from the likely problems of the majority of other potential housing land allocations in the settlement - development will not impact on known archaeological interests; it will not displace any existing employment use; the site is large enough to ensure the amenities of nearby residential properties are not unacceptably affected and the necessary provision can readily be made for site infrastructure.

The site will be able to provide a significant part of the required number of dwellings in the settlement over the plan period. A joint development of this site will help ensure a phased approach limiting the rate of house building can be achieved. The provision of open space and the retention of footpaths mean there is likely Consultee/Agent ID Nature Of Response Officer Comments Response: to be a need for some additional allocation of land within the village but any such provision would be relatively modest such that land could be chosen so as to limit the potential problems associated with many of the other sites around the settlement.

CONCLUSION

In principle, the proposed changes to the settlement hierarchy is supported but the reduction in the overall requirement for housing land in settlements like Kilham is not considered justified. Determining future housing numbers by settlement is premature in advance of the detailed analysis of the relative merits of available sites. To rule out potentially good sites ahead of any such assessment is contrary to good planning and is likely to result in damaging sites being brought forward in the main settlements in an endeavour to make the numbers ‘fit’. It is hoped that this response to the points being made will be taken on board and that the Core Strategy will now set aside the allocation of house numbers by settlement until as proper assessment of the merits of the sites has been undertaken. However and in any event, the land comprising KIL7 and 8 is considered to be ideal to meet a good part of the housing requirement and the combination of these land parcels will bring many advantages to what is considered to be the most suitable site in Kilham for housing purposes. Mr David Renwick, CSFC/999 Support with Whilst the overall approach seems reasonably sensible it would Coment noted. The Draft Strategy East Riding Of conditions be useful to clarify the environmental issues associated with Document includes a policy on Yorkshire Council development in the countryside especially that now proposed for biodiversity value and the plan should be smaller settlements. This could be done by a short paragraph read as a whole. within the supporting text for the policy explaining that the hinterlands and green spaces within many small settlements hold The Allocations Document will consider significant local biodiversity value and that this should be the development of individual sites. protected/enhanced in line with the LDF green infrastructure and biodiversity policies. For example Local Wildlife Sites may be Consultee/Agent ID Nature Of Response Officer Comments Response: located on or within existing development limits for small settlements/villages and development should be prevented on these sites.

Figure 2 - Revised East Riding Settlement Network

Mr P. Crossland, CSFC/121 Object Despite our response to the last consultation (dated 15 July Comment noted. The Draft Strategy Rudston Parish 2010), the Bridlington Coastal boundary line has not been Document now shows Rudston within Council changed. We assume that the intention of these boundaries is to the Driffield and Wolds Sub Area. keep together areas that have common development issues. Rudston, and in our view other North Wolds parishes, have much more in common with the Wolds than with Coastal. Please move the boundary eastwards to place Rudston in the Driffield and Wolds area.

Question 2

Mr James Carder CSFC/4 Support I do agree that there is a great need to create more employment Comment noted. The Local Plan is not within the east riding especialy in bridlington which at present is directly responsible for the provision of lacking. public transport but one of the Strategy Document’s overall aims is to promote One problem we need to readdress is the transport cuts development which can take advantage regarding our bus services this will need improving sooner than of existing public transport provision. later one example is the bus services in and around bridlington, as well rural areas this will need improving. The Infrastructre Study has helped to consider the impact of new If proposing increases in population this means more houses with development on existing infrastructure. facilities available ie drainage, water supply power and gas supplies so on ie public utilities and so,at a reasonable cost.

hope you will consider. Ian Smith, English CSFC/43 Observations The Plan’s Objectives seek to protect the area’s landscape Comment noted. Part C of the policy Heritage Yorkshire character and the setting of its settlements. This aspect is has been removed as it duplicates other Consultee/Agent ID Nature Of Response Officer Comments Response: Region currently missing from Policy SS2. parts of the policy. There are a wide number of issues to consider in terms of Suggested amendment: development (e.g. landscape setting, flood risk) but which are not listed in Amend the end of Policy SS2 Criterion C. to read:- this particular policy. Therefore the Plan will need to be read as a whole and “…and will be appropriate to its size, character, and landscape includes a policy approach for setting” considering the ladscape setting (Policy ENV2 of the Draft Strategy Document). Gemma CSFC/49 Support The proposed "Settlement Network" defines Driffield as a Comment noted and support Edwardson, "Principle Town" which will provide `the main focus of growth in welcomed. Edwardson East Riding of Yorkshire'. The status of Driffield is strongly Associates on supported and it is essential that this Principle Town provides The Allocations Document will consider behalf of Mr T A the centre of both economic development and housing the development of individual sites. Naylor development in the area.

Driffield serves a large catchment area including nearby villages and settlements with limited services and is a key transport link to the other employment areas such as Hull and Scarborough. Driffield is a key supply and hub of services for these surrounding villages and many are served by public transport links including the bus routes or railway. The highway network is also good to the surrounding areas including Beverley, Bridlington and Hull.

The Proposed `Place Statement' for Driffield aims to revitalise the town and includes the `removal of derelict areas'. This site if developed would satisfy this vision.

The level of housing required means there is a requirement for a number of sustainably located Greenfield sites to contribute to meet the housing needs. This site provides the opportunity for development which is not detached from the built form without the need to encroach into the countryside as it is contained by residential properties and the road. Consultee/Agent ID Nature Of Response Officer Comments Response:

The Core Strategy suggests that due to the `lower level of demand for economic development' in Driffield - and given `the need to ensure jobs and housing are provided together' `the level of housing in Driffield may not necessarily be as high as the other Principle Towns.

It is important that Driffield - as a historic market town that has previously relied on the farming communities is encouraged to thrive economically and sustainably. The correct level of economic growth and the provision of quality housing schemes is essential to allow the Town to thrive. As agriculture has been in decline for some time, the traditional market town feel is deteriorating. It is therefore vital that the Core Strategy also focuses on revitalising Driffield and it does not just focus residential development to other Principle Towns such as Bridlington and Goole where regeneration is now essential. Driffield must be encouraged to grow economically and socially in order to attract employment sectors as well as agriculture to the area, particularly as it is still heavily reliant on more traditional activities such as agriculture.

Driffield also needs to attract younger generations who want to live and work in the area instead of moving away to obtain higher level educational and employment opportunities. Inward investment is key to the survival of the Town. Gemma CSFC/51 Support See response to CSFC/49 See officer comments to CSFC/49 Edwardson, Edwardson Associates on behalf of WM E Naylor, Gemma CSFC/53 Support The proposed "Settlement Network" defines Kilham as a Comment noted. Consultee/Agent ID Nature Of Response Officer Comments Response: Edwardson, "Primary Rural Service Centre" which will provide `appropriate Edwardson development to meet local community needs'. The Allocations Document will consider Associates on the development of individual sites. behalf of WM E The status of Kilham is strongly supported and it is essential that Naylor, this settlement provides the opportunity for sustainable housing The growth scenarios recognise the development for the future vitality of the settlement and in terms role and function of Primary and of meeting the needs of the hinterland. It is a substantial village Secondary Rural Service Centres in the with a diverse range of facilities. The services provided need to overall Settlement Network. It also be supported through the sustainable growth of the settlement. supports the overall emphasis on directing large scale development to It is acknowledged that a settlement hierarchy approach is larger higher order settlements where appropriate and that the judgement of the position of there are more services, facilities and settlements in the hierarchy will, at least in part, be based on a employment opportunities. consideration of the perceived sustainability of these settlements. Kilham is considered to be a sustainable settlement that is The availability of land (and the impact suitable to fulfil its function as a Primary Rural Service Centre for of development on the environment and this part of the District. It is capable of accommodating a infrastructure) is a factor for significant amount of additional housing development over the consideration but this needs to be course of the plan period without unacceptably detracting from balanced against other policy objectives. the character of the settlement. Therefore a guide for how much housing should be provided is required. The announcements from the coalition Government are considered to increase the necessary amount of land needed for The Strategy Document needs to future housing development as the result will almost certainly be provide the overall framework for a reduction in the density of development on the ground and a deciding how much development will lower supply of `windfall' housing associated with developing take place in different locations. Such garden areas which had been defined as brownfield land. decisions cannot be devolved to other documents such as the Allocations A key aim of attracting a skilled, professional and resident Document. population is partly dependent on being able to provide a quality housing supply. A good part of this supply needs to be in attractive village locations to attract inward investment by those wishing to set up or relocate a business where the availability of quality housing in attractive rural settlements is likely to be a key Consultee/Agent ID Nature Of Response Officer Comments Response: factor in choosing the location of their enterprise. A balanced high quality mixed housing development in an attractive location will appeal to economically active purchasers into the area.

Kilham needs to successfully focus investment to ensure existing services are supported and employment opportunities are developed and maintained to service both the settlement itself and the hinterland. In this case:

- The provision of housing development in Kilham is required to support economic activity in the Bridlington Coastal sub area and support current service provisions within the settlement.

- Kilham had good transport links to the Principle Towns of Bridlington and Driffield.

- Local planning policy should encourage a mixture of development in rural areas in order to allow economic growth, sustain the vitality of the village and allow this existing community to thrive by supporting its facilities and services such as the Primary School.

The level of housing required means there is a requirement for a number of sustainably located greenfield sites to come forward to help meet the housing needs. This site provides the opportunity for development which is not detached from the built form and will not encroach unacceptably into the countryside. It can also provide for a phased development during the plan period.

It is important that Kilham - as a well serviced settlement that has previously relied on the farming community - is encouraged to thrive economically and sustainably.

Consultee/Agent ID Nature Of Response Officer Comments Response: An appropriate level of economic growth and the provision of quality housing are essential to allow the settlement to continue to thrive. As agriculture has been in decline for some time, it is vital that the Core Strategy also focuses on future growth within the settlement and it does not just focus residential development to other Principle Towns such as Driffield.

In these circumstances, it is not considered appropriate to impose a maximum growth threshold/scenario based on a simplistic percentage of the existing size of the village - any determination of the level of growth should take into account the merits of the particular sites that are potentially available and set a higher level of growth for settlements like Kilham where sites can be developed with minimal impact on the character or amenities of the area so reducing the need to allocate as much land in more sensitive settlements or to expand the larger towns by way of damaging extensions of built form into the open countryside.

All potential sites need to be properly appraised and not dismissed out of hand at the outset owing to a pre-conceived notion of `maximum' growth irrespective of the relative merits of particular sites and settlements. Kilham is a `priority village' for the rural areas and given the settlements existing services this is strongly supported.

The revised version of the Core Strategy `Further Consultation' dated October 2011 indicates that the merits of individual sites and the settlements they may serve will not be a determining factor in deciding overall levels of growth over the plan period. It states that the figures previously outlined in the Preferred Approach Core Strategy were too high and now seeks to impose a limit on the scale of future growth without making any detailed assessment of the various sites put forward as potential housing Consultee/Agent ID Nature Of Response Officer Comments Response: land allocations.

This means that the previously suggested figures of 170 dwellings required up to 2026 has now been amended to 82 dwellings to 2028. In effect the numbers of dwellings-required has decreased significantly. The 'Further Policy Amendment' also proposes to limit development to `overall growth of 20% of the individual settlement, or an average of 10 dwellings per annum - whichever is lower'. Whilst the appropriate phasing of development is supported, the viability of development sites must also be considered in conjunction with the likely infrastructure costs and broader attributes the site and settlement it serves may have.

Taking these factors into account, it is considered appropriate to consider this site as suitable for sustainable housing growth, considering the location of the site in relation to employment, educational and health facilities and the minimal impacts associated with developing this parcel of land. Miss Miranda CSFC/68 Observations As per our answer to Question 1, the policy should not restrict Comments noted. The development Steadman, CB new development to just 'within' the development limits of the limits will be revised through the Richard Ellis on defined settlement network unless, of course, the Development Allocations Document process to behalf of Mr Clive Limits are going to be altered to accommodate appropriate sites accommodate the scale of development Kefford such as our clients which is previously developed and can deliver set out in the Strategy Document. housing. We would recommend that the Development Limits are altered in certain circumstances, like for our clients site, where it would not harm the natural or built environment to do so. Ms Nicola Salvidge, CSFC/86 Observations As with question 1, you seem to of dropped all villages down a Comment noted. Leven is identified as a Seaton PC scale to for a dis-jointed view, how for example can you put Rural Service Centre because of its Leven and Brandsburton into a separate class stucture when location between Hornsea and Beverley. both seen locally as being local service centres. It has more services and facilities than Brandesburton. The future of towns and villages depend upon all forms of development to keep them growing by labelling them as is in this Successive plans have always attempted Consultee/Agent ID Nature Of Response Officer Comments Response: consultation many will be left to disapear. to define a settlement network to ensure that the right development takes place in the right locations. The Strategy Document supports the continued vibrancy of rural areas. Pat Lambert, North CSFC/93 Object The Parish Council accepts the overall approach to development Comment noted. A pragmatic approach Ferriby Parish priorities in this revised policy. However, it considers that has been taken, recognising the rural Council adjustments are needed to the scale and distribution of nature of the East Riding and the need development to give greater emphasis to development in the to support proposals in villages which identified network rather than in the Hinterland villages, rural help sustain village life. In response to villages and the countryside (see Questions 3 and 4). The the consultation, a specific figure for allocation of such a large amount of housing development outside each Hinterland Village (now classed as the priority network (3,060) is not consistent with the stated Primary Villages) which will aid clarity to strategy intentions. It may not be achievable via the necessarily the scale of development planned for. restrictive policy approach within the Hinterland and rural villages, which we support, and could give rise to further Overall, Policy S5 promotes the pressure within villages like ours if countywide housing targets development of 2,986 dwellings in the are not being met. Rural Service Centres and Primary Villages (Around 1,700 in the former and 1,300 in the latter). Mrs Val Wood, CSFC/100 Object Yes, agree. Comment noted and support Anlaby with Anlaby welcomed. Common Parish Council Mrs P.A. Sykes, CSFC/125 Object During our recent Parish Council meeting this document was Comment noted. The Strategy Rawcliffe Parish discussed at length and I was instructed to contact you regarding Document must consider the findings Council the entire village of Rawcliffe being removed from the list. from the evidence base. The Level 1 Strategic Flood Risk Assessment (SFRA). Members were appalled at this statement and would ask in the This shows around a third of the village strongest terms that this proposal should be rescinded. within a “<6 hour warning time area”, The village’s position on the banks of Rawcliffe is a settlement just over two miles from Junction 36 of the River Aire also means it could have Consultee/Agent ID Nature Of Response Officer Comments Response: the M62 motorway and close to the junction with the M18 which a high ‘residual risk’ from potential gives access to the Ml. Rawcliffe has received development in the defence breaches. preceding few years and this development breathed life into a The Draft Strategy Document re- dying and ageing community and this development was welcomed introduces Rawcliffe as a Primary Village by all members and the greater part of the community. (formerly a Secondary Rural Service Centre) in terms of its function but Since that time a new primary school has been built to the does not promote the allocation of sites benefit of the next generation of young people and their for housing on flood risk grounds. successors. Windfall sites may be supported where they can be developed safely. Members feel that development should be allowed to continue within the Parish albeit on a much smaller scale than that of previous years.

It is accepted that the village is within a high risk flood area but members of the Parish Council together with residents of the village remember well the floods of 1947 and the threat of wholescale flooding in 2000. In 1947 part of the village was under water but in 2000, thanks to the renewed riverside defenses there was no flooding, not even on Riverside.

Members would welcome an opportunity to speak with a Planning Officer regarding this very important matter. The Parish Council does not hold a meeting in December and therefore the next meeting is on Wednesday 25th January 2012. there would always be the opportunity of holding an extra ordinary meeting if this would be more convenient. Mr J Winterbottom CSFC/129 Object The four "Principal Towns" defined could not be more The Strategy Document recognises the individually different. Goole is on the major transport network - difference between the four Principal road, rail sea and air close by. Beverley and Driffield are similarly Towns. They each have a different Place placed in relation to potential, but Beverley is hyper-promoted Statement which recognises their and given every feasible facility whereas Driffield is xxx characteristics and a different level of comparatively in most respects. development is planned for in each. The sub area policies provide more detail on Consultee/Agent ID Nature Of Response Officer Comments Response: Bridlingotn is a "dead end" - visitors can go to it but there is no the strategy taken for the different particular route through it. It is what it can only ever be, a Principal Towns. "retirement haven"/old fashioned "holiday resort" which the planning team (meant to improve the image and potential of the xxx) has totally neglected to do by treating is as a potential "manufacturing" centre. The only potential for xxx manufacturing items is "old fashioned coastal holiday" items, xxx, etc due to its total lack of connection to the national transport system. Mr J. Willingham, CSFC/150 Support Yes the policy represents the settlements Comment noted and support Bilton Parish welcomed. Council Mr R Andrew CSFC/152 Object No. Comment noted. National policy seeks to prioritise development on poorer (i) Houses should not be built on good agricultural land. quality agricultural land. The site assessment process also factors this in. (ii) Houses should be built where the jobs are The Draft Strategy Document seeks to (iii) There are and will not be job opportunities in Howden. promote housing in areas where there are employment opportunities. Many of these opportunities are located along the east-west M62 corridor, particularly in and around Goole and Howden. Mrs Judith Macklin, CSFC/168 Observations The Parish Council has always felt that Cottingham should stand Comment noted. The Draft Strategy Cottingham Parish alone as it differs quite considerably from Hessle, Anlaby, Document categorises settlements but Council Willerby and Kirkella. still recognises that a different approach may be needed for each settlement within that category. Cllr John Whittle CSFC/175 Support Yes – what’s in a name? As long as we are all sure of what we Comment noted and support are talking about. welcomed. Cllr John Whittle CSFC/176 Observations Regarding Hornsea I note that as a Local Service centre we are Comment noted. The Strategy to be a focus for many things, including health (Cottage Hospital Document seeks to support future Consultee/Agent ID Nature Of Response Officer Comments Response: beds closing down), entertainment (Floral Hall not fit for development that helps to maintain the purpose, proposed Cultural Centre still awaiting funding) and role and function of particular cultural activities (see previous). Perhaps this rosy view should settlements. be tempered by a little realism? Mrs Sara Towne, CSFC/212 Support Skirlaugh PC agrees with all of these proposals Comment noted and support Skirlaugh Parish welcomed. Council Frances Sadler, CSFC/250 Support We welcome the continued identification of Market Weighton Comment noted and support City of York and Pocklington as Local Service Centres and the new welcomed. Council identification of Stamford Bridge as a Primary Rural Service Centre in Revised Policy SS2: Locating development. Cllr Iain CSFC/267 Support Support welcomed. McKechnie, Wilberfoss Parish Council Mr John Blacker, CSFC/271 Observations We support the council's statement to include Gilberdyke as a Comment noted. The council believes Shirethorn Limited primary role service centre. these two villages can provide a role as a joint Rural Service Centre. A more Gilberdyke is a very sustainable service centre as it has all the restrained approach to development is facilities necessary due to the level of flood risk • Local shops recorded in the area. • Industrial/business park • Schools • Transport service, both rail and bus • Public houses • Petrol stations • Well linked to major centres • Churches

Gilberdyke has large business employers in the farming and horticultural sectors in this area; we do not support the council's view that Gilberdyke and Newport should be combined, as they Consultee/Agent ID Nature Of Response Officer Comments Response: are two separate centres and there is a distance of approximately 1 mile between the two, with the village of Scalby in between. They both have separate parish councils.

Gilberdyke is a larger centre and does not need to be linked to Newport.

In principle rural service centres housing numbers should be increased to 15 houses per annum, this will stabilise schools, leisure facilities and all village amenities and give a balanced community.

Gilberdyke would benefit from this increased number as it is a very sustainable location.

I hope that the council will reconsider and increase the numbers in Gilberdyke and take on board our comments.

We support the council by increasing village development limits. Mr Peter Wood, CSFC/276 Object No Comment noted. The growth scenarios Peacock and Smith recognise the role and function of Rural on behalf of G Revised policy SS2 defines the settlement network as comprising Service Centres and Primary Villages Bush the Major Haltemprice Settlements, Principal Towns, Local (formerly Primary Rural Service Service Centres, Primary Rural Service Centres and Secondary Centres, Secondary Rural Service Local Service Centres. Centres and Hinterland Villages) in the overall Settlement Network. The ‘caps’ These representations relate to the approach towards residential support the overall emphasis on development in the Primary Rural Service Centres, which include directing large scale development to Stamford Bridge. larger higher order settlements where there are more services, facilities and Revised policy SS2 sets out the forms of development which will employment opportunities. be supported in the Primary and Secondary Rural Sevice Centres in order to ensure the delivery of the overall spatial approach. The residential component for the Primary Rural Serice Centres The availability of land (and the impact Consultee/Agent ID Nature Of Response Officer Comments Response: which will be supported is that commensurate with the scale, of development on the environment and role and character of the village providing a maximum growth of infrastructure) is a factor for 20% in the size of the village (measures in terms of the size of the consideration but this needs to be existing dwelling stock) over the plan period, or 10 dwellings per balanced against other policy objectives. annum, whichever is lower.

Table 2 sets out a gross housing requirement of 25,000 dwellings over the period 2011/12 to 2027/28 (ie 17 years). Appendix a, table a notes that Stamford Bridge contains within development limits an existing stock of 1,459 dwellings.

The operation of revised policy SS2 at Stamford Bridge thus results in a requiremnt of 292 dwellings on the scale of criterion, but this reduced by over 40% to 170 dwellings by the application of the 10 DPA 'cap'.

Appendix a, Table a demonstrates, however, that while Stamford Bridge is one of the largest of the Primary Rural Service Centres (next in size only to Gilberdyke and Newport), the operation of the 10dpa'cap' results in a disproportionately higher dwelling requirment figure in a number of the smaller villages.

Middleton on the Wolds is only a quater of the size of Stamford Bridge, but has a dwelling requirement figure equivalent to over 40% of the capped total for Stamford Brdge. The same is true for Aldbrough, Beeford, Bubwith and Kilham which are between 27% and 33% of the size of Stamford Bridge but have dwelling requirements ranging from 47% to 56% of the Stamford Bridge total. This disparity is even more noticable at Hutton Cranswick where the figures are 47% and 90% respectively.

The effect of the mechanism is to distribute 43% of the overall requirement for the Primary Rural Service Centres to villages with just 35% of the existing dwelling stock (ie the measure of Consultee/Agent ID Nature Of Response Officer Comments Response: village size employed in revised policy SS2).

The aim of revised policy SS2 with regard to the Priary Rural Service Centres is clearly to relate future housing growth to the scale, role and character of each village. On the other hand, the 10dpa 'cap' imposes an arbitary limit on dwelling requirements which bears no real relationship with the aims of the policy.

It follows, therefore, that the distribution mechanism should be revised to be more closely reflect the scale, role and character of each village. It is appreciated that a view needs to be taken as to what may represent a minimum sustainable level of provision to support each village over the plan period, and that the application of a 20% growth senarion across the board would result in an over-supply compared with the currently proposed distribution, but it is clear that the operation of the 10dpa 'cap' imposes a distribution mechanism which fails to meet either of these objectives.

So far as Stamford Bridge is concerned, the representations submitted onbehalf of Mr and Mrs XXXX in Jully 2010 in relation to the Allocations DPD Potential Site Consultation (sites SMB2 and SMB3) demonstrate that Stamford Bridge has sufficient highways and environmental (based on ecological, heritage, landscape and agricultural assessments) capacity to accommodate quite significant levels of housing growth over the plan period. Mike Downes, CSFC/278 Support Omnivale support the amended approach to the Settlement Comment noted and support Antony Aspbury Network as set out in Revised Policy SS2 welcomed. Associates on behalf of Mr Adrian Sail, Strawsons Development / Omnivale Ltd Consultee/Agent ID Nature Of Response Officer Comments Response: Mr Henry Scott, CSFC/281 Support We support the development in Principal Towns, such as Goole, Comment noted and support Stephenson & Son where the town will be a centre of economic development and welcomed. on behalf of Mrs housing growth and will cater for their own needs and the Mary Huddlestone service needs of significant parts of the East Riding. The site at The Allocations Document will consider GOO2 meets the Council's soundness tests, as a site which is the development of individual sites. deliverable, viable, achievable and realistic. As highlighted in the Revised Policy SS2, they should be a key focus for services and facilities, including shopping, leisure, transport, education, health, entertainment and cultural activities. Rosemary Jordan- CSFC/288 Observations For the Primary and Secondary Rural Service Centres, limits on Comment noted. The Draft Strategy Jackson, Swanland the overall expansion of the settlement have been set for the Document has been drafted to offer Parish Council plan period as: clarity on the approach. It re-classifies Hinterland Villages and Secondary Rural - Primary Rural Service Centres 20% or 10 dwellings p.a. Service Centres as one category – whichever is lower Primary Villgaes. The policy approach for the former Secondary Rural Service - Secondary Rural Service Centres 10% or 5 dwellings p.a. Centres has been taken forward for this whichever is lower category (10% growth or 85 over plan period). This provides a guide for the No limits have been set for Hinterland Villages either for the scale of development supported over total amount of housing over the plan period or in terms of the the plan period. numbers of dwellings per annum. At the Consultation event for Parish and Town Councils on the Core Strategy, it was made clear that developments in the Hinterland Villages would be limited to sites of “usually no more than 5 dwellings” and this did not mean that 5 dwellings per annum would be allowed. The alternative definition of a total of 5 dwellings over the plan period was also rejected. What was not stated or defined was how the “usually no more than 5 dwellings” would be interpreted. In Swanland there will be considerable pressure from developers to maximise the number of dwellings allowed because of the value of the land in the village. There have already been approaches by developers and the Parish Council has had a planning application submitted on the basis that development will Consultee/Agent ID Nature Of Response Officer Comments Response: now be allowed in the village. Until Policies SS2 & SS3 are clarified it will be impossible to control the number of dwellings coming forward.

The Parish Council would want:

• a maximum limit of 2% increase in the number of dwellings in the village set over the plan period.

• a strict definition of what is meant by “usually no more than 5 dwellings” either over the whole plan period or in the 5 year time frames indicated under policy SS4. Angela Wilkinson, CSFC/300 Observations However, having reviewed the settlement hierarchy in the Comment noted. Public transport East Riding context of public transport, the proposal raises a number of accessibility is one of a number of Transport anomalies. For example, why are settlements like Wetwang (with factors considered in identifying Rural Partnership an infrequent bus service), Kilham with a thrice weekly bus Service Centres and Primary Villages service, and Middleton classed as Primary Rural Service Centres, (formerly Primary Rural Service as are Stamford Bridge and Hutton Cranswick (both of which Centres, Secondary Rural Service have excellent public transport links). Centres and Hinterland Villages). The geographical spread of villages is also an Despite good access via both bus and rail, Naffferton is accorded important factor. only Hinterland Village status; and Cherry Burton (with minimal public transport access), favoured above Bishop Burton – which The Draft Strategy Document, as far as has no primary school, but a regional college and excellent public possible, seeks to promote transport links? development which supports public transport provision. However, it is These inconsistencies are repeated across the hierarchy; further recognised that the East Riding is rural examples would include Hook as a “rural village”, despite its in nature and that many people will proximity to Goole (a principal town); and South Cave in a lower continue to use their cars. settlement category than Kilham.

It would seem that the criteria for the settlement hierarchy are in part determined by road infrastructure - but only in terms of access by car. The lack of public transport in settlements like Consultee/Agent ID Nature Of Response Officer Comments Response: Kilham, Wetwang and Middleton, dictates that potential development of up to 20% at today’s population figures would result in at least an additional 200 car journeys in these parishes. Rose Freeman, The CSFC/322 Support Thank you for your email of 31 October consulting The Theatres Comment noted and support Theatres Trust Trust on a further consultation following the preferred approach welcomed. for the Core Strategy Development Plan Document. Please note there are no plans to The Theatres Trust is The National Advisory Public Body for prepare a Development Control Policies Theatres. The Town & Country Planning (General Development document, town Area Action Plans for Procedure) Order 1995, Article 10, Para (v) requires the Trust Beverley and Bridlington or a Developer to be consulted on planning applications which include Contributions SPD. ‘development involving any land on which there is a theatre .’ It was established by The Theatres Trust Act 1976 'to promote the better protection of theatres'. This applies to all buildings that were either built as theatres or are used for theatre presentations, in current use, in other uses, or disused.

Due to the specific nature of the Trust’s remit we are concerned with the protection and promotion of theatres and therefore anticipate policies relating to cultural facilities.

Revised Policy SS2 Locating Development

We supported this policy because of its focus on entertainment and cultural facilities for the principal towns in section E and this doesn’t seem to have changed.

We have no other comment to make on other sections of the document but look forward to being consulted on the next stage, also Development Control Policies, town Area Action Plans (Beverley and Bridlington) and the Developer Contributions SPD. Mr John Taylor, CSFC/324 Object Our understanding is that the areas for possible development Comment noted. Consultee/Agent ID Nature Of Response Officer Comments Response: have been fixed by a process of methodology using undetailed surveys, projections whose parameters are undisclosed leaving us The Strategy Document is prepared wth the feeling that incorporation of certain sites in the plan are through consideration of a wide range as a result of crystal gazing and wishful thinking. We further of evidence and in response to agreed understand that the sites to be chosen for devopment will be aims and objectives. made in the summer of 2012 and, as admitted' will in part rest upon any applications for permission or notified proposed Whilst development will be prioritised appications . If this is the case it follows that commercial on brownfield land within the town, the interests perhaps offering alleged benefits to the community will scale of housing growth identified means have some sway over which areas devopments actually will take that greenfield site will be required over place. the plan period.

It is accepted that some new deveopment will take place but we Additional reference to priorising the question the suitability of any development to the use of previously developed land has north/northwest of Beverley upon the fundamental tenet been inserted into Policy S3 of the Draft expressed in your newsletter that the countryside should be Strategy Document. protected from inappropriate development. If the methodology is suggesting, as appears to be the case; The Allocations Document will consider the development of individual sites. This 1. that greenfield sites are the least recommended will be subject to consultation. 2, that there should be accessability by public transport which depends on commercial considerations by the transport providers., and 3. that there should be accessibility by walking or cycling to doctors or dental practices, shops and schools and that such places are willing or able to accommodate new families then these criteria are not met by inclusion in the scheme of the land to the north and northwest of Beverley.

This should be coupled with the detrimental effect of an increased number of vehicles in, around and through Beverley with the consequent element of road safety concerns. It is considered that initally, at the least, brownfield development sites within the existing boundaries of Beverley should be used Consultee/Agent ID Nature Of Response Officer Comments Response: to fulfill the alleged increased housing requirement which will substantially meet the above criteria. Speculative commercial developments thereon which may or may not take place especially in the current economic situation should be deferred as should speculative residential developments outwards which if allowed in repect of the north and north western proposed sites will further diminish the character of the town and by definition will attract fewer people wishing to live here. Whether such sites would be required in the future is at best doubtful as is evidenced by the number of properties in Beverley currently advertised for sale.

It is accepted that a degree of long term planning is necessary but, and it must be accepted by the same token, that there may be reasons for change, deferment or cancellation to meet changing future needs and circumstances political, social and economic.

It is further understood that there will be disseminated "consultation" i.e information as to which sites are chosen for development in 2012 and that any planning permission then sought may be subject to appropriate and specific objection. Mr Bryan Davis, CSFC/327 Support We consider that defining Elloughton/Brough as a Local Service Comment noted and support Elloughton-cum- Centre is the correct approach and should ensure that the needs welcomed. Brough Town of our community is recognised. Council John Downing, CSFC/337 Support We agree with the amended approach in defining the Settlement Comment noted and support Rollits Solicitors on Network in Table 1 and the principles which underlie it. welcomed. behalf of East Riding Securities In particular we agree the emphasis of new development into the Limited Major Haltemprice Settlements (including Anlaby) and the Principal Towns (Beverley, Goole, Bridlington, and Driffield). The role in terms of development of the Major Haltemprice Consultee/Agent ID Nature Of Response Officer Comments Response: Settlements is to contribute to the Regional City Role of Hull.

The focus of development into the Major Haltemprice Settlements means that they will need to accommodate additional releases. We have already submitted that principles in which these releases might be considered need to be established. It is not sufficient that new development will be focussed "within" these Settlements. This is both unrealistic and impractical without redeveloping the centres in ways which will threaten the very identity which the policy is designed to preserve.

There is no reason why careful releases in and around the settlement of Anlaby could not be made without imperilling in any way the separate identity of Anlaby or the valuable green spaces which separate them. Indeed the act of development is likely to increase the economic activity of the village centres of the Haltemprice Settlements and thereby give contribute to their economic well-being. Mr Roy Dennett CSFC/376 Object I would like consideration given to the development of a Comment noted. The council did not completely new settlement. A few years ago the government was take part in the Eco-towns initiative. promoting the concept of eco-towns and I would like to see East Yorkshire exploring this option. Has a feasibility study been done on this? Ms Felicity Clayton, CSFC/385 Support Yes Comment noted and support Hornsea Area welcomed. Renaissance Partnership N Rowland, Savills CSFC/391 Object We welcome the recognition that is now given in the Council’s Comment noted. The Draft Strategy revised Core Strategy policy SS3 to the fact that there are a Document offers clarity on the range of villages which lie within the hinterland of the regional approach. It re-classifies Hinterland city (Hull and the Haltemprice settlements) which have a distinct Villages and Secondary Rural Service role to play in delivering sustainable development for the future. Centres as one category – Primary Consultee/Agent ID Nature Of Response Officer Comments Response: Villgaes. The policy approach for the We also note that the Council considers that these villages have former Secondary Rural Service Centres a particular role and function and that they are able to has been taken forward for this accommodate small scale residential development and help category (10% growth or 85 over plan promote a continued focused housing distribution across East period). This provides a guide for the Riding. The recognition that Swanland is one such village is also scale of development supported over welcomed in principle on this basis. the plan period.

However, we are concerned at the rather artificial distinction the Council is seeking to draw between these villages in SS3 and other villages across East Riding and we consider the identification of this additional tier of 'Hinterland villages' has resulted in a rather confused settlement hierarchy particularly as there are two policies which effectively contain settlement hierarchy policies.

At paragraph 3.15 the Council states that the hinterland villages have a ‘particular role and function’ and that this is different to either Primary Rural Service Centres or Secondary Rural Service Centres. However, we have not seen any evidence base that the role of such villages is any different to the role of the Secondary Rural Service Centres.

In order for the Core Strategy to be found sound it needs be justified and have a credible evidence base. The Council needs to justify why this distinction needs to be made, particularly when taking Swanland as an example, this significant settlement with a population of 3,500 (some 1500 dwellings) containing a range of facilities and local employment, scores highly in terms of providing a sustainable location for future development. Indeed, it has been recognised in previous Local Plans as providing a sustainable location for development, (with the allocation of housing sites) and it lies in a key public transport corridor and has a school. It clearly performs a function as a service centre, Consultee/Agent ID Nature Of Response Officer Comments Response: independent of the regional city. Given the role that this settlement performs it should be able to accommodate housing growth in a similar way to the Secondary Rural Service Centres.

As a level of growth is clearly anticipated in the Hinterland villages these should be explained in policy SS2 to make it clear that there is either an additional tier in the settlement hierarchy ( which is explained and justified) or the Hinterland villages are combined into SS2 in one policy as one group of Secondary Rural Service Centres. In the case of Swanland we consider it to be considered as a SRSC. N Rowland, Savills CSFC/404 Object We support part A of policy SS2 which identifies that Stamford Comment noted. The growth scenarios on behalf of British Bridge has an important service centre role within the recognise the role and function of Rural Heart Foundation Settlement Network of East Riding. We also support the Service Centres and Primary Villages renaming of this settlement as a ‘Primary Rural Service Centre’ in (formerly Primary Rural Service the hierarchy in recognition that this is a priority village for this Centres, Secondary Rural Service rural area. Particularly as this area of the Vale of York contains Centres and Hinterland Villages) in the only two market towns and no principal towns. overall Settlement Network. The ‘caps’ support the overall emphasis on We also support the fact that in recognition of the role this directing large scale development to settlement is to play in meeting future housing needs, larger higher order settlements where development which would result in an overall growth of 20% of there are more services, facilities and the settlement in terms of the numbers of existing dwellings employment opportunities. would be supported. The availability of land (assessed through However, we object and do not agree with the further caveat to the SHLAA) is one factor for Part H which restricts this cap further to an average of 10 consideration but this needs to be dwellings per annum ‘or whichever is lower’. balanced against other policy objectives.

Appendix 1 sets out that Stamford Bridge has a total of 1,459 Please note that the SHLAA assesses dwellings and at 10 dwellings per annum this would supply 170 indidivual sites using a general approach, dwellings to 2028. However, the maximum 20% growth scenario but does not consider the cumulative would provide 292 dwellings for the settlement over this period impact of developing multiple sites in a or a difference between 10 dwellings or 17 dwellings per annum. settlement. Consultee/Agent ID Nature Of Response Officer Comments Response: Given that Stamford Bridge is one of the substantial PRSCs in this area and in the absence of a Principal Town and with two market towns that are some distance away (Pocklington & Market Weighton), we consider that there is a justification for the higher proportion to be accommodated in Stamford Bridge. This village can provides a focus for sustainable development in the Vale of York sub-area and accommodate future housing needs for this area.

We object to the fact that the Council is seeking to cap development at 10 dwellings per annum across all the Primary Rural Service Centres regardless of the individual settlements and their relationship with the surrounding areas that they serve or their capacity to accommodate further growth. There is no evidence base for such an approach and the plan is at risk of being found unsound without further justification.

However, more significantly applying such a general percentage approach does not appear to correlate with the SHLAA and ability of settlements to accommodate development and again the evidence to do so is not set out.

We would therefore support policy SS2 but only if it is revised in respect of the housing levels Stamford Bridge retaining the maximum level of 20% growth for the settlement but the removal of the lower threshold figure of 10 dwellings per annum which is not justfied in this sub-area. Ms Rachel Douglas, CSFC/416 Object - The Core Strategy should positively manage growth in order to Comment noted. The Strategy Gladman facilitate a step change in increased housing delivery as promoted Document does not exclude by the NPPF. appropriate development outside of the Major Haltemprice Settlements and the - Whilst the major Haltemprice Settlements and Principal Towns Principal Towns. should accommodate the majority of new development this should not prevent sustainable development coming forward in The Strategy Document needs to Consultee/Agent ID Nature Of Response Officer Comments Response: lower order settlements. provide the overall framework for deciding how much development will Reasoned Justification take place in different locations. Therefore, general figures are required. Policy SS2 defines the settlement hierarchy as follows: It also provides the framework for ensuring sufficient land is allocated. 1. The major Haltemprice Settlements – that part of East Riding comprising the Regional City – Anlaby, Cottingham, Hessle, Kirk Ella and Willerby; 2. Principal Towns – Beverley, Bridlington, Driffield and Goole; 3. Local Service Centres – Elloughton / Brough, Hedon, Honsea, Howden, Market Weighton, Pocklington and Withernsea 4. Primary Rural Service Centres – Alderbrough, Beeford, Bubwitch, Gilberdyke & Newport, Holme on Spolding Moor, Hutton Cranswick, Kilham, Leven, Middleton on the Wolds, Patrington, Snaith, Stamford Bridge and Wetwang; and 5. Secondary Rural Service Centres – Bradenburton, Easington, Eastrington, Flamborough, Keyingham, Melbourne, North Cave, Roos, Skirklaugh, South Cave and Wilberfoss.

Whilst recognising that the major Haltemprice Settlements and Principal Towns should accommodate the majority of new housing and employment development in order to continue to support services, community facilities and essential infrastructure, this must not be interpreted as an exclusion of sustainable development in lower order settlements.

The proposed change to rename Rural Services Centres to ‘Primary Rural Service Centres’ (PRSC) and Supporting Villages to ‘Secondary Rural Service Centres’ (SRSC) is supported. The renaming of the settlements clarifies which takes precedent in the settlement hierarchy. Further proposed changes to Policy SS2 relate to the scale of housing development proposed for the PRSC’s and SRCS’s. The proposed amendments to policy SS2 Consultee/Agent ID Nature Of Response Officer Comments Response: suggest:

‘Development will be supported which provides a maximum growth of:

• 20% in the size of the village (in terms of exiting dwellings) over the plan period for the Primary Rural Service Centres, or 10 dwellings per annum whichever is lower; • 10% in the size of the village (in terms of existing dwellings) over the plan period doe Secondary Rural Service Centres; or 5 dwellings per annum, whichever is lower.’

PPS 3 (’Where need and demand are high, it will be necessary to identify and explore a range of options for distributing housing including consideration of the role of growth areas, growth points, new free standing settlements, major urban extensions and the managed growth of) does not promote an arbitrary decision based approach on how land is classified suitable for development. Alternative options, such as the release of suitable sites within and adjacent to PRSC’s and SRSC’s, that are deliverable and sustainable need to be considered in order to meet housing need and create economic growth. This is particularly important when there is a less than 5 year housing supply and identified market demand. By detailing the specific quantum of development that would be permitted restricts the ability of the policy to satisfy residential need throughout the plan period. It is therefore recommended that this section of Policy SS2 is removed.

Alongside managing the location of growth the Core Strategy should positively manage the scale of growth in order to facilitate a step change in increased housing delivery as promoted by the NPPF. The Local Authority needs to allocate sufficient land to meet identified need over the plan period. A Contingency Policy Consultee/Agent ID Nature Of Response Officer Comments Response: should also be in place should delivery fall short. Our recommended Contingency Policy is detailed in the attached representation to Question 4 and should be taken forward in order to ensure a continuous supply of housing during the plan period. Ms Sarah Belton, CSFC/418 Support AGREE Comment noted and support Airmyn Parish welcomed. Council E H Smith, CSFC/429 Support The settlement of Holme on Spalding Moor has been proposed Comment noted and support Hornseys on behalf to be identified as a Primary Rural Service Centre in the East welcomed. of Miss E M Riding Local Development Framework - Core Strategy Further Southgate Consultation - October 2011 - Revised Policy SS2: Locating development. My client wishes to support this proposal as the settlement of Holme on Spalding Moor has the characteristics and location to perform the Primary Rural Service Centre role. Mrs C. Binnington, CSFC/432 Support Agree Comment noted and support Driffield Town welcomed. Council Mr C. Cromack, CSFC/439 Support Yes Comment noted and support Preston Parish welcomed. Council Ms Victoria King, CSFC/453 Object The strategy surrounding the distribution of new housing growth Comment noted. The growth scenarios Walker Morris on to the Primary Rural Service Centres ("the PRSC") has been recognise the role and function of Rural behalf of Mr Paul amended. Originally, the LPA set out a policy whereby the rate Service Centres and Primary Villages Lisseter of house building would be at 10 dwellings per year. This has (formerly Primary Rural Service been amended to supporting development "which would result in Centres, Secondary Rural Service an overall 20% growth of the individual settlement (in terms of Centres and Hinterland Villages) in the the number of existing dwellings), or an average of 10 dwellings overall Settlement Network. The ‘caps’ per annum- whichever is the lower". This approach is not support the overall emphasis on supported. By setting out a policy that uses the number of directing large scale development to existing dwellings in a settlement as its basis could lead to larger higher order settlements where Consultee/Agent ID Nature Of Response Officer Comments Response: unsustainable growth in settlements with limited services and there are more services, facilities and facilities. employment opportunities.

It is considered that new development should be apportioned to Each Rural Service Centre and Primary each PRSC based on the number of facilities and services that are Village has a basic range of services and located in a settlement and the proximity of the PRSC to existing facilities which supports the approach of settlements higher up the settlement hierarchy. There are two sustainable growth. documents in the Evidence Base that help to support our suggested approach: the Smaller Settlements Development Plan The Smaller Settlements DPD is no Document; and the Infrastructure Study. longer being progressed and the approach to managing development in Whilst the Smaller Settlements DPD is dated, it provides a smaller villages has been revised through general overview of the services and facilities in each settlement. the Draft Strategy Document. There are a number of short-comings to the DPD regarding the LPA's approach to the location of each settlement and their proximity to settlements higher up the settlement hierarchy. Nevertheless it is clear that Hutton Cranswick has a very good selection of the desired services and facilities but has been down graded due to its close proximity to Beverley and Driffield. The fact that Hutton Cranswick has a train station that provides quick access to Beverley and Driffield should be considered as a positive and sustainable attribute and not something that should be penalised.

The Infrastructure Study sets out where there are potential problems in the future with providing essential services and facilities in some of the settlements across the East Riding, Below is a summary of the findings for Hutton Cranswick:

- There are no surface water drainage problems in Hutton Cranswick that are evident in other settlements. - Yorkshire Water has confirmed that there are no problems with the increased quantum of growth across the East Riding in general. Consultee/Agent ID Nature Of Response Officer Comments Response: - There will be a need in the future to increase the capacity of the sewerage and wastewater treatment infrastructure in a number of settlements including Hutton Cranswick.

- There is a need in Hutton Cranswick for a new doctor's surgery. This could be rectified with an increase in population in Hutton Cranswick. The same situation applies to dentist provision. - There are adequate recycling facilities in Hutton Cranswick. - The A614 that links Driffield to Beverly has been assessed as being below 75% stress levels and therefore there are no issues in terms of road capacity in the lifetime of the LDF.

In terms of Hutton Cranswick, there are not considered to be any insurmountable problems in terms of infrastructure capacity and future growth in the lifetime of the plan.

We consider that Hutton Cranswick is a very sustainable settlement that should be given a higher proportion of development than is currently suggested in the Document based on its current services and facilities and the future capacity available. Mr Geoff Prince, CSFC/462 Object Whilst we agree that there is probably a case for making a Comment noted. “Local Service Geoffrey Prince distinction between Principal Towns (PTs) and Local Service Centres” have been renamed “Towns”. Associates Ltd on Centres (LSCs), we consider that it would be more appropriate behalf of Client to retitle LSCs (a planning acronym!) as ‘Market Towns’ – The Draft Strategy Document re- Unknown, settlements such as Elloughton cum Brough, Hedon, Howden, classifies Hinterland Villages and Market Weighton, Pocklington, Hornsea and Withernsea have a Secondary Rural Service Centres as one wide range of services and employment opportunities serving a category – Primary Villgaes. The policy wide catchment, have a defined town centre, and are more akin approach for the former Secondary to PTs than the next level down in the settlement hierarchy, the Rural Service Centres has been taken Rural Service Centres. To define such settlements as towns forward for this category (10% growth would give them an additional sense of importance in terms of or 85 over plan period). This provides a marketing to attract in more jobs and services, and also to guide for the scale of development Consultee/Agent ID Nature Of Response Officer Comments Response: provide a clear distinction with the RSCs, which are clearly of a supported over the plan period. lower order in terms of population and function. The growth scenarios recognise the We also consider that the RSCs and Supporting Villages (SVs) role and function of Rural Service should be merged into one category – these settlements are all Centres and Primary Villages in the fairly similar in terms of size, role and function – the Council are overall Settlement Network. The ‘caps’ trying to be too clever in trying to distinguish between them! support the overall emphasis on The new category of Hinterland Villages (HVs) should also be directing large scale development to incorporated into this category of RSCs, and also relabelled larger higher order settlements where Service Villages. Again they all have similar range of services and there are more services, facilities and population – in some cases the HVs are larger than the RSCs employment opportunities. listed in Table 1. If these HVs are only allowed to grow by 5 dwellings over the plan period, then it is clear that they will The Allocations Document is the gradually lose services – they will be unable to rejuvenate mechanism for considering the themselves and the they will develop increasingly older development of particular sites in and population age profiles. It is important that such settlements are around settlements. This provides a kept alive, and do not just become dormitory settlements for transparent and rigourous process for neighbouring PTs. local people to engage with.

Rather than determining the scale of development in such settlements (refer Annex A), the market should be allowed to determine the level of housing in these settlements within broad parameters. We propose that all RSCs, SVs and HVs should be encouraged to grow by between 10% and 20% over the plan period in terms of overall increase in the number of dwelling units based on market interest and availability of suitable sites. Why, for example, should growth in South Cave be limited to less than 10% when it is one of the most attractive places to live, close to the strategic road network and jobs along the A63/M62 corridor, and where there are already an excellent range of shops, services and also good public transport links. Similarly why limit growth in Woodmansey to just 5 houses over the plan period –the settlement is effectively a suburb of Beverley with two major employment parks (Tokenspire and Lakeside), with Consultee/Agent ID Nature Of Response Officer Comments Response: excellent public transport, walking and cycle path links to Hull and Beverley along Hull Road, and boasting a good range of local services.

Proposed Revisions to Policies SS2 Locating Development and SS3 Development in Hinterland Villages, Rural Villages and the Countryside

Policy SS2 should be amended to comprise the following settlement hierarchy:

- Haltemprice Settlements - Principal Towns - Market Towns - Service Villages (to combine Primary and Secondary RSCs and also Hinterland Villages)

The policy wording at the start of Policy SS2 should be amended so that its states:

‘The Council will support proposals for new residential development within and adjoining the settlement boundaries of the PTs, MTs and Service Villages, where it can be demonstrated that other development control policies can be met and subject to appropriate pre application public and stakeholder consultation in accordance with the requirements of the Localism Act’.

This will enable development to take place in advance of the Allocations DPD which is unlikely to be adopted for some time. The preparation of the Allocations DPD should not be allowed to constrain and stifle development in the short and medium term. Mr John Ackerley, CSFC/463 Support Generally yes, but decisions here out of our area of direct Comment noted and support Consultee/Agent ID Nature Of Response Officer Comments Response: Yapham cum concern. welcomed. Meltonby Parish council Mr Malcolm Shute, CSFC/472 Other With regard to the amended approach to the Settlement Comment noted. The growth scenarios Malcolm N Shute Network as set out in revised Policy SS2 of the consultation. We recognise the role and function of Rural on behalf of Mr & support the realignment of Eastrington as a Secondary Rural Service Centres and Primary Villages Mrs A W Kay Service Centre (SRSC) so long as it doesn't detract from the key (formerly Primary Rural Service objective of attracting new residential allocations to the Centres, Secondary Rural Service settlement. With regard to the proposals under part H of SS2 to Centres and Hinterland Villages) in the limit growth to 10% or 5 units per annum. We consider this is an overall Settlement Network. The ‘caps’ unnecessary constraint to development and subject to support the overall emphasis on appropriate allocations being made consistent with the directing large scale development to designation of the village as a SRCS the market should be allowed larger higher order settlements where greater freedom to define the rate of development. The there are more services, facilities and imposition of artificial constraints in the current economic employment opportunities. climate could affect deliverability of sites. Some formula providing a linkage to additional infrastructure/community contributions if the Part H (1) rates are exceeded could be more supportive of development and the provision of housing but providing a community benefit to such growth. Mr M Bottomley, CSFC/482 Support with We would support the broad settlement hierarchy set out under Comment noted and general support Dacres conditions revised Policy SS2 and the proposed approach to identifying the welcomed. The scale of development Commercial on Major Haltemprice Settlements, including Cottingham, at the proposed in the Rural Service Centres behalf of Redrow upper tier of the hierarchy. This reflects the spatial importance and Primary Villages (formerly Primary Homes (Yorkshire) of Hull, as Regional City, and the interconectivity of the adjoining Rural Service Centres, Secondary Rural Ltd settlements which fall both within the City and the East Riding. Service Centres and Hinterland Villages) These settlements are highly sustainable with good accessibility recognises the rural population and to public transport and the principal highways network. In line nature of the East Riding and takes into with former Policy YH4 of RSS these settlements should be a account identified need and demand. prime focus for housing and employment growth.

We support the identification of Elloughton cum Brough as a Local Service Centre. The Centres will have an important role in Consultee/Agent ID Nature Of Response Officer Comments Response: supporting the Principal Towns, particularly where constraints to further development have been identified, and in meeting housing and employment needs within the settlement and its hinterland. This is particularly relevant in respect of Elloughton cum Brough given the identified constraints on further development in Beverley as Principal Town.

We support the revised wording under Policy SS2 (F) which removes the potential overlap with the Rural Service Centres role in delivery development to meet local community needs. A greater level of constraint is required within the RSCs in order to avoid the undermining of the role of the LSCs in supporting the Principal Towns and we consider that this is appropriately reflected in the revised Policy wording.

Whilst we note that the Rural Service Centres have now been split into primary and secondary villages, the latter replacing the former reference to Supporting Villages, we would continue to express concern at the number of settlements identified within this lower tier and the potential for a considerable dispersal of development within the rural areas. Whilst the identification of a "cap" on average annual housing growth within these settlements is set out the extent of growth promoted under the Policy is extensive and culmulatively similar to that set out for the LSCs. Mr Steven Roberts, CSFC/484 Support 3.17 The current Goole campus has the potential to be suitable Comment noted and support Drivers Jonas for a range of alternative uses. welcomed. The development of specific Deloitte on behalf sites will be considered through the of Goole College 3.18 Revised Policy SS2: Locating Development - within the Allocations Document. Further Consultation paper notes that:

“Principal Towns will be centres of economic development and housing growth and will cater for their own needs and the service needs of significant parts of the East Riding. They will be a key focus for services and facilities, including shopping, leisure, Consultee/Agent ID Nature Of Response Officer Comments Response: transport, education, health, entertainment and cultural activities.”

3.19 The College Supports this statement.

3.20 A mixed use allocation on the College’s site will provide sufficient flexibility over the plan period to enable various uses to come forward.

3.21 National Policy guidance PPS4 – Planning for Sustainable Economic Growth, Policy EC2 suggests that Regional planning bodies and local planning authorities should ensure that their development plans seek to make the most efficient and effective use of land, prioritising previously developed land which is suitable for re-use and, subject to specific policy requirements, reflect the different location requirements of businesses, provide access and proximity to markets, as well as the locally available workforce.

3.22 The proposed mixed-use allocation is further supported by Policy EC10 of PPS4 which states:

“Local planning authorities should adopt a positive and constructive approach towards planning applications for economic development. Planning applications that secure sustainable economic growth should be treated favourably.”

3.23 The Principal Town designation will allow for both economic development and housing market growth, supporting the growth ambitions of the College and giving weight to its role within society. The College therefore wish to reinforce that should any part of the existing estate become surplus to requirements, the Council plan for a flexible policy allocation to ensure the site is both deliverable and developable to maximise Consultee/Agent ID Nature Of Response Officer Comments Response: the receipts for reinvestment within the College’s academic operations operation. Mrs G. Newlove, CSFC/496 Object 1 Following the previous consultation the Parish Council carried Comment noted. Hutton Cranswick Hutton Cranswick out its own survey by way of a questionnaire sent out to all does not meet the definition of a Parish Council villagers. A clear majority thought additional land beyond the Hinterland Village. It is feasible for many existing village limit is not needed and less development people to walk/cycle between Nafferton preferred than the proposed 10 dwellings per annum over the and Driffield as it is less than 5km away next 15 years. from the town centre and has a cycle path. Whilst Hutton Cranswick is close 2 Allied with these views were the erosion of the rural character to Driffield, it is beyond the walking and of the village, an outdated drainage system and an undesirable cycling journey of most people. increase in traffic flow in the village. These views have been consistently held over the length of the Borough Wide Plan for the village and seen and heard in various surveys and public meetings.

3 A case has been made in the past for Hutton Cranswick to be considered in the same context as Nafferton. Both villages are close to the proposed Principal Town of Driffield, thereby meriting a non-competing status to reduce any degree of conflict with the policy of Driffield as a centre of economic development and housing growth.

4 With Nafferton proposed as a Hinterland Village and Hutton Cranswick as a Primary Rural Service Centre this (3) would not seem to be the case.

5 In view of the historically strong local feeling in Hutton Cranswick against further expansion it would seem more appropriate for the local planning authority to accept that Hinterland Village status is the correct designation.

6 The Parish Council requests that you reassess the designation of Hutton Cranswick in your ongoing review of the Core Consultee/Agent ID Nature Of Response Officer Comments Response: Strategy. Mr Steve Young, CSFC/502 Observations Generally HOSM PC believes that future development in the Comment noted. Holme on Spalding parish should be of small 4 to 5 dwelling schemes Moor Parish Council Mr Tom Cook, ID CSFC/504 Support The purpose of this representation is to make known to the Comment noted and support Planning on behalf Local Planning Authority my client's position in respect of the welcomed. The development of specific of Ben Bailey Core Strategy further consultation document. sites will be considered through the Homes (Yorkshire) Allocations Document. Limited My clients have an interest in the settlement of Melton that is located a short distance from North Ferriby, Welton and The village of Melton has not been Brough. The location is considered to be exceptionally located assessed as performing a strategic role with easy access to Hull, Beverley and the wider area due to the in the Settlement Network. proximity of the A63.

Melton benefits from many local amenities, including the large, substantial 40 hectare (100 acre) employment site known as Melton Park. The owners of Melton Park, St Modwen are proposing the major expansion of this allocation given its exceptional location and access to major highway nodes.

For ease of reference a site location plan, with the land that is owned and thus controlled by Manor Grange (Melton) Limited is attached to this representation. It is proposed that the attached site could be developed for a number of uses that would be beneficial to the amenity of the wider area. Uses such as;

1. Residential including provision of affordable homes; Healthcare (i.e. Doctor's Surgeries or other medical); Care Facility; 2. Education; 3. Community facilities; and 4. Local conveniences.

Consultee/Agent ID Nature Of Response Officer Comments Response: The site owned by Manor Grange (Melton) Limited is identified within the extant Local Development Plan as being subject to a SSSI. Discussions have taken place with Natural England as to this designation and in particular the ability to develop the site without affecting the SSSI status.

Natural England reviewed a potential development of the site and confirmed that, their opinion, the site could be developed within the red line as indicated on the attached site location plan without causing any harm to the SSSI designation.

Core Strategy - Further Consultation Settlement Network

In 3.1 the Council acknowledge that they are listening to comments made previously in that they need to ensure that "housing and jobs are provided together". Such an approach, i.e. that new jobs are linked to the delivery of new homes within the District is wholly welcomed by my client. As stated above the attached site is located close to Melton Park, a large employment site.

There are proposals to significantly expand Melton Park in order to provide for new employment generating opportunities and thus the promotion of my clients land for the purposes of the uses outlined above is considered to be wholly complimentary to the strategic growth of this sustainable settlement and location.

The creation of sustainable settlements where housing, jobs and community facilities (such as local services) however should be a primary aim of the Core Strategy document.

It is important to acknowledge that new homes should be provided within existing settlements wherever possible. Recognition should be given in respect of the need to support Consultee/Agent ID Nature Of Response Officer Comments Response: existing locations where further development of both new residential properties and local amenities (in order to create a thriving community) would assist in ensuring that these existing communities and business locations become more sustainable.

Following on from this Council fully recognise that there is a need to manage growth in rural service centres and supporting villages whilst also managing development within the countryside.

Melton clearly has an existing resident and working population and therefore, given its linkages with the A63, is considered to be an exceptionally located settlement that can support additional development.

Elloughton come Brough is identified within the Core Strategy further consultation document as a service centre. Further development in Melton (by expanding its existing industrial estate) is also referenced. Specifically reference is made within the document as follows;

"Employment development within Elloughton and Brough will have been complemented by the further growth of the industrial estate at Melton and units suitable for small and medium businesses. Together, this development will help to provide more employment opportunities for residents close to home. Any development near the banks of the Humber will have been managed to ensure that the risk of flooding is minimised."

By therefore promoting additional development that will result in Consultee/Agent ID Nature Of Response Officer Comments Response: the creation of new employment generating uses, the Council should also be considering additional residential development within Melton in order to assist in meeting the stated aim of ensuring that "housing and jobs are provided together".

In para 4.17 the Core Strategy, Further Consultation Document further reinforces the importance of additional development in Melton;

"Elloughton/Brough is a growing Local Service Centre some 12 miles from Hull city centre. The area has strong links with the city of Hull and is within the Hull Housing Market Area. However, there is evidence of a number of people commuting outside of East Yorkshire for work. It benefits from good access to the road network, and the development of nearby Melton should help encourage shorter journeys to work. Significant investment in electricity distribution capacity may be required to facilitate further growth at Melton and Brough. Elloughton and Brough have experienced significant development in recent years and this is set to continue in the short- to medium-term as existing sites continue to be built out. This will need to be complemented by the provision of new and enhanced services and facilities to meet the needs of the growing population, which could include investing in additional school capacity to serve rising pupil numbers."

The location is considered therefore to be exceptionally sustainable and an attractive place for people to both work and reside.

This point is reinforced by the presence of South Hunsley School and Sixth Form College which is a major educational establishment within the district. The school has over 2000 pupils and draws children and young adults from far and wide. Consultee/Agent ID Nature Of Response Officer Comments Response:

It is therefore considered reasonable to consider that the settlement can accommodate further development of both employment opportunities, expansion to the school and new residential properties. Mr Tom Cook, ID CSFC/510 Support See response to CSFC/504 See officer comments to CSFC/504 Planning on behalf of Manor Grange (Melton) Limited Mr David CSFC/511 Support with The ERoYRP generally supports the approach to the Settlement Comments noted and support Farnsworth, East conditions Network as set out in Revised Policy SS2 with the caveat that welcomed. Riding of Yorkshire some settlements will present legitimate "exceptions to the rule". Rural Partnership The ERoYRP recognises the enormity of the task facing planners, developers, businesses and communities in delivering the imaginative and innovative development that will be required to deliver a truly sustainable Settlement Network (both where development is allowed and other areas where it will become more restricted). Lyndsey Fielding, CSFC/529 Support with Generally YES but about South Cave specifically NO Comment noted. South Cave Parish conditions Council Lyndsey Fielding, CSFC/532 Observations 2) There appears no explanation as to the change of name from Comment noted. South Cave Parish Supporting Village to SRSC but this is minor Council R J Kingdom, South CSFC/539 Object Generally YES but about South Cave specifically NO Comment noted. Cave Active Residents Lyndsey Fielding, CSFC/543 Object 12) As in your alternative approach Option A where you state Comment noted. The preliminary South Cave Parish that it is not clear what need the proposed urban extensions findings from the Strategic Housing Consultee/Agent ID Nature Of Response Officer Comments Response: Council would seek to meet, it is not clear what need 85 dwellings in Market Assessment/Housing Needs South Cave would meet, other than attract commuting families, Survey shows a relatively high level of reliant on the private car, this is contrary to extant policy and housing requirement in South Cave. the policy objectives of the core strategy. The South Cave Parish Council suvery in 2010 recorded 21.5% of households (extrapolated to 356 households) having difficulty finding an affordable home locally in the last 5 years – 97% of which were seeking owner-occupied tenure. Lyndsey Fielding, CSFC/544 Object 13) It would be unsound for ERYC to continue the failed local Comment noted. The Draft Strategy South Cave Parish plan policies of dispersed settlement using 30 year old allocations Document introduces a more focussed Council by including South Cave as a SRSC, which is neither remote nor approach than historic delivery and serves any rural catchments area. previous plans. Lyndsey Fielding, CSFC/545 Object 14) Due to the proximity of Elloughton / Brough which is a Local Comments noted. It is agreed that South Cave Parish Service Centre, if South Cave requires any definition, then it may South Cave should be considered as a Council be better to consider South Cave as a "Hinterland village" Hinterland Village (now known as although this newly introduced Category is by no means Primary Village) due to its proximity to satisfactory nor the village's inclusion in that category clear cut. Elloughton cum Brough. Lyndsey Fielding, CSFC/546 Object 15) What is clear cut is that South Cave is not remote, does not Comments noted. It is agreed that South Cave Parish serve any catchment area, is heavily populated by a commuting South Cave should be considered as a Council workforce with over reliance on the private car, which Hinterland Village (now known as commutes one the longest distances of any village in the East Primary Village) due to its proximity to Riding and significant house building will only serve to increase Elloughton cum Brough. the dormitory nature of the village contrary to national and local Policy. The proximity to Elloughton / Brough means the village cannot fulfil a role of Secondary Rural Service Centre in any respect. R J Kingdom, South CSFC/557 Observations 2) There appears no explanation as to the change of name from Comment noted. Cave Active Supporting Village to SRSC but this is minor Residents R J Kingdom, South CSFC/570 Object 12) As in your alternative approach Option A where you state Comment noted. The preliminary Consultee/Agent ID Nature Of Response Officer Comments Response: Cave Active that it is not clear what need the proposed urban extensions findings from the Strategic Housing Residents would seek to meet, it is not clear what need 85 dwellings in Market Assessment/Housing Needs South Cave would meet, other than attract commuting families, Survey shows a relatively high level of reliant on the private car, this is contrary to extant policy and housing requirement in South Cave. the policy objectives of the core strategy. The South Cave Parish Council suvery in 2010 recorded 21.5% of households (extrapolated to 356 households) having difficulty finding an affordable home locally in the last 5 years – 97% of which were seeking owner-occupied tenure. Ms Rachael Martin, CSFC/571 Support My client supports the amended approach in relation to the Comments noted and support Colliers Local Service Centres and Primary and Secondary Rural Service welcomed. International on Centres. behalf of Mr Peter Garrett, KeyLand Developments R J Kingdom, South CSFC/572 Object 13) It would be unsound for ERYC to continue the failed local Comment noted. The Draft Strategy Cave Active plan policies of dispersed settlement using 30 year old allocations Document introduces a more focussed Residents by including South Cave as a SRSC, which is neither remote nor approach than historic delivery and serves any rural catchments area. previous plans. R J Kingdom, South CSFC/573 Object 14) Due to the proximity of Elloughton / Brough which is a Local Comments noted. It is agreed that Cave Active Service Centre, if South Cave requires any definition, then it may South Cave should be considered as a Residents be better to consider South Cave as a "Hinterland village" Hinterland Village (now known as although this newly introduced Category is by no means Primary Village) due to its proximity to satisfactory nor the village's inclusion in that category clear cut. Elloughton cum Brough. E H Smith, CSFC/588 Support Mr & Mrs Jibson own land at Market Weighton forming part of Comments noted and support Hornseys on behalf potential Site Ref MW8 (west of A1079) as identified in the East welcomed. of Mr and Mrs Riding Local Development Framework – Allocations Jibson Development Plan Document – Potential Sites Consultation – May 2010.

On behalf of my clients I wish to make the following comments: Consultee/Agent ID Nature Of Response Officer Comments Response:

The town of Market Weighton has been proposed to be identified as a Local Service Centre in the East Riding Local Development Framework – Core Strategy Further Consultation – October 2011 – Revised Policy SS2: Locating development. My clients wish to support this proposal as the town of Market Weighton has the characteristics and location to perform the Local Service Centre role. Ms Laura Mepham, CSFC/589 Support We agree with the tiered approach to development with the Comments noted and support John R Paley Haltemprice settlements being the main focus of growth for the welcomed. Associates on East Riding. behalf of Ms Jayne Hudson, Hull and East Yorkshire Hospitals NHS Trust R J Kingdom, South CSFC/603 Object 15) What is clear cut is that South Cave is not remote, does not Comments noted. It is agreed that Cave Active serve any catchment area, is heavily populated by a commuting South Cave should be considered as a Residents workforce with over reliance on the private car, which Hinterland Village (now known as commutes one the longest distances of any village in the East Primary Village) due to its proximity to Riding and significant house building will only serve to increase Elloughton cum Brough. the dormitory nature of the village contrary to national and local Policy. The proximity to Elloughton / Brough means the village cannot fulfil a role of Secondary Rural Service Centre in any respect. E H Smith, CSFC/636 Support The town of Pocklington has been proposed to be identified as a Comments noted and support Hornseys on behalf Local Service Centre in the East Riding Local Development welcomed. of Mr R C Bird Framework – Core Strategy Further Consultation – October 2011 – Revised Policy SS2: Locating development. My client wishes to support this proposal as the town of Pocklington has the characteristics and location to perform the Local Service Centre role. Consultee/Agent ID Nature Of Response Officer Comments Response: Mr Garth Hanlon, CSFC/638 Support Within revised policy SS2, St John’s College Cambridge support Comments noted and support Savills on behalf of the continued identification of Goole as a Principal Town. welcomed. St John's College, Alongside the major Haltemprice settlements, the Principal Cambridge Towns will be the focus of growth within the East Riding. Such locations will be centres for economic development and housing and will cater for their own needs and the service needs for significant parts of the East Riding. It will be a key focus for services and facilities, including shopping, leisure, transport, education, health, entertainment and cultural activities. As a major landowner on the western side of the town adjacent to Capitol Park, St John’s College has a strategic land holding capable of being brought forward within the plan period to contribute to the continued expansion within the employment sector to assist in fulfilling key objectives of the Core Strategy Document.

The amended approach within Policy SS2 still retains the overall approach for focussing growth in the Main Haltemprice Settlements and the Principal Towns within East Riding. Goole will play a major role in this context. Ms Annie Smith, CSFC/643 Support Yes Comments noted and support Kilham Parish welcomed. Council Mr David Hickling, CSFC/653 Support with We agree that the settlement network in SS2 represents a sound Comments noted and support Hickling Gray conditions general approach but maintain the view that Newbald (South and welcomed. Newbald does not fulfil the Associates North) should be designated as a Secondary Rural Service criteria of a Rural Service Centre or Centre as it appears to fulfill the requirements for such Primary Village (formerly Primary Rural designations and is located mid-way between South / North Cave Service Centres, Secondary Rural and Market Weighton with good public transport and Service Centres and Hinterland employment provision. Villages). Mr Philip Parker, CSFC/660 Object Further to our recent meeting at County Hall , and my letter Comments noted. The development of Philip Parker dated 14/7/2011, I wish to respond to the Local Development specific site will be considered through Consultee/Agent ID Nature Of Response Officer Comments Response: Planning Services Framework Core Strategy Consultation October 2011 the Allocations Document. on behalf of Client document in the context of the residential allocation proposal Unknown for the KIL 10[part] site at East End Kilham. The growth scenarios recognise the role and function of Rural Service In general terms , I consider the general approach taken in this Centres and Primary Villages (formerly latest version of the Core Strategy deserves support in that it Primary Rural Service Centres, provides another opportunity for consultation , and because the Secondary Rural Service Centres and general thrust of the document proposes to increase the amount Hinterland Villages) in the overall of new housing in the East Riding . This approach is welcomed at Settlement Network. The ‘caps’ and this time of economic downturn . proportional approach support the overall emphasis on directing large scale Furthermore , the suggested review of policies relating to the development to larger higher order provision of affordable housing and recreational facilities is noted settlements where there are more , but I would comment that any requirement for such planning services, facilities and employment gain should be set at a level which also recognises the need to opportunities. achieve high standards of housing design , especially in conservation areas , and planning gain must not compromise or The scale of development proposed for undermine other equally important planning objectives . Kilham is commensurate with the historic delivery rate. With particular regard to Kilham , I can sympathise with the view that the previous level of housing growth suggested in the 2010 Preferred Approach Core Strategy , namely 170 new dwellings up until 2026 , was too high , representing a 40% increase in the size of the village . Some local opinion shared this view , and indeed my earlier letter argued that several of the submitted sites were too large, and unsuitable for Kilham . However , it appears to me that the Local Planning Authority has over - reacted with its much lower revised housing growth figure , where , without any detailed explanation , the latest version of the Core Strategy now seeks to limit housing growth in the village to only 82 new houses until 2028! The current document only states in very general terms that the level and distribution of new housing has been revised downwards [in Kilham] as part of a County - wide review . Whilst it is considered to be reasonable Consultee/Agent ID Nature Of Response Officer Comments Response: to state , as in Revised Policy SS2 , that new housing development in Primary Rural Service Centres [such as Kilham] should be "commensurate with the scale , role and character of the village" , this needs to be applied so as to balance local circumstances and opportunities on the ground for sustainable rural development . It should not be used as a blunt instrument that says for example 20% maximum housing growth and no more ie. a degree of flexibility is required.

The current Core Strategy now proposes a very significant reduction in new housing numbers for Kilham of over 50% since 2010 , leaving a requirement of only 82 new houses over the next 17 years . Indeed , it is not entirely clear if this figure is actually only 71 new dwellings as of now . I would request that the Local Planning Authority confirms the actual proposed figure , and articulates in detail on what basis and what new evidence this reduced level of housing growth for the village is based . Any such reduction should only be based on material planning considerations which are specific to the settlement , and should not be a response to unsubstantiated local objection , or be a result of any attempt by the Council to impose a standardised grouping of various larger villages across the East Riding , without having sufficient regard to local conditions or circumstances , or the potential for sustainable small - scale housing growth

I believe the proposed housing provision is too low for Kilham , a larger village which even in the terms of the Core Strategy , is a Primary Rural Service Centre . A village like Kilham needs the injection of new housing in order to sustain and ensure the continuation of local services and facilities . The very modest level of new housing growth now proposed will undermine the role of the village , and constrain the future economic viability and vitality of both the settlement and its rural hinterland .

Consultee/Agent ID Nature Of Response Officer Comments Response: It is therefore requested that the target figure for new dwellings in Kilham should be increased . A level of housing growth of between 100 - 120 dwellings would be a reasonable and realistic figure that would help to underpin the role of the village as a Primary Rural Service Centre . The size and status of the village [ population 1010 at the 2001 Census ] as one of the larger villages in the East Riding , and its relatively isolated location within a rural hinterland , has endorsed its current designation in the Core Strategy and this should be reflected in a higher level of proposed new housing .

Thus Kilham is now recognised as one of the "small - scale service hubs for rural areas" [October 2011 document] . Yet now it appears that the lower housing provision [which is half the 2010 level] is partly based on a generalised classification process that seeks to limit housing growth in Primary Rural Service Centres below 20% of the existing settlement size . This does not appear to take account of the level of services existing in the village , which includes several shops , a petrol filling station , two public houses with restaurants , a post office , school , and local bus services . Nor does it seem to recognise that Kilham is a large linear village that has the physical capacity to accept new development .

Whilst an increase of say 100 - 120 new dwellings would equate to an increase of something like 25 - 30% , over a 17 year period to 2028 , this would only average around six or seven dwellings per year . I consider such a modest level of housing growth would not adversely affect the character or appearance of the village , but would help to sustain local services .

However , whether or not the Local Planning Authority resolves to provide a lower level of housing growth in Kilham , it is considered the KIL10[part] site still deserves the support of the Consultee/Agent ID Nature Of Response Officer Comments Response: Council on the basis of the planning merits of the site highlighted in my letter dated 14/7/2011 , and when compared to the other residential allocation bids in the village . This site has the potential to provide approximately 12 dwellings , and although it is a Greenfield site , it is compact , self - contained , and in terms of the character and appearance of the village , has a close proximity to and relationship with the existing built - up area of the village , and the Kilham

Conservation Area in particular . The KIL I0 site as now amended , some 0.5 ha in size , stands out as an appropriate sustainable location for new housing , where a bespoke design can enhance this part of the village .

By contrast , of the other residential land bid sites in Kilham , several are much larger sites , outside the urban grain of the village , and in some cases project into open countryside . These larger sites in particular are likely to lead to suburban - estate design solutions out of keeping with the surrounding area , and more remote from the village centre .

In conclusion , I consider that the Council should reinstate a higher level of new housing growth for Kilham than the 82 dwellings now proposed . Through the Core Strategy , the Local Planning Authority recognises that new housing is needed to sustain local services in villages like Kilham , consistent with its designation as a Primary Rural Service Centre , yet no specific justification has been given to reduce the level to half that in the 2010 Core Strategy. Kilham is a large village with a relatively large rural hinterland in which a higher level of new housing can be reasonably accommodated over the next 17 years .

Notwithstanding the above , I consider that the planning merits and sustainable planning credentials of the KIL 10 site [as Consultee/Agent ID Nature Of Response Officer Comments Response: amended] make it a sound location for approximately 12 dwellings , and should be allocated accordingly in the emerging Local Development Framework . This would create a high quality small - scale housing development enhancing the Kilham Conservation Area . Ms Jenny Waddell, CSFC/662 Support We strongly agree that most economic and housing growth Comments noted and support George F White on should be located in Principal Towns and welcome the inclusion welcomed. behalf of Mrs S of Goole as a Principal Town. Goole’s existing transport network Backhouse and proximity to major transport links is critical to its ongoing expansion and role as a main focus for development.

Goole contains adequate facilities to support housing growth. Further economic growth will also facilitate and encourage housing growth within the town. Ms Jenny Waddell, CSFC/668 Object Whilst we agree with the designation of Bubwith as a Primary Comment noted. The growth scenarios George F White on Rural Service Centre, we disagree with the level of growth recognise the role and function of Rural behalf of Mrs M allocated to it over the Plan period. Service Centres and Primary Villages Peach (formerly Primary Rural Service The 20% alllocation over the plan period or 10 dwellings per Centres, Secondary Rural Service annum (whichever is the lower) does not take into account the Centres and Hinterland Villages) in the individuality of the settlements or the differing demand between overall Settlement Network. The ‘caps’ the settlements designated as Primary Rural Service Centres. and proportional approach support the overall emphasis on directing large scale This broad brush approach is unlikely to be found sound, development to larger higher order particularly as it doesn’t seem to be based on any particular settlements where there are more evidence. services, facilities and employment opportunities. Bubwith in particular can support more development over the Plan period than the allocation 20% or 10 dwellings per annum The availability of land is one factor for without it being to the detriment of the village. Indeed, additional consideration but this needs to be housing development is essential in order for Bubwith to be able balanced against other policy objectives. to fulfil its role as a Primary Rural Service Centre and able to provide the required support to Market Weighton, Pocklington Consultee/Agent ID Nature Of Response Officer Comments Response: and the surrounding area.

The attached plan shows an area of Bubwith which is readily available, achievable and suitable for development. The site represents a logical and modest expansion to the south of the village which at 1.56ha could support approximately 46 dwellings based on a provision of 30 dwellings per hectare. The site is currently used as a haulage yard and benefits from access to Highfield Road. Residential development lies along Highfield Road to both sides of the site. Given the residential uses to either side of the site, the haulage yard is unsuitably located and use for residential dwellings would be more appropriate and fitting within the area.

Although the entire field is available for development, the area edged in red (and detailed on plan ref PEA 01) is the most appropriate area given the existing layout and form of development in the vicinity.

The site has ready access to facilities with water and waste services running along the road to the north. The site also abuts the road and consequently access to any development would be easily achievable. Three phase electricity is available at the site. Ms Jenny Waddell, CSFC/673 Object Whilst we agree with the designation of Kilham as a Primary Comment noted. The growth scenarios George F White on Rural Service Centre, we disagree with the level of growth recognise the role and function of Rural behalf of Mr P allocated to it over the Plan period. Service Centres and Primary Villages Middlewood Esq (formerly Primary Rural Service The 20% allocation over the plan period or 10 dwellings per Centres, Secondary Rural Service annum (whichever is the lower) does not take into account the Centres and Hinterland Villages) in the individuality of the settlements or the differing demand between overall Settlement Network. The ‘caps’ the settlements designated as Primary Rural Service Centres. and proportional approach support the overall emphasis on directing large scale This broad brush approach is unlikely to be found sound, development to larger higher order particularly as it doesn’t seem to be based on any particular settlements where there are more Consultee/Agent ID Nature Of Response Officer Comments Response: evidence. services, facilities and employment opportunities. Kilham in particular can support more development over the Plan period than the allocation 20% or 10 dwellings per annum The availability of land is one factor for without it being to the detriment of the village. Indeed, additional consideration but this needs to be housing development is essential in order for Kilham to be able balanced against other policy objectives. to fulfil its role as a Primary Rural Service Centre and able to provide the required support to Driffield and the surrounding area.

The attached plan shows an area of Kilham which is readily available, achievable and suitable for development. The site represents a logical and modest expansion to the south of the village which at 1ha could support approximately 30 dwellings based on a provision of 30 dwellings per hectare. The site lies to the south of South Side with Southside Farm lying to the west and a row of houses abutting Mill Lane lying to the east.

Although the entire field is available for development, the area edged in red (see plan ref MID 01) is the most appropriate area given the existing layout and form of development in the vicinity. The field benefits from an existing farm access which could be easily upgraded to serve residential properties.

The site has ready access to facilities with water and waste services running along the road to the north. Three phase electricity crosses the site. Mr Mark Jones, CSFC/685 Object No, we object to the approach of the Settlement Network as set Comments noted. The development Barton Willmore out in Revised Policy SS2. limits will be revised through the on behalf of Mr Allocations Document process to Paul Butler, Barratt First, we object to part A of Revised Policy SS2 given that it only accommodate the scale of development and David Wilson supports development within the development limits of those set out in the Strategy Document. Homes settlements listed within the defined settlement network. The Council has acknowledged in the Core Strategy that The policy has been amended to refer Consultee/Agent ID Nature Of Response Officer Comments Response: development will be required in and around the higher end to the Major Haltemprice Settlements, settlements in East Riding. The policy therefore needs to reflect Principal Towns and Towns (formerly this. Local Service Centres) as the main focus for growth in the East Riding. Secondly, we object to part B of Revised Policy SS2. In terms of focussing growth in East Riding, this part of the policy groups Major Haltemprice Settlements and Principal Towns together stating that these will be the main focus for growth. It then groups Local Service Centres and Primary and Secondary Rural Service Centres and says that these will provide for more limited growth. We object to the inclusion of Local Service Centres within the latter and consider that it would be more appropriate to group the third tier of the settlement hierarchy with the top two.

We also note that throughout the Core Strategy the top three tiers (Major Haltemprice Settlements, Principal Towns and Local Service Centres) are often grouped together and considered within the same context, although we accept that within this there is a priority for growth towards the top tier cascading down.

Recommended changes

Thus, we request that part c of the policy is altered as follows:

“B. The Major Haltemprice Settlements, and Principal Towns and Local Service Centres will be the main focus of growth in the East Riding. The [Delete] Local Service Centre and [Delete] Primary and Secondary Rural Service Centres will provide for more limited development to sustain and meet the needs of rural areas.”

In light of our comments to part a of the policy, in that Revised Consultee/Agent ID Nature Of Response Officer Comments Response: Policy SS2 fails to support development adjacent to the development limits of the main settlements in East Riding, we consider that part c should be amended as set out below:

“C. Development and regeneration activity in and adjacent to the Major Haltemprice Settlements, the Principal Towns and the Local Service Centres should support and enhance the service function of the settlement, and will be appropriate to its size and character.“ Mr Mark Jones, CSFC/692 Support Revised Policy SS2: Locating Development: Parts A.2, B and F - Comments noted and support Barton Willmore Support welcomed. on behalf of Mr Andrew Byrne, Linden supports the reference in parts a, b and f) to Beverley Linden Homes being designated as a Principal Town. Our client also supports the reference at b) identifying that Principal Towns will be the main focus of growth in the East Riding, whilst part f) recognises that they will be centre of economic development and housing growth. This approach is entirely consistent with PPS3, which states at paragraph 10, fourth bullet point that the planning system should deliver housing developments in suitable locations, which offer a good range of community facilities and with good access to jobs, key services and infrastructure.

Linden also notes that paragraph 111 of the Draft NPPF seeks to deliver a wide choice of quality homes by identifying the size, type, tenure and range of housing that is required in particular locations, reflecting local demand.

Linden supports reference in paragraph 4.32 of the Local Housing Study, which states that there is evidence to suggest developers will focus on strong high demand markets where there is confidence that the investment made is at a lesser risk than in more fragile or un-tested market areas. Our client believes that Beverley to be in an area of high demand, and Consultee/Agent ID Nature Of Response Officer Comments Response: focusing on settlements such as this will assist the East Riding to work towards returning to past levels of delivery.

Therefore in this regard, these parts of proposed policy SS2 is in accordance with national guidance. Mr Mark Jones, CSFC/693 Object Revised Policy SS2: Locating Development: Part A.2 - Objection Comments noted. The development Barton Willmore limits will be revised through the on behalf of Mr Linden believe that part a) as currently worded does not provide Allocations Document process to Andrew Byrne, the appropriate flexible planning framework to allow growth accommodate the scale of development Linden Homes beyond the defined development limits for Beverley. It is clear set out in the Strategy Document. that given the planned scale of growth, development outside the existing settlement boundary, including greenfield urban extensions in suitable locations, are needed.

Recommended changes

Linden therefore believes that part a should be reworded as follows:

A. New development will be focused within and where necessary through extensions, including urban extensions, to the development limits of the defined settlement network which consists of:

2. Principal Towns – Beverley Mr Nicholas CSFC/711 Observations Barmby Moor Comments noted. Spencer, Barmby Moor Parish Noted: Council (1) That sites will not be specifically allocated for residential development unless the local community - via P.C - wish to promote development of a specific site.

Consultee/Agent ID Nature Of Response Officer Comments Response: (2) BM will retain separate identity to that of Pocklington. Mr Michael CSFC/720 Support Yes. The amendment certainly seems more flexible, which is Comments noted and support Turnbull, Skeffling good as the smaller settlements need supporting and welcomed. Parish Council regenerating. Mr Michael Glover, CSFC/727 Support with The Great Gutter Lane Collaboration supports revised Policy Comments noted and support Michael Glover LLP conditions SS2 with its focus for new development on a defined settlement welcomed. on behalf of Great network. There is though scope to make the policy approach Gutter Lane clearer in parts E-I of the policy to make the relative focus of Development in and around the Major Collaboration, growth in the network clearer. The Major Haltemprice Haltemprice Settlements must be Great Gutter Lane Settlements should be the main strategic focus for development considered in light of: supporting the Collaboration in the East Riding whilst the Principal Towns should fulfil a more role of the city of Hull (in terms of local focus reflecting their roles as service centres. regeneration and investment priorities within the city); the environmental and There is a compelling sustainability basis for a more urban infrastructure capacity of the area; and concentrated pattern of development. It will serve to support the objective of avoiding settlement urban renaissance; deliver a more compact and transport- coalescence. orientated pattern of development ; make the best use of existing infrastructure; promote the use of public transport; get a better relationship between homes and current and future jobs; maximise accessibility to services and facilities; reduce greenhouse gas emission; and address climate change.

Recommended Change

The policy approach could be further improved by recognising that the Major Haltemprice Settlements should be “the [bold] prime [bold] focus for development” under part D of revised Policy SS2.

Justification: This will make the approach to guiding the location of development clearer by ensuring that the focus and distribution of development reflects that the Major Haltemprice Settlements are the most sustainable locations for future Consultee/Agent ID Nature Of Response Officer Comments Response: development in the East Riding of Yorkshire and form part of the overall Regional City. Mrs G. Newlove, CSFC/733 Object [copy of response to Core Strategy Preferred Approach and Comments noted. The development of Hutton Cranswick Allocations DPD - Potential Sites consultation submitted] specific sites will be considered through Parish Council the Allocations Document. The Parish Council request that the comments made below taken into consideration when the consultation’s responses are taken into consideration.

After carrying out its own survey by way of a questionnaire sent out to all villagers the parish council wish to make the following representations as regards the ERYC’s LDF – Potential Sites Allocation Plan Document Consultation of 2010.

• The majority view is that respondents would prefer less development than the proposed 10 dwellings per annum over the next 15 years.

• The potential sites as shown on the allocation plan are excessive for the village’s housing needs.

• Excessive development would erode the rural character of the village, encouraging urbanisation

• The current outdated drainage system (foul and surface water) is inadequate for an increase in development.

• The already busy highway system within the village cannot cope with additional traffic flow, especially the area surrounding Main Street the main thoroughfare through the village.

• The parish council’s survey showed that there are no other sites particularly recommended for inclusion other than (4 respondents) that of DC/10/00846/OUT/EASTNN (Outline – Consultee/Agent ID Nature Of Response Officer Comments Response: Residential development (Access to be considered) at land to the south of Ivy House, 14 Station Road, Cranswick), which the parish council approved earlier this year on the understanding that the services (ie, drainage and sewage system) are brought up to date before the ERYC consider approving the application. Mr Andy Booth, CSFC/736 Support with The amended Settlement Network approach is generally Comments noted and support Globe Consultants conditions supported. welcomed. on behalf of Mr R Beal, Beal However, with reference to Primary and Secondary Rural The approach taken for Rural Service Developments Ltd Service Centres, it is considered that a more sophisticated and Centres and Primary Villages (formerly bespoke growth strategy for each settlement should be Primary Rural Service Centres, considered. Secondary Rural Service Centres and Hinterland Villages) places them in This should be as response to the size, form, function and role context for the overall Settlement for each settlement with an objective for ensuring that the Network. The ‘caps’ and proportional sustainable credentials for each settlement are best supported approach support the overall emphasis and enhanced. on directing large scale development to larger higher order settlements where For example, North Cave occupies a strategic position close to there are more services, facilities and employment areas and the M62. Additional residential employment opportunities. development here together with associated investment (possibly funded through additional development) in infrastructure and The proportion of people using the car community improvements (eg traffic calming/management to travel to work is broadly the same measures and sports facilities) would enahnce the sustainable for North Cave and South Cave. In qualities of the village and further support existing facilities and addition, the proportion of people services. travelling less than 20km for work is higher in South Cave than for North Additional similar levels of development in South Cave which has Cave. seen significant levels of growth in recent years may simply lead to additional commuting. The essential benefits for existing services or potential delivery of enhanced sustainable credentials would require a far greater level of development , perhaps to the detriment of village form and character.

Consultee/Agent ID Nature Of Response Officer Comments Response: In essence a bespoke level of growth is advocated for each settlement within the broader Rural Service Centres cartegory. Mr John Blacker, CSFC/743 Observations Introduction Comments noted. The development of Howdenshire specific sites will be considered through Limited on behalf 1.1 These representations are on behalf of Humber Growers the Allocations Document. of Humber Limited in response to consultation on the East Riding Local Growers Limited Development Framework in order to assist the council in allocating sites for housing development. The site we refer to is situated at Common Lane, Welton in the parish of Welton. This site is owned by Humber Growers, R M Sayer and Poolbank and extends in total to approximately 23 acres.

1.2 A location plan of the site is attached at appendix 1. The business operated by the landowners is a fresh produce business which has recently moved its offices, packing and distribution facilities to a new site at Ellerker.

The buildings off Common Lane, Welton are now empty and not in use although some of the existing greenhouses are still operational for growing of fresh produce. These greenhouses are old and inefficient and ideally need replacing.

Statement

2.1 In it’s Local Framework the council have identified some principle towns such as Beverley, Driffield, Goole and Bridlington.

Brough and Elloughton and Welton together have been identified as a service centre and as such can accommodate more housing. The council currently has an application for the construction of 800 houses south of the railway line pending. This would require a significant amount of infrastructure work before any development could take place and it is unlikely that any housing Consultee/Agent ID Nature Of Response Officer Comments Response: will be constructed before 2014.

A new bridge would be required over the inter city railway line. This would require the approval of the Strategic Rail Authority who will no doubt seek recompense and, because the link is an inter city line the bridge would need a higher standard of construction than normal – it will therefore be more costly.

Site

3.1 We put forward the Humber Grower / R M Sayer/ Poolbank site for housing development. This site, ideally situated to the east of the main settlement, would be available for immediate development without the inherent problems of the larger site to the south of the railway. It offers the following benefits

3.2

• It is not in a flood zone. • There is no ground contamination. • It enjoys excellent access to primary and secondary schools. • All mains services are easily connectible. • The landscape value is very low on what is in effect a poor quality brown field site, with extensive concrete and greenhouse areas. • This site has no quality trees or hedge rows. • Importantly, its development would not increase traffic going into the centres of Brough and Elloughton, areas which already see significant congestion at peak work and school hours.

Transport

4.1 The railway station at Brough links with inter-cities and is approximately 2kms from this site, it also has adequate car Consultee/Agent ID Nature Of Response Officer Comments Response: parking.

4.2 East Yorkshire Motors offer a bus service that runs round Elloughton and Brough, linking the railway station, bus station at Elloughton and supermarket.

4.3 Transport access to the A63 is within 100m of the site, linking with the M62 to the west and Hull to the east.

Conclusion

5.1 We recognise that the council must seek to facilitate new development and regeneration in order to achieve the vision and objectives set out in the Core Strategy. The site south of the railway line is many years away from deliverability due to the massive amount of infrastructure to be provided, e.g. bridge over the railway line, roundabouts, all main services, etc, not withstanding that this is in a flood area on low lying ground.

The Humber Growers site would give people the choice of sites and not be restricted to housing development south of the railway line.

The Humber Growers site at Common Lane offers immediate deliverability as we pointed out previously that it has all the infrastructure available, plus transport links.

5.2 This proposed site off Common Lane is partly brown field and is not affected by any flood zone according to the Environment Agency and has a level of 19ms above ordnance datum. Sequentially this is an excellent site for housing development and the council could promote both this site and the one south of the railway in their local development framework plan, giving greater choice to the general public and Consultee/Agent ID Nature Of Response Officer Comments Response: house builders.

5.3 The location of this site off Common Lane would not interfere with any overloading of the highway network in Brough cum Elloughton but would have links to the shopping centre, but most of all the car movements at peak times would not alter the balance or be an annoyance to the residents.

NOTE

We hope that East Riding of Yorkshire Council will support this site as a whole or in part for immediate development within Brough and Elloughton, as it would provide an excellent short to medium term solution for housing needs before any substantially larger development could take place. Mr D Curtis, CSFC/745 Support Sustaining the market for private sector housing within Hull is an Comments noted and support Homes and important part of ensuring the success of on-going welcomed. Communities comprehensive redevelopment projects. For these reasons, the Agency Agency supports the rejection of ‘Option A’ (Urban extensions to the City of Hull) associated with Policy SS2 (Locating development), including the specific reasons set out for rejecting that option. W.R. & P.M. Ayres CSFC/751 Object An account of its' expansion over the past 20 or 30 years, in Comments noted. The impact of relation to what is proposed for the future. The development of development on the A1079 has been Pocklington, to date, could be said to be 'so far, so good'. There considered through the council’s has been a fairly large increase in good quality housing stock, Infrastructure Study and further work is using 'brown field' and 'infill' sites, over the past 20 or more being undertaken to assess potential years. The Town has thus expanded, yet it has retained its' improvement works. Market Town profile with a locally identifiable community base. The down side to this expansion is the pressure that has been The development of specific sites will be placed upon our communications and services. The schools have considered through the Allocations had to expand; the Health provision has visibly expanded and Document. needs to grow further and our transport situation has has Consultee/Agent ID Nature Of Response Officer Comments Response: become, in the case of the A1079, not fit for purpose. There are traffic jams and considerable parking and access problems in Pocklington at peak times.

To plan to expand into Pocklington's 'green' areas - whether they be Green Belt or Sports Fields etc., - is not acceptable. The Town has already done its' bit, as mentioned above, and the downside problems are fully evident. To add to these problems with further expansion, albeit in the medium term, can only be seen to be irresponsible. Any expansion of Pocklington should only be considered alongside definite proposals for service provisions and the easing of traffic problems on the A 1079. To that extent, the whole Framework should be viewed in that context, not just the part that applies to Pocklington.

One of the ingredients, for a potential services and communications disaster in Pocklington, is 12 miles down the road at York University. Their declared and active expansion states that they will create 2,500 permanent jobs (in addition to the student increases), as a result of this development. York is already bucking the economic trend by proving to retain a bouyant housing market and its' own housing development plans are needed to meet the demands of its' evidently, stable economy.

The first major population base, moving eastwards along the A1079, is Pocklington. It doesn't need much foresight to see that any Pocklington expansion will, by default, meet part of the housing needs of York. The occupants of such housing will probably work in York and, as such, the East Riding Council will be meeting housing needs of a City which is outside its' local government area.

It appears that the East Riding Council is approaching these Local Consultee/Agent ID Nature Of Response Officer Comments Response: Development Plans from a one dimensional aspect - i.e. communicating with its' population to achieve a pre-determined (some would say fait accompli) housing requirement. The whole plan and framework should be returned to Central Government for re-consideration, in the light of the obvious problems which the Framework throws up. For example, unless I am mistaken, the problem of the A1079, which is key to these proposals, is outside of the sphere of the East Riding Council. E.R.Y.C. Officials, alongside our M.P.s, should be putting this situation to Central Government to ensure that we aren't proposing developments without essential infrastructure.

Returning to the plans for Pocklington; assuming that the key problem of the A1079 could be resolved, then a prime 'brown field' site could be the eastern end of the Pocklington Industrial estate. It would be adjacent to the A1079 and could be developed with a mix of affordable and private housing. There would be an amenity buffer of the Gliding Club and Pocklington School between there and the Town and the infrastructure is already being developed. No matter that it is designated for industrial purposes - where there is a need, then plans can be altered and adapted. That particular end of the 'airfield' is presently, an eyesore (remember Bondgate). Far better to develop such an area to the advantage of planning; amenity and social requirement, than take some fields on the periphery of the Town and fill them with tarmac, bricks and mortar. Mr Stephen CSFC/756 Support with SECTION 3 - SETTLEMENT NETWORK Comments noted and support Courcier, Carter conditions welcomed. The approach taken for Jonas LLP on behalf Revised Policy SS2: Locating Development Rural Service Centres and Primary of Mr Huddleston Villages (formerly Primary Rural Service 3.5 Revised Policy SS2 Locating Development sets out the Centres, Secondary Rural Service settlement hierarchy for the district and identifies those Centres and Hinterland Villages) places settlements where growth will be concentrated. We are them in context for the overall supportive of identifying a Settlement Hierarchy where the Settlement Network. The ‘caps’ and Consultee/Agent ID Nature Of Response Officer Comments Response: largest proportion of growth is focussed on the proportional approach support the larger settlements and where it meets identified regeneration overall emphasis on directing large scale objectives. However the Settlement Hierarchy should recognise development to larger higher order the different housing markets operating within the district and its settlements where there are more predominately rural nature. services, facilities and employment opportunities. Representations to East Riding Further Consultation Core Strategy Page 11 of 19 The scale of development proposed in Holme on Splading Moor is broadly 3.6 We support the identification of Holme-on-Spalding-Moor as similar to historic delivery rates in the a Primary Rural Service Centre. The designation appropriately village. reflects the role of the settlement and the comprehensive range of services it provides. Holme-on-Spalding-Moor fulfils a significant local service centre role for the surrounding countryside, and would be equally suitable for designation as a Local Service Centre. The village fufils a role in providing local services and facilities for a wide area between Market Weighton, Holme-on-Spalding-Moor, Howden and York. The settlement has a large range of services and facilities including a village hall, convenience stores, primary school, bank, post office and a number of public houses.

3.7 Holme-on-Spalding-Moor has a large and growing employment base. The Skiff Lane industrial estate accommodates a number of well established businesses. There are also significant employment opportunities provided by Meadow Foods Limited on Station Lane.

Furthermore there is over 7 hectares of available employment land allocated at Skiff Lane Industrial Estate and a further 2.29 hectares at Station Lane.

3.8 It is critical that sufficient growth is allowed within Primary Rural Service Centres, such as Holme on Spalding Moor, to Consultee/Agent ID Nature Of Response Officer Comments Response: ensure that they can meet their housing needs and demands including those of their surrounding rural hinterlands. As currently drafted, the policy is overly prescriptive and would not allow sufficient growth to come forward. The scale of development should only be given as guidance and should be determined for each settlement within the context of local needs and demand and its size and character. If a figure has to be given it should be in excess of 10 dwellings per annum. Mr Stephen CSFC/759 Observations Revised Policy SS2 Locating Development sets out the Comments noted and support Courcier, Carter settlement hierarchy for the district and identifies those welcomed. The approach taken for Jonas LLP on behalf settlements where growth will be concentrated. We are Rural Service Centres and Primary of C Carver Esq supportive of identifying a Settlement Hierarchy where the Villages (formerly Primary Rural Service and Family largest proportion of growth is focussed on the larger Centres, Secondary Rural Service settlements and where it meets identified regeneration Centres and Hinterland Villages) places objectives. However the Settlement Hierarchy should recognise them in context for the overall the predominately rural nature of the district. Settlement Network. The ‘caps’ and proportional approach support the We consider that North Cave should be identified as Primary overall emphasis on directing large scale Rural Service Centre. The designation would reflect the role of development to larger higher order the settlement and the comprehensive range of services it settlements where there are more provides. North Cave fulfils a significant local service centre role services, facilities and employment for the surrounding countryside, and has a large range of services opportunities. and facilities including a village hall, convenience stores, primary school, banking facilities, post office and a number of public The scale of development proposed in houses. It also has a stable and growing employment base North Cave is broadly similar to historic provided by the nearby prisons and cluster of employment uses delivery rates in the village. around Junction 37 of the M62.

It is critical that sufficient growth is allowed within Primary and Secondary Rural Service Centres to ensure that they can meet their housing needs including those of their surrounding rural areas. As presently designated as a Secondary Rural Service Centre there is a potential risk that the proposed level of housing to brought forward within North Cave would be Consultee/Agent ID Nature Of Response Officer Comments Response: insufficient to preserve the settlement’s viability and vitality or maintain its services and facilities.

As a minimum, the policy should be amended because it is overly prescriptive. The scale of development in Primary and Secondary Service Centres should only be given as a guideline and should be determined for each settlement within the context of local needs and its size and character. If a figure is to be given it should be in excess of an average of 10 and 5 dwellings per annum respectively. Mr Alex Codd, CSFC/769 Support With regard to SS2, A1, Hull City Council considers that it Comments noted and support Hull City Council would be clearer if the phrase: welcomed.

"that part of the East Riding comprising the Regional City - Part A1 has been redrafted in the Draft Anlaby, Cottingham, Hessle, Kirk Ella and Willerby" Strategy Document (Policy S3) to reflect that the Major Haltemprice Settlements be replaced by are immediately to the west of the city of Hull. "that part of the East Riding comprising part of the Regional City - Anlaby, Cottingham, Hessle, Kirk Ella and Willerby". The policy approach for the Major Haltemprice Settlements has been Instead of "support the regeneration interventions within the revised to reference other development City of Hull", (SS2D) Hull City Council would prefer "support proposals within the city (not just the regeneration interventions and other development regeneration schemes). commitments and aspirations".

Hull City Council strongly supports the decision to rule out urban extensions to the City of Hull. Also, the recognition that Hull's Published Core Strategy has already identified sufficient housing land within the city boundary is welcomed. Hull City Council does not consider that any urban extension beyond the City's boundary is either necessary or justifiable. Mr David Hand, CSFC/777 Support No objections Comments noted. Consultee/Agent ID Nature Of Response Officer Comments Response: Scarborough Borough Council Cllr Charles CSFC/786 Object The Authority should not be split into 6 but 3 sub-areas, a Comments noted. The division of the Bayram, ERYC coastal sub-area, a rural sub-area and a sub-area covering the East Riding into 6 sub areas has been A63/M64 growth area. largely welcomed.

Too many additional homes are proposed for Driffield, The regeneration strategy for Bridlington and the Coastal sub-area, or settlements without Bridlington incorporates a growth sufficient employment. agenda and this is supported through the Strategy Document. The primary planning principles are that economic growth is encouraged in the most appropriate locations; new homes are The distribution of jobs across the then planned accordingly. The Authority’s vision is to put most authority (and in neighbouring areas) new homes into the largest settlements; it should reflect has been a key factor in determining the economic growth, not settlement size. distribution of housing. A significant proportion of housing is to be directed The Authority should explain why Ferriby is to have no housing in and around the main east-west multi- allocation, yet has the largest new employment site, and why modal corridor where economic Hedon is linked to Saltend and Hedon Haven, yet only has a opportunities are likely to be the growth of 3.5%. The authority should also explain why North greatest. Cave has more jobs compared to its population yet very little in the way of housing. The Department foe Communities and Local Government’s (CLG) 2001 Urban The Authority is not using any recognised method of assessing Settlements (previously called Urban settlements. It is not correct to just use Parish or Ward numbers Areas) defines all settlements above 20 as data. The Authority should use the method set out in the hectares where the land use is urban in Government’s “Urban/ Rural Definitions” guide. The data should character. Further work as part of the be used from the 2001 census “until 2013” because it is data CLG urban-rural definitions (2004) uses readily available to everyone. A settlements size includes all the the same 2001 Urban Settlements, and built environment, it stops once there is a green field gap of 200 classifies as ‘Urban’ those settlements meters or more. where the population count is 10,000 or above. Below this level, settlements are It should be of no importance whether a settlement is, urban or known as being within the ‘rural rural, a town or a village, a supporting village or a service centre. domain’. (Source: Urban and Rural Consultee/Agent ID Nature Of Response Officer Comments Response: It is about the role, the function of a settlement, how it works, is Classification 2004 – An Introductory it performing its role within the community? A shop which sells Guide). The Urban and Rural everyday items, a school and a meeting place, a hall or a pub are Classification 2004 shows that only the the three key services which bring people together. Public Major Haltemprice Settlements, transport gets you to work and back. Beverley, Bridlington, Driffield and Goole meet the ‘urban’ definition. Without sufficient jobs and growth, a settlement will die, its need must relate to all jobs, within and up to 2km from its outer The methodologies for identifying limits. settlements have been developed to consider their role and function. The This plan is for 15 to 17 years, to allocate too much growth in services referred to have been the wrong place can be worse than too little. No settlement considered. should increase by over 40% during the plan period, 3% per year, or 14% per 5 year period, even in a growth area. Policy S3 of the Draft Strategy Document begins with reference to The Authority is not directing development on to previously prioritization of the redevelopment of developed land - something the community want to see. There previously developed land and this is re- should be a 20% target at least and no affordable housing, the emphasised through Policy H4. authority should encourage Brownfield development. The level of flood risk has been an The Authority should not allocate any land in the 2 one 3 high integral part of considering the overall risk flood areas. They should use option B, a levy on all, but not strategy. The allocation of specific sites Brownfield land. will be determined through the Allocations Document. The authority should take into account of the Junction 38 or Walkington cluster, South Cave, North Cave, Newport and The suggested [Walingfen] Cluster is Gilberdyke together has a population of over 11,000 at 2001, to noted, though this appears to be based include the satellite villages over 17,000 population. It should be solely on a cumulative population of 9 made a service cluster instead of Howden. Howden is too close villages rather than on any consideration to Goole to be of value as a service centre. The Authority plan of their merits as a service centre to impose a 50 to 60% growth, this should be reduced; it is the cluster. highest growth in the plan. Gilberdyke and Newport have been identified as a Primary Rural Service Consultee/Agent ID Nature Of Response Officer Comments Response: Centre along with North Cave and South Cave as Primary Villages.

The scale of housing proposed in Howden does not constitute a growth of 50%-60% and is a reflection of the level of existing commitments in the town. Mr Pete Sulley, CSFC/791 Observations Settlement Network – Question 2: There are no representations Comments noted. The development Barton Willmore to make in relation to the amended approach to the Settlement limits will be revised through the on behalf of Network. Allocations Document process to Central Land accommodate the scale of development Holdings Policy SS2 has been revised from the Preferred Approach Core set out in the Strategy Document. Strategy, primarily in relation to the designation of Primary and Secondary Rural Service Centres as opposed to the previous designation of Rural Service Centres and Supporting Villages.

3.2 In terms of its land interests in Anlaby, Central Land Holdings is generally in support of the strategy of focussing development towards the Major Haltemprice Settlements and Principal Towns as set out in the relevant parts of Policy SS2, which remain largely unaltered from the Preferred Approach Core Strategy and which comprise A1, A2, B (specifically Major Haltemprice Settlements and Principal Towns reference), D and E.

However, there is concern that A. states that ‘New development will be focused [bold] within [bold] the development limits of the defined Settlement Network….’ (our emphasis). This does not provide sufficient flexibility for edge of settlement greenfield extensions, which will be required to achieve the housing targets set out in the Further Consultation, notwithstanding Central Land Holdings‘ comments on actual housing numbers as set out later in these representations. Mr Pete Sulley, CSFC/800 Support with 3.1 Policy SS2 has been revised from the Preferred Approach Comments noted. The development Barton Willmore conditions Core Strategy, primarily in relation to the designation of Primary limits will be revised through the on behalf of and Secondary Rural Service Centres as opposed to the previous Allocations Document process to Trustees of the designation of Rural Service Centres and Supporting Villages. accommodate the scale of development Needler Settlement set out in the Strategy Document. 3.2 In terms of its land interests in Beverley, The Trustees are generally in support of the strategy of focussing development towards the Major Haltemprice Settlements and Principal Towns as set out in the relevant parts of Policy SS2, which remain largely unaltered from the Preferred Approach Core Strategy and which comprise A1, A2, B (specifically Major Haltemprice Settlements and Principal Towns reference), D and E.

Consultee/Agent ID Nature Of Response Officer Comments Response: 3.3 However, there is concern that A. states that ‘New development will be focused within the development limits of the defined Settlement Network….’. This does not provide sufficient flexibility for edge of settlement greenfield extensions, which will be required to achieve the housing targets set out in the Further Consultation, notwithstanding The Trustees’ comments on actual housing numbers as set out later in these representations. Mr Pete Sulley, CSFC/814 Support with Settlement Network – Question 2: There are no representations Comments noted. The development Barton Willmore conditions to make in relation to the amended approach to the Settlement limits will be revised through the on behalf of Network. Allocations Document process to Central Land accommodate the scale of development Holdings 3.1 Policy SS2 has been revised from the Preferred Approach set out in the Strategy Document. Core Strategy, primarily in relation to the designation of Primary and Secondary Rural Service Centres as opposed to the previous designation of Rural Service Centres and Supporting Villages.

3.2 In terms of its land interests in Goole, Central Land Holdings is generally in support of the strategy of focussing development towards the Major Haltemprice Settlements and Principal Towns as set out in the relevant parts of Policy SS2, which remain largely unaltered from the Preferred Approach Core Strategy and which comprise A1, A2, B (specifically Major Haltemprice Settlements and Principal Towns reference), D and E.

3.3 However, there is concern that A. states that ‘New development will be focused within the development limits of the defined Settlement Network….’ (our emphasis). This does not provide sufficient flexibility for edge of settlement greenfield extensions, which will be required to achieve the housing targets set out in the Further Consultation, notwithstanding KPDC’s comments on actual housing numbers as set out later in these representations. Mr Zulficar Ali, CSFC/840 Object We have some concerns regarding the methodology of the Comments noted. The growth scenarios Environment settlement network specifically for the Primary Rural Service recognise the role and function of Rural Agency Centres (PRSC) and the Secondary Rural Service Centres Service Centres and Primary Villages (SRSC). We are unclear as to how the council has arrived at the (formerly Primary Rural Service revised 10% and 20% housing growth for these settlements. It Centres, Secondary Rural Service would be useful if an opening paragraph clearly states the Centres and Hinterland Villages) in the approach taken to arrive at these figures. overall Settlement Network. The ‘caps’ and proportional approach support the Consultee/Agent ID Nature Of Response Officer Comments Response: Para 3.9 advises why the 10 and 5 dwellings per year for the overall emphasis on directing large scale PRSC and the SRSC would potentially result in an overall 40% development to larger higher order increase in some of these villages which the council would want settlements where there are more to avoid. We believe the same approach is needed to justify why services, facilities and employment a 10% and 20% approach has been taken in this further opportunities. consultation approach. The council has continued to take It is important for the council to justify what evidence base account of the changes in the prompted a change to the settlement network. Whilst we have Environment Agency’s Flood Map and no concerns in principle to the approach taken in forming the has continued to liase with the PRSC’s and SRSC’s the method in approach to housing Environment Agency on flood risk development in these locations needs to be justified and made matters related to the Local Plan. clear. In those Primary Villages which are The council may wish to take this opportunity to update their entirely within the high risk flood zone, SFRA. Since the previous consultation on the Preferred the policy approach is to not allocate Approach many changes have occurred in terms of modelling and sites for housing development. subsequent changes to the flood map. In addition further mapping improvements will be continued to made in 2012. As such in order to be confident to deal with the above concern it would be advised that an update is carried out to ensure that there is consistency between our flood maps and your SFRA.

We welcome para 3.7 and 3.8. Para 3.8 states that you intend on removing Rawcliffe from the list as a result of its constraints. We would welcome inclusion of a paragraph to advise what would then happen to Rawcliffe as a consequence of removing it from the primary and secondary rural service status. It is important to note that Rawcliffe is protected by flooding from defences. However, the area could still flood in extreme events, particularly as the area is tidally dominated so any storm surges could be propagated upstream. Some areas surrounding Rawcliffe were affected by the floods of June 2007. Mr Dan Mitchell, CSFC/851 Support with 1.5 Overall, our client is supportive of the broad approach to Comments noted and support Consultee/Agent ID Nature Of Response Officer Comments Response: Barton Willmore conditions employment growth in East Riding as set out in the Core welcomed. on behalf of Strategy and in previous Development Plan Documents including Wykeland Group the RSS, the former East Riding Local Plans and RSS. However, it Policy SS5 of the Further Consultation Limited is noted that the recent recession has impacted significantly on Core Strategy provided specific the existing strategy and the Council should now be seizing the guidance on the sacle of development opportunity afforded by the new Core Strategy to address the required for employment land over the key employment issues to be facing East Riding over the next 15- plan period. This noted the importance 20 years. As currently drafted, the Core Strategy does not do of the east-west multi-modal corridor this. The development strategy appears to follow the planning for economic uses. strategy of old and does not recognise some of the important opportunities for new job growth in East Riding. We amplify our A specific reference to the east-west clients concerns under our response to the relevant headings multi-modal corridor, from Hedon below. Haven to Goole, as an economic focus has been added to Policy S3 of the Draft 1.6 It is noted at this point that there is an inherent inconsistency Strategy Document (Focusing between the development strategy, settlement hierarchy and development) to reflect its importances employment market. We note that there is a significant need to and the opportunities which arise there. generate new jobs in Hull and East Riding, particularly along the A63/M62 corridor which has also played a main role in the The development limits will be revised Council’s economic development strategy over the last plan through the Allocations Document period with allocations at Bridgehead and Melton. The current process to accommodate the scale of consultation document does not reflect these sites or the new development set out in the Strategy opportunities along the multimodal M63/A63 corridor. This Document. should be reflected in the Core Strategy to mirror the identification of these areas in the Council’s Economic Development Strategy (2007-2011) on page 43 and 44 of that document.

1.7 This is fundamental given recent announcements and emerging technology sectors. In September, BAe Systems announced the closure of the facility at Brough with the loss of 900 jobs. In response, the Government has announced that Brough will become an Enterprise Zone. We would note that the Enterprise Zone at Brough is, however, reactive to the Consultee/Agent ID Nature Of Response Officer Comments Response: announcement to close the BAe Systems facility. If it progresses, it with help to mitigate the loss of employment in a very localised area at Brough. In contrast, Melton West provides for a strategic employment location and the proposed extension to Melton West into Phase 3 could, for the first time, provide new cycle and pedestrian linkages with Brough, thereby enabling long term economic prosperity to this part of East Riding with its locational advantages and improving sustainability. The importance of an expanded Melton West along the A63 corridor should be recognised in the Core Strategy. We also refer to the Wykeland take up schedules in the appendices to this statement which illustrate the success story that is economic development at Melton West.

1.8 In parallel, we note that both Hull and East Riding Council’s recognise the opportunity brought by the renewable energy sector to this sub-region. Very recently, Siemens has submitted a series of planning applications to Hull City Council for a new £200m wind turbine factory in Hull. This facility in itself is stated as creating 700 new jobs and will also act as a catalyst for further inward investments into the sub region. Estimates have suggested and it is widely reported that this new sector will create some 10,000 new jobs along the north bank of the River Humber.

1.9 This growing sector is focused on the corridor between Hedon Haven and Brough. Wykeland considers that this area should be expressly identified within the Core Strategy. It is noted that this is a different employment market to the M62 corridor which extends as far as Goole. Goole provides for an entirely different employment offer focusing on B8 storage and distribution uses due to its national road connectivity. The A63 corridor from Hedon Haven to Brough (including Melton) is the core growth area on the North bank that will deliver the employment land opportunities for the renewable sector. This Consultee/Agent ID Nature Of Response Officer Comments Response: should be clearly identified in a separate Core Strategy Policy and on the proposals maps.

1.10 Wykeland is keen to build on its track record and deliver new employment opportunities for the East Riding. It is promoting some of the next generation employment sites via the Site Allocations Development Plan Document. These include the following:

• Opportunity to expand Melton West • Provision of a new rail freight terminal at Melton • Development of the Bridgehead site • Employment land at Hessle • Promotion of north bank – strategic cluster

1.11 It is within the above context that Wykeland considers that the East Riding Council should recognise this strategic area of national and regional important and that this should be dealt with specifically in the Core Strategy.

3. Settlement Network (and Policy SS2)

Response to Question 2 – Do you agree with the amended approach to the Settlement Network as set out in Revised Policy SS2?

3.1 Table 1 on page 20 of the Core Strategy provides for the preferred approach settlement network. Our client has no objections to this hierarchy per se, however it is concerned that the settlement network does not align with the economic growth strategy for the East Riding including the Employment Land Review (ELR). This issue is unique to East Riding being a very large geographical area and due to parts of the East Riding adjoining the Regional City of Hull. Consultee/Agent ID Nature Of Response Officer Comments Response:

3.2 To expand on our concerns, it is firstly noted that Policy SS2 focuses growth to within the development limits of defined settlements at part A. There appears to be no need for part A, given parts B, C, D, E and F which also refer to each settlement.

3.3 Separately we note that there is an inevitable need for land release outwith the development limits, as identified under the Place Statements. Policy SS2 is therefore contradictory to other parts of the Core Strategy and the Place Statements which do indicate the need for green field land release for both housing and employment growth. In this regard, Policy SS2 should clearly state this.

Alternative Approaches

3.4 In respect of employment land, both the Council’s ELR and the Economic Development Strategy highlight the importance of the A63/M62 corridor to the sub region which is a major feature of the development strategy to date. Policy SS2 does not address this, despite Policy SS5 referring to the east west multi modal corridor.

3.5 Whilst growth is being rightly focused on existing settlements, the Core Strategy needs to recognise the continued importance of the A63/M62 sites. Business will always seek locational advantages to ensure competitiveness. Unless this is recognized in the Core Strategy, there is a danger that the development and location strategy will not match the Council economic growth strategy.

3.6 This can be achieved by an additional paragraph being added to Policy SS2 reflecting these matters as an exception for employment land. Appropriate wording will be needed to clarify Consultee/Agent ID Nature Of Response Officer Comments Response: that the key employment locations along the M62/A63 corridor are complementary to the growth of existing settlements in the hierarchy.

3.7 We would suggest the addition of the follows:

“Strategic employment growth along the A63/M62 – multi modal corridor

In addition to the provision of new employment land at the settlements in the Council’s hierarchy, extensions to existing strategic employment sites will be identified as a focus for economic growth. Development at the existing employment sites along the A63/ M62 multi modal corridor is a key part of the overall economic growth strategy and existing sites and new land will ensure that the sub region benefits from sustained growth. Such sites will provide for inward investment opportunities and for the clustering of new technologies such as the renewables sector.” Mr Chris Calvert, CSFC/870 Observations Local Service Centres Comments noted and support Pegasus Planning welcomed. It is not considered that any Group on behalf of In a large rural area like the East Riding, the importance of local settlements fulfil, or have the potential John W Scholey services and the need to ensure their future survival cannot be to fulfil, the Town role (formerly Local understated. My client has previously submitted comments (our Service Centre) in the northern part of ref. 001.nb/YOR.1729) regarding the geographical spread of the the East Riding. Local Service Centres across the district, particularly that the northern part of the district, around Driffield, has a gap in the The delivery and monitoring section of settlement hierarchy as a result of there being no settlement the Draft Strategy Document sets out within that part of the district which fulfils a local service centre the potential response to under- role. My client considers that the absence of a local service provision of housing. centre in the northern part of the district should be acknowledged. This will then enable consideration of how other settlements in the hierarchy, such as Hutton Cranswick, can help to address this gap. Consultee/Agent ID Nature Of Response Officer Comments Response:

Rural Service Centres

Hutton Cranswick has a wide range of services and excellent public transportation connections to the wider District. My client therefore strongly supports Hutton Cranswick's inclusion in the settement hierarchy.

My client notes that Policy SS2 Part H has been amended so that "small scale" residential development has been replaced with development "commensurate with the scale, role and character of the village". The uniform increase in planned development in PRSCs (10 dwellings pa) has been superseded with proportional growth scenarios (20%).

Whilst it would be feasible to monitor performance against PRSCs growth targets there is no provision in the policy for a situation arising whereby a particular settlement(s) underperforms against this proportional growth target. If this occurs, will the shortfall be made up by additional release in other settlements and if so how would this be managed?

My client submits that North Frodingham should be identified as Consultee/Agent ID Nature Of Response Officer Comments Response: a Secondary Rural Service Centre within the settlement due to the provision of local services (school, village store, post office, Public Houses). The village needs to accommodate some growth in order to sustain these existing services. Mr Chris Calvert, CSFC/880 Observations Local Service Centres Comments noted and support Pegasus Planning welcomed. It is not considered that any Group on behalf of In a large rural area like the East Riding, the importance of local settlements fulfil, or have the potential Mr R Swales services and the need to ensure their future survival cannot be to fulfil, the Town role (formerly Local understated. My client has previously submitted comments (our Service Centre) in the northern part of ref. 004.sm/YOR.1159) regarding the geographical spread of the the East Riding. Local Service Centres across the district, particularly that the northern part of the district, around Driffield and Bridlington, has The delivery and monitoring section of a gap in the settlement hierarchy as a result of there being no the Draft Strategy Document sets out settlement within that part of the district which fulfils a local the potential response to under- service centre role. My client considers that the absence of a provision of housing. local service centre in the northern part of the district should be acknowledged. This will then enable consideration of how other settlements in the hierarchy, such as Kilham, can help to address this gap.

Rural Service Centres

Kilham has a good range of services and plays an important role in this remote and rural part of the district. My client therefore strongly supports Kilham's inclusion in the settement hierarchy.

Whilst it would be feasible to monitor performance against Consultee/Agent ID Nature Of Response Officer Comments Response: PRSCs growth targets there is no provision in the policy for a situation arising whereby a particular settlement(s) underperforms against this proportional growth target. If this occurs, will the shortfall be made up by additional release in other settlements and if so how would this be managed?

My client notes that new evidence (Infrastructure Study and SFRA) has informed the proposed changes to the identification of rural services centres - the use of such evidence is a sound approach. Mr Chris Calvert, CSFC/884 Object Primary Rural Service Centres Comments noted. The Draft Strategy Pegasus Planning Document amends the names of the Group on behalf of Leven has a wide range of services and good public categories to help understand the WC Watts Estate transportation connections to the wider District. It plays an different roles. Rural Service Centres & Mr D Watts important role in the eastern rural part of the district. My client (formerly Primary Rural Service therefore strongly supports Leven's inclusion in the settement Centres) are those villages which hierarchy. complement the network of higher order centres in locations which Secondary Rural Service Centres provide a geographic spread. They support a small rural catchment beyond The settlement of South Cave is a large village strategically their own communities. Primary Villages located and well served by local services and facilities. My client (formerly Secondary Rural Service strongly supports the inclusion of South Cave in the settlement Centres and Hinterland Villages) are hierarchy and considers that its role is commensurate to a PRSC those villages which have basic services rather than a SRSC. and facilities but which are not necessarily geographically positioned in My client notes that Policy SS2 Part H has been amended so that terms of meeting needs beyond their development "commensurate with the scale, role and character own communities. Some of the Primary of the village" will be supported. The uniform increase in planned Villages (formerly the Hinterland development in PRSCs (10 dwellings pa) and SRSC (5 dwellings Villages) also benefit from good access pa) has been superseded with proportional growth scenarios to larger neighbouring centres which do (20%/10%). perform a service centre role.

My client is unconvinced that the distinction between PRSCs and South Cave is in proximity to Elloughton Consultee/Agent ID Nature Of Response Officer Comments Response: SRSCs has been clearly justified and explained, which makes the cum Brough which suggests it doesn’t allocation of different amounts of housing problematic. South have a service centre role to play in Cave, for example, ranked highly in the Council's smaller terms of meeting the needs of areas settlement study and is of a distinctly different scale to those beyond the South Cave community. other settlements identified as SRSCs.

My client notes that new evidence (Infrastructure Study and SFRA) has informed the proposed changes to the identification of rural service centres - the use of such evidence is a sound approach. Mr Chris Calvert, CSFC/891 Observations Local Service Centres Comments noted. It is not considered Pegasus Planning that any settlements fulfil, or have the Group on behalf of In a large rural area like the East Riding, the importance of local potential to fulfil, the Town role Mr & Mrs JH services and the need to ensure their future survival cannot be (formerly Local Service Centre) in the Foreman understated. My client has previously submitted comments (our northern part of the East Riding. ref. 08.sm.YOR.1126) regarding the geographical spread of the Local Service Centres across the district, particularly that the The delivery and monitoring section of northern part of the district, around Driffield, has a gap in the the Draft Strategy Document sets out settlement hierarchy as a result of there being no settlement the potential response to under- within that part of the district which fulfils a local service centre provision of housing. role. My client considers that the absence of a local service centre in the northern part of the district should be acknowledged. This will then enable consideration of how other settlements in the hierarchy, such as Hutton Cranswick, can help to address this gap.

Rural Service Centres Consultee/Agent ID Nature Of Response Officer Comments Response:

My client notes that new evidence (Infrastructure Study and SFRA) has informed the proposed changes to the identification of rural services centres - the use of such evidence is a sound approach. Mr Chris Calvert, CSFC/899 Support Local Rural Service Centres Comments noted and support Pegasus Planning welcomed. Group on behalf of In a large rural area like the East Riding, the importance of local Evison Farmers services and the need to ensure their future survival cannot be understated. My client supports the identification of Elloughton cum Brough as a Local Service Centre with new development appropriate to ensure its future viability and continued existence of services for its community and rural catchment. Mr Chris Calvert, CSFC/904 Support My clients support the role given in Policy SS2 to the major Comments noted and support Consultee/Agent ID Nature Of Response Officer Comments Response: Pegasus Planning Haltemprice settlements with the settlement hierarchy. Kirk Ella welcomed. Group on behalf of is an appropriate location for new housing development given its Mr and Mrs role in supporting the regeneration of the wider Regional City of Hudson Hull. Mr Chris Calvert, CSFC/909 Support with Principal Towns Comments noted and support Pegasus Planning conditions welcomed. Group on behalf of My client supports the approach in Policy SS2 for principal towns Mr Peter Ward, as centres for economic development and housing growth to The delivery and monitoring section of Peter Ward cater for their own needs and the service needs of significant the Draft Strategy Document sets out Homes Ltd parts of the District. My client supports the inclusion of Goole in the potential response to under- the settlement hierarchy and the distribution of growth to this provision of housing. settlement.

Rural Service Centres

The settlements of Beeford and Holme on Spalding Moor are well served by local services and facilities which allows these villages to act as a central point for the rural hinterland. My client therefore strongly supports the inclusion of Holme on Spalding Moor and Beeford in the settlement hierarchy and the distribution of growth to these settlements.

Rural Service Centres

The settlement of Beeford is well served by local services and facilities which allows the village to act as a central point for the rural hinterland. My client strongly supports the inclusion of Beeford in the settlement hierarchy and the distribution of growth to this settlement. Mr Michael Glover, CSFC/920 Support with The exor of Sydney Howard believes the amended approach is Comments noted and support Michael Glover LLP conditions broadly correct within SS2 but considers that the role and scale welcomed. South Cave is in proximity on behalf of Exors of facilities in South Cave and the catchment area it serves are to Elloughton cum Brough which of Sydney Howard such that it should be elevated to a Primary Rural Service suggests it doesn’t have a service centre Consultee/Agent ID Nature Of Response Officer Comments Response: Deceased , Centre. role to play in terms of meeting the Robsons Chartered needs of areas beyond the South Cave Accountants Within an earlier residential planning appeal on the Water Lane , community. South Cave site owned by the exor , the inspector criticised the distance of South Cave from the rail station ( and , from memory, the other facilities in Brough) , and the convenience of access from the A63 and the scale and range of facilities offered in South Cave provides a far more wider ranging offer than the other settlements included within the Secondary Rural Service Centre category.

The village is just a little too far from Brough to take full advantage of those facilities , particularly from the hinterland villages and other settlements surrounding to the north, and east , which would look primarily to South Cave or north to Market Weighton or east to Beverley if a wider ranging scale of shops and services were required . Mr Chris Calvert, CSFC/921 Observations My client notes that Policy SS2 Part H has been amended so that Comments noted. The delivery and Pegasus Planning "small scale" residential development has been replaced with monitoring section of the Draft Strategy Group on behalf of development "commensurate with the scale, role and character Document sets out the potential Mr G Rhodes of the village". The uniform increase in planned development in response to under-provision of housing. PRSCs (10 dwellings pa) has been superseded with proportional growth scenarios (20%).

Whilst it would be feasible to monitor performance against RSCs growth targets there is no provision in the policy for a situation arising whereby a particular settlement(s) underperforms against this proportional growth target. If this occurs, will the shortfall be made up by additional release in other settlements and if so how would this be managed? Mr John Brown, CSFC/924 Support The revised classification seems useful in helping determine Comments noted and support Pocklington and potential housing allocations and identifying service hub functions welcomed. Wolds Gateway more accurately. It can be particularly constructive in Consultee/Agent ID Nature Of Response Officer Comments Response: Partnership consideration of the hinterland roles associated with the market towns. The definition as ‘hinterland’ settlements is a timely reminder of the importance of such settlements to the continuing development of the market towns. Mr Chris Calvert, CSFC/925 Support My client notes that new evidence (Infrastructure Study and Comments noted and support Pegasus Planning SFRA) has informed the proposed changes to the identification of welcomed. Group on behalf of rural service centres - the use of such evidence is a sound Mr G Rhodes approach. Mr Michael Glover, CSFC/930 Support Anlaby Estates Ltd supports the concept proposed within revised Comments noted and support Michael Glover LLP policy SS2 which sets out the focus for new development on an welcomed. Development in and around on behalf of identified settlement network . the Major Haltemprice Settlements Anlaby Estates, must be considered in light of: Anlaby Estates Notwithstanding this , Anlaby Estates Ltd believe that the Major supporting the role of the city of Hull Haltemprice Settlements should be the principal focus for (in terms of regeneration and development in the East Riding on the grounds that, in investment priorities within the city); sustainability terms such a concentrated pattern of development the environmental and infrastructure would make the best use of existing public transportation capacity of the area; and the objective of systems, existing infrastructure ( and the economic and efficient avoiding settlement coalescence. delivery and use of new infrastructure and public transportation systems ) and the provision of housing and ancillary services in a well related pattern relative to existing and future employment .

Such focus on the Major Haltemprice Settlements is a logical mechanism to address the above aims and outcomes, which will be important steps in furthering the need to address climate change, make efficient use of scarce resources and reduce greenhouse gas emissions . Mr Chris Calvert, CSFC/939 Support Haltemprice Settlements and Principal Towns Comments noted and support Pegasus Planning welcomed. Group In broad terms we support the main focus of development towards the Haltemprice settlements and Principal Towns. Mrs A J Pickering, CSFC/1007 Observations The Kirk Ella and West Ella Parish Council have concerns about Comments noted. The Infrastructure Consultee/Agent ID Nature Of Response Officer Comments Response: Kirk Ella & West adequate drainage for new development and concern over Study has assessed the potential impact Ella Parish Council pressure on the already congested highways. of development on infrastructure and further work will be undertaken as part of reviewing the plan and in the preparation of the Allocations document. Mr Chris Calvert, CSFC/942 Object Rural Service Centres Comments noted. The Draft Strategy Pegasus Planning Document amends the names of the Group We have previously questioned the methodology for categories to help understand the distinguishing Rural Service Centres (now Primary Rural Service different roles. Rural Service Centres Centres) and Supporting Villages (now Secondary Rural Service (formerly Primary Rural Service Centres) and our comments in this regard remain. Please refer Centres) are those villages which to Pegasus' representation submitted on the 16th July 2010 (our complement the network of higher ref. 001.sm/PPG/CS Rep). order centres in locations which provide a geographic spread. They The uniform increase in planned development (10 / 5 dwellings support a small rural catchment beyond pa) has been superseded with proportional growth scenarios their own communities. Primary Villages (20% / 10%) which have distinctly reduced the proportion of the (formerly Secondary Rural Service District's housing requirement to be met within the PRSCs and Centres and Hinterland Villages) are SRSCs. We remain unconvinced that the distinction between those villages which have basic services PRSCs and SRSCs has been clearly justified and explained, which and facilities but which are not makes the allocation of different amounts of housing problematic, necessarily geographically positioned in further compounded by the scale of development envisaged terms of meeting needs beyond their within Hinterland Villages in Policy SS3 (i.e. same as RSCVs). own communities. Some of the Primary Villages (formerly the Hinterland Villages) also benefit from good access to larger neighbouring centres which do perform a service centre role. Mr Chris Calvert, CSFC/943 Support It is noted that new evidence (Infrastructure Study and SFRA) has Comments noted and support Pegasus Planning informed the proposed changes to the identification of rural welcomed. Group service centres - the use of such evidence is a sound approach. Mr Chris Calvert, CSFC/940 Object Local Service Centres Comments noted. It is not considered Consultee/Agent ID Nature Of Response Officer Comments Response: Pegasus Planning that any settlements fulfil, or have the Group In a large rural area like the East Riding, the importance of local potential to fulfil, the Town role services and the need to ensure their future survival cannot be (formerly Local Service Centre) in the understated. We have no objections to the seven local service northern part of the East Riding. centres proposed, which appear to have been selected on the basis of reasonable consistent criteria, and are supported by the 2004 RSS Settlement Study. However, the geographical spread of the Local Service Centres across the district raises some concerns. It is clear that to the northern part of the district, around Driffield and Bridlington, there is a gap in the settlement hierarchy as a result of there being no settlement within that part of the district which fulfils a local service centre role. We consider that the absence of a local service centre in the northern part of the district should be acknowledged. This will then enable consideration of how other settlements in the hierarchy can help to address this gap. Mr Paul Forshaw, CSFC/964 Object Part A of Revised Policy SS2 identifies Hedon as a Local Service Comments noted. The role and status BNP Paribas Real Centre. Part F states that Local Service Centres (LSC) will of Hedon has been considered through Estate on behalf of provide the local focus for housing, economic development, the preparation of the Strategy Associated British shopping, leisure, transport, education, health, entertainment and Document and has used a variety of Ports cultural activities for the town and its rural hinterland. It states sources. The RSS Settlement Study that LSC will support and complement the Principal Towns and Report (June 2004) used to inform the the Regional City. preparation of the RSS identified Hedon as fulfilling a Local Service Centre role. Given this definition of LSC, ABP objects to the designation of For example, the population of Hedon is Hedon as a LSC and considers that it should be designated as a just over half of that of the smallest Principal Town. The Yorkshire and Humber Plan: Regional Spatial Principal Town, Driffield, and has Strategy to 2026 (May 2008) (hereafter referred to as the “RSS”) substantially fewer services and facilities defines LSC as: “Towns and villages that provide services and compared to the four Principal Towns. facilities that serve the needs of, and are accessible to, people in The amount of retail floorspace in the surrounding areas.” Hedon is a quarter of that of Driffield (again, the smallest of the Principal It is considered that Hedon plays a greater role in the ERoY Towns) and the council’s Retail Study Settlement Hierarchy than this. In particular, like the Major identified Hedon as having a district Consultee/Agent ID Nature Of Response Officer Comments Response: Haltemprice Settlements to the west of the Regional City of Hull, centre below that found in Principal Hedon is closely linked to the City of Hull. Hedon not only has Towns. its own employment offer and services, but also has excellent access to significant employment opportunities and services in Hedon’s access to Hull does not Hull, and is linked to the Regional City by regular direct public provide the evidence to suggest it fulfils transport services. a Principal Town role.

The links between the Regional City of Hull and Hedon will also be strengthened if ABP’s land at Paull Road, Saltend (Hedon Haven) is developed for port-related uses and renewable / low carbon energy related-development. This site has been designated as part of the Humber Enterprise Zone along with Green Port Hull and Queen Elizabeth Dock.

A significant number of jobs will be created close to Hedon as part of the development of the Enterprise Zone, and these employment opportunities will complement additional employment opportunities close to Hedon, including BP Chemicals, International Power at Saltend, Vivergo (the bioethonal plant at the BP Chemical Park which is due to start production shortly) and Centrica’s offices.

In addition, Hedon also has a number of services and facilities including shops, public houses, restaurants, health facilities, a supermarket and education facilities, including 2 primary schools. The South Holderness Technology College is also located close by.

Given the level of services and employment opportunities within and surrounding Hedon, as well as its strong links with the Regional City of Hull, it is considered that Hedon plays a greater role than a LSC. It is considered that its role is that of a Principal Town.

Consultee/Agent ID Nature Of Response Officer Comments Response: Policy YH5 in the RSS allows local planning authorities to designate further Principal Towns in the

LDF where the settlement will:

■ Provide employment, community facilities and services for local and surrounding populations; and ■ Have good accessibility by public transport to Regional Cities. Hedon clearly meets both these criteria as it provides employment opportunities and service provision for not only its own residents, but also residents of surrounding settlements, including Preston, Burstwick, Paull and Thorngumbald. It also has excellent links with the Regional City of Hull, including by frequent public transport services.

It is therefore considered that Hedon fulfils the role of a Principal Town, as defined by Policy YH5 in the RSS. As such, ABP requests that Hedon is designated as a Principal Town in the Core Strategy. Mr Chris Calvert, CSFC/961 Support My clients support the approach in Policy SS2 for principal towns Comments noted and support Pegasus Planning as centres for economic development and housing growth to welcomed. Group on behalf of cater for their own needs and the service needs of significant Mr S Goodwin and parts of the District. the Farnsworth Family Mr Michael Glover, CSFC/955 Support The Beverley South Landowner Collaboration support the Comments noted and support Michael Glover LLP strategy set out within draft Policy SS2 and wish to draw to the welcomed. on behalf of councils attention that this long formed landowner collaboration Beverley South has become very active ( working jointly with Mr John Kirkham Landowner formerly of Taylor Woodrow and now with Persimmon Homes) Collaboration, now that it seems fairly clear that the Beverley Southern By-Pass is likely to become a reality, after years of uncertainty.

Consultee/Agent ID Nature Of Response Officer Comments Response: Until such time that reasonable certainty as to the likely building of the by pass was announced , it was premature to take significant steps ( other than a previous land bid) to fully promote the area, as the potential for allocation ( principally residential) of land south of Beverley seemed unlikely without this.

In support of the direction set out within draft policy SS2 , naming Beverley as a Principal Town and the proposed distribution of development towards the Principal Towns at 43.5% of the total number of dwellings, the Beverley South Landowners believe that the south side of the town provides the most suitable margin area of the town for expansion, not least because of the proximity of this area to the town centre and the ability to link into the town centre with public transport links, ultimately combined with a Park and Ride site linked to the new by-pass.

Work is currently ongoing to work up binding legal agreements between the individual landowners and between the landowners and a developer to secure the requisite certainty that the ERYC is likely to require in the context of their Allocations DPD and the requisite further studies and justifications are now being planned to show deliverability of an appropriate scheme of development . Mr A J Hunt CSFC/1009 Observations I can raise a few issues, however, about the village where I live, Comments noted. Cottingham, and therefore I have the following comments.

I have no problem with the basic development of the village. I do believe, as I have lived in many villages in this country and abroad, that the centre of the village should be preserved as a viable shopping/social centre to maintain the community spirit. I found that villages with a good community spirit also had a village centre that attracted the local population. Consultee/Agent ID Nature Of Response Officer Comments Response: Mrs J Gill, Welton CSFC/1018 Support Settlement Network Comments noted and support Parish Council welcomed. We agree with the amended approach Mr Neil Martyn, CSFC/1025 Object The Crown Estate still consider Skirlaugh as a Primary Rural Comment noted. The growth scenarios Amec E & I UK Ltd Service Centre as opposed to a Secondary Rural Service Centre. recognise the role and function of Rural on behalf Crown As detailed in our response to the Preffered Approach Core Service Centres and Primary Villages Estate Strategy, we do have concerns over the approach taken towards (formerly Primary Rural Service the grading of Skirlaugh when compared to other settlements Centres, Secondary Rural Service such as Leven. We also believe the scale and nature of Centres and Hinterland Villages) in the development proposed will further justify Skirlaugh’s promotion overall Settlement Network. The ‘caps’ to PRSC level in the settlement hierarchy. support the overall emphasis on directing large scale development to The Crown Estate has been promoting ‘Land West of Skirlaugh’ larger higher order settlements where throughout East Riding of Yorkshire’s LDF process. there are more services, facilities and Development of the site has the potential to create a vibrant and employment opportunities. quality expansion to Skirlaugh, offering an opportunity for quality and choice in homes, environment, and local facilities. The availability of land is one factor for consideration but this needs to be Land West of Skirlaugh relates to saved housing allocation SK2 in balanced against other policy objectives. the Holderness Local Plan 1999. A Development Brief was produced by Holderness District Council in 2001 which The delivery and monitoring section of suggested 166 units could be provided on the site (at 25dph). the Draft Strategy Document sets out The site has not come forward to date due to the moratorium the potential response to under- on the development of greenfield housing allocations. This provision of housing. position has recently changed following the moratorium being lifted in October. The Crown Estate are now keen to progress this allocation in the short term to assist the Council in maintaining a 5 year supply of housing and meet the sustainable development needs of Skirlaugh. The Crown Estate is therefore keen to retain the allocation and renew it through the emerging LDF process.

As such Skirlaughs designation as a Secondary Rural Service Centre and associated growth of 10% in the size of the village Consultee/Agent ID Nature Of Response Officer Comments Response: (66 units) is too low and should be increased to reflect The Crown’s aspirations to promote and develop their landholdings within Skirlaugh.

The Crown Estate also has concerns over the setting of ridgid maximum growth levels of 20% and 10% respectively for Primary and Secondary Rural Service Centres. Although it is recognised new development does need to be proportionate to the settlement to which it relates, specifying maximum growth levels in this manner could limit the Councils ability to maintain a responsive and flexible housing supply.

This would also be consistent with guidance in PPS12 which outlines that to avoid having to frequently update core strategies, local authorities are encouraged to consider the implications of different levels of development taking place either within or beyond the core strategy period (PPS12, paragraphs 4.14-15). Through the core strategy, LPAs are also required to show what alternative strategies have been prepared to handle uncertainties and what would trigger their use. According to PPS12 (paragraph 4.46): “A strategy is unlikely to be effective if it cannot deal with changing circumstances. Core strategies should look over a long time frame - 15 years usually, but more if necessary”. It continues, “Plans should be able to show how they will handle contingencies: it may not always be possible to have maximum certainty about the deliverability of the strategy”.

It is therefore suggested the policy is amended to remove a 'maximum' limit and also sets out circumstances whereby a greater level of growth would be acceptable in these locations Mr David Graham, CSFC/1033 Object For the reasons set out above we would request that Melton / Comments noted. Nathaniel Lichfield Melton Park / North Ferriby is identified under item A3 of Policy & Partners Ltd on SS2 as an additional Local Service Centre and that this status is behalf Mr S also reflected in Figure 2 - Revised East Riding Settlement Consultee/Agent ID Nature Of Response Officer Comments Response: Prosser, St Network. Modwen Properties PLC Ms Claire Easton, CSFC/1039 Object We support the general approach as set out within the Comments noted and support Spawforths on Settlement Network (Question 2) to development and welcome welcomed. The development limits will behalf of Messrs housing growth within Haltemprice Settlements and Principal be revised through the Allocations Hick, Goulden and Towns to support the growth of services and growing Document process to accommodate the Sweeting employment within such towns. We strongly support housing scale of development set out in the growth in Local Service Centres, which provide sustainable Strategy Document. locations for growth. Policy S3 of the Draft Strategy We consider however that:- Document has been amended to refer to the Major Haltemprice Settlements, Section A should refer to “New development will be focussed Principal Towns and Towns (formerly within the development limits and as extensions to the defined Local Service Centres) as the main focus Settlement Network…” This will allow each settlement to for growth in the East Riding. promote the most sustainable ways of accommodating the requisite growth identified for the settlement but without forcing The Draft Strategy Document sets out a it to be accommodated upon important open spaces within the scale of growth for the Rural Service settlements. Centres and Primary Villages (formerly Primary Rural Service Centres, Section B should not put the Local Service Centres and Primary Secondary Rural Service Centres and and Secondary Rural Service Centres together in policy terms. Hinterland Villages) as growth over the The role of the LSCs and Secondary RSCs are very different. plan period rather than an annual Section B should be reworded “The Major Haltemprice requirement. Settlements and Principal Towns will be the main focus of growth in the East Riding, followed by the Local Service Centres. Primary and Secondary Rural Service Centres will provide for more limited development to sustain and meet the needs of rural areas”.

We agree with Section G of the Policy that the Primary and Secondary Rural Service Centres should be limited to small scale development levels which are necessary to serve the “basic Consultee/Agent ID Nature Of Response Officer Comments Response: needs” of the local community only rather than more strategic growth. We consider that the thresholds set out in Section H of the policy are correct BUT should not be requirements per annum. The words “..per annum..” should be removed and instead these should be site maximums. This would be more akin to the approach set out in Policy SS3 for Hinterland Villages. If these levels were built our per annum, then we remain concerned that this level of growth outside of the most sustainable locations is inconsistent with the overall vision of the Core Strategy and the principles of sustainable development. Mr Mark Jones, CSFC/1046 Object PLANNING POLICY CONTEXT – CROSS BOUNDARY Comments noted. East Riding of Barton Willmore WORKING (DUTY TO CO-OPERATE) Yorkshire Council has worked with Hull on behalf of Stuart City Council on supporting the Evison Regional Spatial Strategy approach taken in the respective Strategies. The Yorkshire and Humber Regional Spatial Strategy (RSS) requires East Riding to provide around 40% of its housing The option of urban extensions to Hull provision within the Hull housing market area to help deliver the was considered and rejected through core approach of focusing development on the Regional City the Further Consultation Core Strategy (RSS para 12.28). This approach is endorsed in the East Riding process. Core Strategy. One of the key strategic priorities is to It is therefore imperative that the East Riding Core Strategy support the regeneration and recognises and supports cross boundary working and that this is development aspirations within the city incorporated in to East Riding’s overall Local Development of Hull boundary. This is clearly Framework. There are suitable sustainable housing sites on the demonstrated in the emerging Strategies edge of Hull that should be afforded higher priority than other of Hull and the East Riding (as per settlements in the Core Strategy. paragraphs 44-47 of the draft NPPF).

This fundamental point is not currently being address by the Paragraph 47 of the draft NPPF enables Council which is promoting a development strategy which joint working to meet development ignores urban extensions to Hull. We expand upon this point in needs which cannot wholly be met in our representations below. We note that the Core Strategy is one area. The view from Hull City unsound on this basis as it is not in accordance with national Council is that their needs can be met Consultee/Agent ID Nature Of Response Officer Comments Response: guidance and is ineffective when compared to the alternative within the city boundaries – evidenced options. through their SHLAA.

RSS, for the purposes of the plan, defines the Regional City of Hull as all of the unitary authority area of Kingston-upon-Hull plus the adjoining settlements of Cottingham, Anlaby, Kirkella and Hessle which are in the East Riding of Yorkshire (RSS para 5.4, our emphasis). In the core approach, the Council appears to be willing to consider urban extensions to the adjoining settlements Haltemprice as listed above, but not urban extensions to other parts of Kingston-upon-Hull. No evidence is provided as to this inconsistency. We return and expand upon this point below.

Cross Boundary Working

PPS 3 requires a housing market area approach and requires local planning authorities to undertake collaborative working to ensure the government’s policy strategic objectives are achieved.

PPS 12 requires local planning authorities to bring forward plans that thoroughly consider the alternatives and which are coherent with the Core Strategies prepared by neighbouring authorities where cross boundary issues are relevant.

Draft NPPF is a material consideration. It sets out the direction of travel of Government policy and identifies that sustainable development is at the heart of the planning strategy.

Paragraphs 44-47 of NPPF expressly set out that public bodies have a duty to cooperate on planning issues that cross administrative boundaries, particularly where these relate to strategic priorities (of which housing and economic development is listed as the first bullet). Joint working is expected and local Consultee/Agent ID Nature Of Response Officer Comments Response: planning authorities are required to ensure proper coordination across local boundaries. Collaborative working is required to enable delivery of sustainable economic growth.

Paragraph 46 of NPPF requires local planning authorities to demonstrate evidence of having successfully cooperated to plan for issues with cross boundary impacts when their Local Plans are submitted for examination. Paragraph 47 enables joint working to meet development needs which cannot be wholly met within their own areas.

The PPS3, PPS12 and NPPF requirements are particularly relevant to the East Riding Core Strategy. The Council accepts that sites that are in East Riding but adjoin Hull’s boundary are the most sustainable in the district, as they maximise the accessibility to the highest order settlement. The Council has, however, not sought to test such options and instead has discounted this approach at an early stage of the Core Strategy without any evidence in support.

The Council is instead relying on a very short statement from Hull City Council which suggests that urban extensions are not needed to meet Hull’s requirements. This statement is enclosed at Appendix 1 [see attached file]. It provides no evidence as to why urban extensions are unnecessary. In accepting the comments from Hull City Council, East Riding Council has effectively ignored national guidance and the very purpose of spatial planning. We are objecting to the Core Strategy on this basis. Mr Mark Jones, CSFC/1048 Object Response to Alternative Approaches (Option A) Comments noted. The ‘Regional City’ is Barton Willmore the prime focus for development – for on behalf of Stuart Chapter 3 of the Core Strategy sets out the settlement hierarchy example, 75% of development in the Evison and development location Policy at SS2. Our client objects to Hull Housing Market Area is being Policy SS2 and Table 1. directed to Hull and the Major Consultee/Agent ID Nature Of Response Officer Comments Response: Haltemprice Settlements. The Council’s Table 1 (page 20) sets out the Preferred Approach Settlement Network. As per our representations above, RSS The RSS does not state that urban defines the Regional City of Hull as extensions around Regional Cities are a higher priority than those around “For the purposes of the Plan, the Regional City comprises all of Principal Towns. Policy YH7 takes a the unitary authority area of Kingston upon Hull plus the sequential approach to sites within a adjoining settlements of Cottingham, Anlaby, Kirkella and Hessle specific city or town – it does not within the East Riding.” prioritise between cities and towns. For example, the approach for Hull is to Policies YH4, YH5, YH6 and YH7 of RSS clearly set out the consider the re-use of previously region’s settlement hierarchy. Hull is identified as a Regional City developed land and buildings before and Beverley a Principle Town within the Hull Housing Market considering suitable infill opportunities Area (40% of growth). This is accepted by both East Riding and and then extensions to the city. Hull Hull Councils. have noted that their needs can be met through the re-use of land and infill Policy YH4 specifies that the Regional Cities (includes Kingston opportunities as well as the existing upon Hull) should be the prime focus for housing and commitments at Kingswood. employment growth. The preparation of the Further Policy YH7 of RSS provides a region’s approach to the location Consultation has been undertaken of development. This prioritises previously developed land in the through Regulation 25 which is the same City or Town as first priority, followed by infill, and the third consultation stage as the Issues and priority is listed under YH7 as: Options and Preferred Approach documents. Therefore, the option of “3. Third priority to extensions to the relevant city or town”. urban extensions has been considered as part of the preparation stage. RSS Policy YH7 further identifies the ‘transport orientated approach’ to ensure that development uses existing transport A different approach has been taken for and infrastructure and accessibility by walking and cycling. the Major Haltemprice Settlements as these are settlements entirely within the The RSS location of development strategy therefore concludes East Riding and are entities in their own that: right. This is not the case for other places on the outskirts of Hull. The Consultee/Agent ID Nature Of Response Officer Comments Response: • Kingston upon Hull should be the prime focus for housing and Major Haltemprice Settlements are employment growth; generating a need which needs to be addressed in anad aroud them whereas • RSS sets a policy framework for urban extensions around the need eminating from Hull can be Regional Cities, if land is needed beyond the priority of delivered within the city boundary. previously developed land and infill; and The Further Consultation Core Strategy • Given the definition of the Regional City of Hull, urban explicitly references the need to extensions to Hull that fall into East Riding (including the support the regeneration interventions Haltemprice areas and land which adjoins the Kingston upon Hull within the City in terms of the approach authority area) are both appropriate and the highest priority to the Major Haltemprice Settlements. (higher even than urban extensions to Principal Towns). The dynamics between the two areas are therefore noted. However, as This fundamental point has been missed by the Council. The explained above, the Major Haltemprice Council is advancing a development strategy which allows for Settlements have their own needs which urban extensions to Haltemprice settlements on the basis of need addressing (and balancing). their sustainability credentials and contribution to the regeneration of Hull, yet discounts other urban extensions to Please note that the Regional City and Hull. This inconsistency does not align with the development the Hull Housing Market Area are not strategy set by RSS as above. The plan is unsound on this basis one and the same. The latter covers a much wider geographical area as Alternative Approaches outlined in the RSS (figure 12.1) and includes Beverley, Hedon, Hornsea, Page 25 refers to Option A (Urban extensions to the City of Withernsea, Elloughton cum Brough and Hull), which the Council state was an alternative option identified numerous villages. in response to representations to the Preferred Approach Core Strategy. However, this approach has been rejected by the In respect of flood risk, the options for Council. development around Goole in areas of low risk are severely restricted. First, we are very concerned that the Council appears to have However, there is a compelling only considered this option in response to representations justification for supporting development received at the Preferred Approach stage. This aligns with our in the town based on its role, the ability concerns that urban extensions were effectively “ruled” out from to achieve sustainable development the beginning of the Core Strategy and have not been properly (flood risk notwithstanding), and the Consultee/Agent ID Nature Of Response Officer Comments Response: considered as part of the Core Strategy evidence base. It also economic opportunities presented in reinforces our comments regarding a lack of collaboration that areas. The same is true for within between East Riding and Hull Councils regarding the cross the city boundary. Around Hull boundary approach. This is contrary to national guidance and the however, there are opportunities duty to co-operate is now part of the Localisation Act 2011. around the city for development in low risk areas. Therefore, sequentially We disagree with the Council and do not consider urban preferable (national policy) locations extensions to the City of Hull to be an “alternative approach”. exist. RSS, which is part of the statutory development plan, provides a robust framework of focusing development toward the Regional The development of specific sites will be Cities and fully allows for urban extensions. The Council has considered through the Allocations accepted this within its approach to the Haltemprice settlements Document. which does allow for urban extensions, however it has failed to assess the potential contribution of other urban extensions that lie within East Riding but which benefit from adjoining the Regional City. This is a flaw in the Council’s development strategy. It is not clear why a different approach has been taken to the Haltemprice areas opposed to land elsewhere.

In respect of the Core Strategy evidence base, the Council appears not to have ‘tested’ any alternative strategy of urban extensions at all. Instead, the rationale for not considering this further appears to stem solely from a meeting with Hull City Council held in March 2011 and Hull City Council’s subsequent memorandum in reply. We enclose this at Appendix 1. [see attached file]

We set out below our response to each of the four reasons given by the Council for not pursuing urban extensions (green box on page 25), and also having regard to the memo from Hull City Council:

• There are serious concerns that urban extensions to the city would have a significant and negative impact on the Hul Housing Consultee/Agent ID Nature Of Response Officer Comments Response: Market Area. A number of the proposed extensions are very close to areas of programmed housing renewal within the city. Alowing further development immediately adjacent to the city boundary (unrelated to any East Riding settlement) wil undermine the significant public and private investment being made in renewal areas.

We are not aware of any evidence that demonstrates that urban extensions to the City of Hull will have (or potentially have) a significant and negative impact on the Hull Housing Market Area. It is unclear as to how urban extensions would undermine public and private investment being made in renewal areas, especially given the potential for private market housing to actually offer significant benefits for the wider area including areas in need of regeneration, at a time when grant funding is being cut or no longer exists. In this regard it is noted that the HCA stopped HMRI grant funding in 2011.

Hull City Council has confirmed the position regard a lack of funding for housing. In its press release dated 24 November 2011, the Council notes that:

• Hull received only £3.3m of the £6.1m it bid for from the transitional fund.

• The £3.3m transition funding will be matched by £7.1m by the Council.

• The announcement says that the funding is for Ings and Newington and St Andrews in Hull, but it is just for Ings.

• Overall, the withdrawal of HMR, private sector grant and PFI funding for Hull’s regeneration areas was estimated at over £400 million in public and £800m in private sector investment. Consultee/Agent ID Nature Of Response Officer Comments Response:

Current Position, East Hull:

• The bid for HMRTF focused on acquiring and demolishing a further 300 properties, opening up land to deliver a mix of homes for sale and rent, with the potential of a further 700 new- build homes. This plan will now be revisited, given the reduced funding allocation.

• The funding now potentially available for East Hull will fund just a small part of the planned regeneration of the area.

Current Position, West Hull:

• Working with Keepmoat as the lead private sector partner in Newington and St Andrew's, West Hull, Hull City Council was provisionally allocated £8m from Regional Growth Fund Round 1 although the bid is still going through due diligence.

• This funding will allow the next phases of regeneration to start in the Hawthorn Avenue area.

• The funding, subject to final sign approval of their RGF bid, is as follows:

o £9m will come from the Council

o £8m will come from the government's Regional Growth Fund via Keepmoat; £118m will come direct from Keepmoat (this is subject to the Regional Growth Fund bid being confirmed) to build new homes in the area.

• They envisage this will enable 224 houses to be demolished and deliver 1,475 new and refurbished eco-efficient homes in former Consultee/Agent ID Nature Of Response Officer Comments Response: HMR areas, namely Hawthorne Avenue East, Amy Johnson 2, Woodcock and Riley Village.

• The bid covers a period of 13 years, commencing in April 2011. Capital funding from RGF of £8 million is being sought for the first three years 2011-2014.

• However, with less money available, some planned clearance work will not happen, and those homes that cannot be demolished will instead benefit from frontage improvements. In addition, the bid will only fund work in one part of the Newington St. Andrew's neighbourhood and in other nearby areas the regeneration has stalled until further funding opportunities can be identified.

(Source: Hull City Council)- link as follows: http://www.hullcc.gov.uk/portal/page?_pageid=221,674011&_dad =portal&_schema=PORTAL &p_id=3509&p_month=&p_page_number=&content=pressreleas e&p_mode=result&p_keywor d=ings&p_match=title&p_theme=0)

Based on the above evidence from Hull City Council, we would context that the Council’s statement that urban extensions would undermine regeneration efforts is unfounded. It is the lack of funding that will slow these initiatives. It is in fact suggested that greenfield urban extensions will both deliver much needed housing in the Hull Housing Market Area and, have the potential to cross fund regeneration.

East Riding Council is suggesting that urban extensions in Haltemprice areas will, however, be acceptable. These are likely to be located in areas which are equidistance from Hull City Council’s renewal areas, yet these are somehow deemed not to Consultee/Agent ID Nature Of Response Officer Comments Response: have a negative impact on housing renewal whereas other extension sites would. Such locations are in the same housing market area. The Council is being inconsistent in this regard.

Hull City Council’s memo intimates that urban extensions would, impact upon their regeneration activities, suggesting that the impact would be inevitable. The note offers just one short paragraph on these concerns with no reference to any evidence whatsoever.

It is further noted that in recent years, Hull City Council has itself promoted green field urban extensions at Kingswood (planning permissions in place). Much of Kingswood is based upon the need to deliver higher quality, family and aspirational housing.

It is therefore not clear what constitutes the ‘serious concerns’ suggested in the Core Strategy.

Given that funding is being cut, urban extensions around the Regional City of Hull actually offer one way to secure regeneration funding (green field cross funding brownfield development). The Council should embrace this opportunity.

• The extensions are not required to meet the housing need generated in Hull. Hull City Council has confirmed through its emerging Core Strategy that sufficient land is available within the city boundary.

Justification for not investigating urban extensions in the earliest stages of the Core Strategy on the basis of they are not required by Hull City Council misses the fundamental point that the Regional City should be the primary focus for development and growth by both Councils. Consultee/Agent ID Nature Of Response Officer Comments Response:

Urban extensions are required by East Riding to meet its needs of focusing development within the Hull Housing Market Area. RSS requires East Riding to focus 40% of its growth into this housing market area. Irrespective of the housing needs of Hull, the focus on the Regional City as the primary location is established. Therefore at least 40% of East Riding’s housing requirements (of 1500 per year, i.e. at least 600 per year) should be focused on the Regional City. Urban extensions to Hull should therefore be considered first to meet these needs.

In respect of Hull City Council’s housing requirements, it is noted that in reporting year 2009-2010, the Council delivered - 91 net dwellings against a target in RSS of 880 dwellings (i.e. it cleared more than the net gain). Over the period 2004-2010 the Council has only delivered less than half of its requirements. Hull City Council’s 2010 AMR states:

The number of additional net dwelings completed between April 1st 2004 to March 31st 2010 is 1376. The Regional Spatial Strategy (RSS) net additional dweling requirement for the April 1st 2004 to March 31st 2010 was 2880 dwelings.

(Source Hul CC: AMR December 2010)

The Council is therefore not meeting existing requirements via its existing supply. Much of this is due to the viability issues of brownfield sites and housing market issues. Without a major change in strategy, Hull City Council will not meet its housing requirements over the next 15 years.

Overall, the justification that urban extensions are not appropriate because Hull does not need them is flawed. East Riding needs to provide extensions to meet its own needs Consultee/Agent ID Nature Of Response Officer Comments Response: irrespective of Hulls position. This need is heightened given the pressure on the Hull Housing Market Area due to Hull City Council not meeting its own requirements. Both Council’s operate in the same housing market area.

• It is not clear what need the proposed urban extensions would seek to meet. Development around Beverley and the Major Haltemprice Settlements wil meet housing needs in those areas. Elsewhere around the city, it is sparsely populated and the level of need is relatively low. Needs can be addressed through other policies, specificaly Revised Policy SS3: Development in rural vilages and the countryside, without the requirement for urban extensions around the city.

The above statement intimates that the Council’s growth strategy is only focused on meeting the needs of existing residents only in Beverley and the Haltemprice settlements. This is not true. East Riding is advocating a strategy of at least 40% of its growth into the Hull Housing Market Area rather than a much wider dispersed strategy. Similarly, the Council has not sought to develop a strategy based upon meeting local needs only in any evidence based document.

The Council’s overall strategy is policy based and seeks to direct growth towards the most sustainable locations. Greenfield urban extensions to the Regional City are the most sustainably located sites in East Riding. The housing need for urban extension stems from the Hull Housing Market Area which both Councils accept and which is enshrined in RSS’s location based approach.

• The vast majority of the urban extension options proposed are within the high risk flood zone. Along with national guidance, the East Riding’s policy approach for flood risk is to only consider sites in high risk areas where there is a lack of available sites in Consultee/Agent ID Nature Of Response Officer Comments Response: lower risk areas. For the Beverley and Central sub area, there are alternative sites available around the Major Haltemprice Settlements and Beverley that could accommodate the level of development proposed and which are in areas of lower flood risk.

The Council rightly notes that some urban areas around Hull are subject to significant flood risk. However, the Council should not be pre-determining locations of growth on solely flood risk issues at this stage as many of the other settlements which are identified for growth by the Council are subject to flood risk issues. It is not clear as to how this has been factored into the Council’s strategy. There is no evidence available that suggests broad locations for growth should be discounted on the basis of flood risk at this point.

We note that this approach has not prevented areas of growth being identified in other centres either in the East Riding Core Strategy or the Hull Core Strategy. For example, development is still being directed to Goole even though a large proportion of it lies in Flood Zones 2 and 3. In Hull, the Kingswood urban greenfield extension, supported by the Council, is entirely within areas of high flood risk.

In addition to the above, paragraph 3.21 of the Core Strategy states that the Council’s approach to managing house building in areas of high flood risk is consistent with the national approach. Thus, the Council will be ensuring that development is in accordance with PPS25. The same approach should therefore be applicable to the edge of Hull where a sequential test will be required in areas of high flood risk to ensure that a sequential approach to delivering housing growth is undertaken to ensure that the safest locations are considered first.

Consultee/Agent ID Nature Of Response Officer Comments Response: Further and in connection with our client’s land, we note that a substantial amount of land north of Cumbrian Way can be developed within any flood risk issues. The majority of the site is within Flood Zone 1. To discount this option at this stage, on the basis that other urban extension sites are generally the subject of flood risk, is a flawed approach. Our client has provided the Council with an indicative masterplan illustrating that the majority of the broad location is in Flood Zone 1

Revised Policy SS2

Overall, Policy SS2 fails to acknowledge and support growth in sustainable locations in East Riding on the edge of Hull as set out above.

Part D of Policy SS2 states that:

“The Major Haltemprice Settlements wil be a focus for development, commensurate with their role as part of the Regional City, whilst recognising the need to support the regeneration interventions within the City of Hul”.

However, The policy fails to support housing growth in other locations of East Riding which would support the role of the Regional City and would support the regeneration aims of Hull City Council.

It is our client’s position that sustainable urban extensions on the edge of Hull which support and complement the Regional City should be the focus for growth in the East Riding. Policy SS2 should be amended accordingly. Without this change, the approach to locating development does not reflect the key principles of spatial development focusing growth on major cities which provide the best access to jobs and services. Consultee/Agent ID Nature Of Response Officer Comments Response: Mr Barry Lee, Roos CSFC/1052 Support with Roos Parish Council broadly welcomes the revisions outlined in Comments noted and support Parish Council conditions the “Scale of development in the Primary and Secondary Rural welcomed. In Appendix A of the Service Centres”, Appendix A. Further Consultation Core Strategy, the current size of the settlement is defined However, Roos Parish Council seeks clarification of how the by the number of dwellings within the boundaries of Roos as a settlement are defined, for example, is it current development limits (as set out the area defined by the building development limit or some in the Holderness District Wide Local extended area which includes North End. Further we would like Plan). to know how changes to the building development limit to allow for new development are to be made. Available space within the The development limits of settlements currently described building development is extremely limited will be re-drawn through the and recent development has been approved in gardens, counter Allocations Document preparation. to the Recommendations outlined in the Village Design Statement 2003. Mr Barry Lee, Roos CSFC/1055 Observations This is currently fully developed with the exception of the Comments noted. The preparation of Parish Council Paddock on Rectory Road. the Allocations Document, thorugh which the identification of future sites Properties have been built upon garden or “backland sites” will be made, is subject to public counter to Recommendations in the Village Design Statement; consultation and East Riding of Supplementary Planning Guidance. Yorkshire Council will work with Roos Parish Council to seek their views. Roos Parish Council produced a Community Led Parish Plan in 2005, which identifies preferred building locations for Affordable Housing. These sites were each investigated in turn by the then Affordable Housing Enabling Officer.

Now in 2011, a “Refreshed” Roos Parish Plan is being developed and extensive consultation is taking place across the parish. This should identify the sites preferred by residents.

It is important that the shape and balance of the settlement is maintained and that development does not “creep” in an undesirable direction and that account be taken of Conservation Areas, tree cover and other green spaces. Consultee/Agent ID Nature Of Response Officer Comments Response:

Residents preferred sites for development may not correspond with the Land Bids for development submitted by landowners. Mr Roy Hunt CSFC/1070 Observations Perception of Bias Comments noted. The Further East Riding Council has often been accused of preferring some Consultation Core Strategy considered parts of the authority area to others. It is important therefore Gilberdyke and Newport to fulfil a that there is no perception of bias for or against any particular similar role to other settlements in the geographic area. Rural Service Centre (formerly Primary To equate Newport with major settlement areas such as Rural Service Centre) category such as Stamford Bridge and Holme on Spalding Moor asks an important Holme on Spalding Moor and Stamford question. Also, to equate the major settlements of North and Bridge. South Cave with small villages such as Eastrington and Roos seems to ask the same question. The question being; are these The identification of specific villages in decisions bought about by clinical analysis or political bias. What certain categories has been undertaken we cannot afford is either bias or the perception of bias, and for through an objective analysis and subject these reasons the questions posed need to be answered. to public consultation. East Riding of Conclusion Yorkshire Council believes a consistent We need a policy for future housing that is consistent and treats approach has been provided. all settlements based on the geographic proximity of facilities and infrastructure rather than whether these are specifically inside the settlement boundary. Where factors such as flood risk are taken into account, again, consistency of approach is important to avoid perceptions of bias. Mr Daniel CSFC/1065 Support We note this consultation covers specific further analysis and Comments noted and support welcome. Wheelwright, consideration of settlement network, the scale and distribution Ryedale District of development and development policies. Clearly we share a Council boundary at Stamford Bridge. We note that Stamford Bridge is designated as a ‘Primary Rural Service Centre’ and as set out in our draft Local Plan Strategy, we will work with East Riding of Yorkshire Council to ensure that any development is considered in a consistent and collaborative way

Consultee/Agent ID Nature Of Response Officer Comments Response:

Paragraph 3.12

Lyndsey Fielding, South Cave CSFC/536 Object 6) 3.12 appears to understand that dormitory Comments noted. Paragraph 3.12 does not Parish Council villages are not to be encouraged and is say this. However, the overall approach contrary to government policy objectives. provides homes and jobs close together, We are unclear therefore in what way acknowledging that the east-west multi-modal allowing further development in South Cave, corriodor will be a focus jor economic which serves no purpose other than a growth in the East Riding. The approach is dormitory village, furthers this policy also pragmatic in recognising that some objective development will help to meet local needs. R J Kingdom, South Cave Active CSFC/563 Object 6) 3.12 appears to understand that dormitory Comments noted. Paragraph 3.12 does not Residents villages are not to be encouraged and is say this. However, the overall approach contrary to government policy objectives. provides homes and jobs close together, We are unclear therefore in what way acknowledging that the east-west multi-modal allowing further development in South Cave, corriodor will be a focus jor economic which serves no purpose other than a growth in the East Riding. The approach is dormitory village, furthers this policy also pragmatic in recognising that some objective development will help to meet local needs.

Paragraph 3.13

Mr Milner Edward CSFC/7 Observations Villlage Limits should be flexible and include Comments noted. The development limits of all brown field sites but not green field areas villages will be determined through the Allocations Document. Mrs S Farrar CSFC/137 Support Many villages not specified by name as Comments noted. The development of recommended for development within this specific sites will be considered through the document have areas within the village Allocations Document. development limits suitable for development - that is brownfield and infill within existing The approach to development in villages is residential areas. Such infill plots should be pragmatic and small scale development will be favourably considered providing the design, supported where it is in character with the size and layout is in keeping with the area and commensurate with the size/role of Consultee/Agent ID Nature Of Response Officer Comments Response: neighbouring properties and village as a the place. whole. Such development will support pre- existing local services - post offices, pubs and primary schools, churches, shops and mobile service providers, as well as pre-existing public transport, BUT development should not be dependent upon that public transport. In many localities, reductions in council subsidies and increase in fuel costs have meant that some services have been reduced. Specific and limited development will inject new blood into village communities. These communities often include generations of families who want to remain in the village but are prevented fom doing so by the strangle hold that has been imposed as a blanket approach by the planning authority over the last few years.

Paragraph 3.14

Mrs Elizabeth Rogers CSFC/16 Support Having a development limit as proposed helps Comments noted and support welcomed. to retain the integrity of each village community and the transparency of planning policy.

Paragraph 3.15

Mr Milner Edward CSFC/8 Support Villages need extra support Comments noted and support welcomed. Mrs S Farrar CSFC/141 Support Support welcomed.

Prof Ian Reid, Beswick Parish CSFC/309 Support The designation of "Hinterland Village" is Comments noted and support welcomed. Consultee/Agent ID Nature Of Response Officer Comments Response: Council eminently sensible, providing access links such The capacity of schools has been considered as cycle/pedestrian paths are developed and through the Infrastructure Study and will be maintained and bus services are available for considered further through the development access to neighbouring Principal Towns (with of the Allocations Document. the hope of minimizing/reducing car traffic).

The question of local provision of e.g. primary school places will require consideration where provision is already at capacity or might reach capacity in future due to homes development in Hinterland Villages.

Paragraph 3.16

Mr James Fielden CSFC/76 Object Swanland is now included as a hinterland Comments noted. Swanland is within 5km of village. Which Major Haltemprice Settlement Anlaby. is the 5km measured from - Anlaby, Willerby, Kirkella, Cottingham, Hessle? Lyndsey Fielding, South Cave CSFC/550 Support with 3) There may indeed be some merit it Comments noted. A previous comment from Parish Council conditions defining a new category of village as in para the Parish Council notes that South Cave 3.16 which has good links to the regional does not fulfil a service centre role as this is cente or principle town and is 5km from the undertaken by Elloughton cum Brough. There centre, however there is a far weaker is therefore an argument that supporting argument for assuming the same relationship additional development in the service center between a Local Service Centre and a village and in proximity to it is appropriate. where links are less robust. R J Kingdom, South Cave Active CSFC/607 Support with 3) There may indeed be some merit it Comments noted. A previous comment from Residents conditions defining a new category of village as in para the Active Residents notes that South Cave 3.16 which has good links to the regional does not fulfil a service centre role as this is cente or principle town and is 5km from the undertaken by Elloughton cum Brough. There centre, however there is a far weaker is therefore an argument that supporting argument for assuming the same relationship additional development in the service center between a Local Service Centre and a village and in proximity to it is appropriate. Consultee/Agent ID Nature Of Response Officer Comments Response: where links are less robust.

Paragraph 3.17

Mr James Fielden CSFC/75 Object Villages now included as hinterland villages Comments noted. The purpose of the should have the opportunity to question the Further Consultation Core Strategy is to criteria used in the assessment. Swanland, for provide that opportunity for input. instance, is now included but how do you get to the larger centre by foot or cycle without As well as the route across the A164, there is crossing the substantial physical barrier of the a route available into Anlaby and Willerby via A164 or proceeding up/down the steep hill West Ella Road. via North Ferriby? Mrs S Farrar CSFC/138 Object Remove this altogether. Public transport Comments noted. The Strategy Document services are being reduced all the time - what needs to reflect on the evidence at the time happens if a village meets the criteria now, of its preparation. It should also be viewed as but then the services are cut - will you be a proactive document which seeks to support removing their Hinterland status? I doubt it. existing services and facilties which are Most rural village don't have cycle paths. I already in place. The Local Transport Plan will accept that the Planning Authority is trying to align its strategy (and resources) with the limit LENGTHY car journeys, but 5km? This approach set out in the Local Plan. A 5km is simply too restrictive. Surely 5-10 miles distance represents a maximum distance at would be more realistic? Just because a village which most people would replace a car is within 5km doesn't mean to say that journey with a cycle journey. The approach residents will work in that nearest settlement, does not suggest that lengthy journeys will be city, town or LSC does it, or that if they do replaced by this measure. they'll go to work on a bike? Most people live where they do because they like the village, Building regulations seek to drive the energy or are close to friends/family or it's their efficiency of new buildings and Policy ENV1 of childhood location. The Planning Authority the Draft Strategy Document supports the can insist that new development in villages are use of low carbon and renewable environmentally friendly to limit the effects - technologies. solar panels etc.

Consultee/Agent ID Nature Of Response Officer Comments Response:

Paragraph 3.18

Mr James Fielden CSFC/74 Object Surely each village which has been included as Comments noted. The purpose of the a hinterland village should have the Further Consultation Core Strategy is to opportunity to examine the criteria used to provide that opportunity for input. ensure that the assessment is accurate. The Site Assessment Methodology – which is The data used in the Site Assessment used for the Allocations Document – is Methodology should be made available for available on the council’s website and was questioning by the villages. subject to public consultation. Mrs S Farrar CSFC/139 Object The strategy should not include the need to Comments noted. The identification of Other satisfy ALL 3 criteria. The presence of a Villages (formerly Rural Villages) is based on primary school should allow that village to the presence of one of these have limited development within the village services/facilities. Limited development is development limits. More development could supported in the Villages. lead to a future village shop, and what do you specify as everyday items? Many villages have Church meeting rooms are included. The road side stalls selling vegetables, eggs etc. reference regarding a pub as a meeting place Some are served by mobile shops, library is acknowledged and this has now been services, butchers, wet fish and fried fish vans, included in the criteria for Villages. frozen goods etc. Where do you draw the line? Just because a village doesn't have a village hall doesn't mean it doesn't have a focal point for village meetings. Pubs are often used for meetings, as are churches. Should these be added to the tick list too? Mr Nicholas Spencer, Barmby CSFC/709 Observations Barmby Moor - Shop is now a haridressing Comments noted. Based on this, Barmby Moor Parish Council salon Moor no longer meets the criteria for a Primary Village (formerly Hinterland Village). - P.O existing-does not sell everyday items Consultee/Agent ID Nature Of Response Officer Comments Response:

Paragraph 3.19

Mr Ian Burnett, East Riding of CSFC/198 Observations Page 28, Paragraph 3.19 - I note that we have Comments noted and the commitment to Yorkshire Council provided safe, off-road cycle routes, through consider the approach of the Strategy LTP3, between the majority of the hinterland Document in respect of the third Local villages and their nearest Principal Town, Transport Plan is welcomed. Local Service Centre, Major Haltemprice Settlement or the Regional City. The Transport Policy Team will investigate the potential to provide safe cycle routes for the remaining hinterland villages in the next LTP3 Implementation Plan.

Paragraph 3.20

Mr James Fielden CSFC/77 Object Much more detail is required. Comments noted. In response to the consultation comments, the Draft Strategy Is the 5 dwellings criteria counted per Document merges the categories of development per annum or can there be a Secondary Rural Service Centres and number of developments of up to 5 houses in Hinterland Villages to form Primary Villages. a year? Thus, the approach for Primary Villages is to support their growth in the order of 10% There should be an agreed maximum per over the plan period. This provides clarity on village on a cumulative basis. For instance, 5 the overall scale of development expected dwellings per annum over the 15 years of the over the plan period (a figure for each village plan would be an increase of 75. The is provided in the table accompanying Policy infrastructure for Swanland could not support S5 of the Draft Strategy Document). such an increase. Policy S3 includes a reference to prioritizing The use of previously developed land should the redevelopment of previously developed be encouraged but the exclusion of gardens land and Policy H4 re-inforces this approach. from this definition must be observed as directed by the government. Consultee/Agent ID Nature Of Response Officer Comments Response:

Infill opportunities should be more clearly defined - what if the 'infill' is a garden?

The opinion of the Parish Council should be given greater weight. Mr Tom Cook, ID Planning on CSFC/219 Object One area of concern is however para 3.20, Comments noted. In response to the behalf of Landmark Development which states; consultation comments, the Draft Strategy Projects Document merges the categories of "Small-scale residential development, which Secondary Rural Service Centres and generally means proposals of no more than 5 Hinterland Villages to form Primary Villages. dwellings, will be supported in Hinterland Thus, the approach for Primary Villages is to Villages. It is expected that most proposals support their growth in the order of 10% will involve the redevelopment of existing over the plan period. This provides clarity on sites and infill opportunities. Sites will not be the overall scale of development expected specifically allocated for residential over the plan period (a figure for each village development unless the local community - is provided in the table accompanying Policy through the parish council - wish to promote S5 of the Draft Strategy Document). the development of a specific site or sites in the Allocations DPD or a Neighbourhood Development Plan."

Please note that my client does not support the wording of para 3.20.

Policy SS3 reiterates the threshold of five dwellings being appropriate in hinterland villages. We would recommend that this threshold is removed and wording inserted that at least allows for;

"Each case on its own merits dependent upon the benefits of the wider proposals". Consultee/Agent ID Nature Of Response Officer Comments Response: Mr Tom Cook, ID Planning on CSFC/223 Object One area of concern is however para 3.20, Comments noted. In response to the behalf of Key Growing Limited which states; consultation comments, the Draft Strategy Document merges the categories of "Small-scale residential development, which Secondary Rural Service Centres and generally means proposals of no more than 5 Hinterland Villages to form Primary Villages. dwellings, will be supported in Hinterland Thus, the approach for Primary Villages is to Villages. It is expected that most proposals support their growth in the order of 10% will involve the redevelopment of existing over the plan period. This provides clarity on sites and infill opportunities. Sites will not be the overall scale of development expected specifically allocated for residential over the plan period (a figure for each village development unless the local community - is provided in the table accompanying Policy through the parish council - wish to promote S5 of the Draft Strategy Document). the development of a specific site or sites in the Allocations DPD or a Neighbourhood Development Plan."

Please note that my client does not support the wording of para 3.20.

Policy SS3 reiterates the threshold of five dwellings being appropriate in hinterland villages. We would recommend that this threshold is removed and wording inserted that at least allows for;

"Each case on its own merits dependent upon the benefits of the wider proposals".

Paragraph 3.21

Mrs S Farrar CSFC/144 Object The sequential test requirement should be Comments noted. The sequential test is a removed. If someone wants to live in a requirement of national policy and is an particular location, which is within a flood risk approach used to consider areas of lower risk area, but has not been subject to flooding in the first instance. Consultee/Agent ID Nature Of Response Officer Comments Response: within the last 20 years, then the LPA should merely require flood protection in terms of Policy ENV6 of the Draft Strategy Document design and building regs - for example sets out the approach to building in areas of elevated floor heights, wiring to come from flood risk including specific site/building top down not down up, means of escape for requirements. all sleeping areas, etc. Many parts of Goole are now classed as flood risk, but in reality it's highly unlikely these areas will ever see water! Goole is in need of housing and some streets are undergoing regeneration, but they are within flood zones, so does that mean it should all stop? No! The sequential test is a nonsense.

Paragraph 3.22

Mr Milner Edward CSFC/9 Object Without developments villages will die and Comments noted. Policy S4 of the Draft the need for halls extra will not be needed Strategy Document sets out the types of but with development they may well attract development supported in Villages and the the need for this and shops etc. countryside. Mrs S Farrar CSFC/140 Object I agree with Mr Milner's comments entirely - Comments noted. Policy S4 of the Draft you're adopting a "chicken and egg" approach. Strategy Document sets out the types of It seems to me that the strategists don't development supported in Villages and the understand rural village life. Small countryside. communities can withstand infill development within the village development limits, with only beneficial effects on the communities. Controlled development provides paid employment for many local families - electricians, plumbers, builders, gardeners and garden designers, heating engineers, plasterers - they all live in villages too!!! New development brings in much needed work for Consultee/Agent ID Nature Of Response Officer Comments Response: them without having to travel out to the towns and cities. Mrs S Farrar CSFC/142 Support Para 3.18 for Hinterland villages - Comments noted. The scale of development requirement should be to meet 1 of the three proposed in the Primary Villages (formerly facilities, not all 3 Secondary Rural Service Centres and Hinterland Villages) is greater than that in Other Villages (formerly Rural Villages) so the level of services and facilities in the Primary Villages should be greater than in Villages.

Paragraph 3.23

Mrs S Farrar CSFC/143 Support Agreed - local need was a ridiculous Comments noted and support welcomed. statement that could never be proven in the way the LPA wanted it. If someone is submitting an application for a residential development - then is that not enough to show there is a need?

Development in Hinterland Villages, Rural Villages and the Countryside - Revised Policy SS3

Mr Tom Cook, ID Planning on CSFC/208 Observations Following on from this Council fully recognise Comments noted. behalf of Landmark Development that there is a need to manage growth in Projects rural service centres and supporting village which also managing, effectively development within the countryside. Mr Tom Cook, ID Planning on CSFC/209 Observations Following on from this Council fully recognise Comments noted. behalf of Key Growing Limited that there is a need to manage growth in rural service centres and supporting village which also managing, effectively development within the countryside. Consultee/Agent ID Nature Of Response Officer Comments Response: Mr Tom Cook, ID Planning on CSFC/211 Observations Policy SS3 sets out the consideration of Comments noted. behalf of Landmark Development development in locations noted as being Projects `hinterland villages'. The definition of a hinterland village whilst broad brush does enable for each settlement to be considered in respect of the role and function of each village. Naturally each settlement will be different; however the supporting text states that "some villages close to larger centres have a particular role and function". Mr Tom Cook, ID Planning on CSFC/213 Observations Policy SS3 sets out the consideration of Comments noted. behalf of Key Growing Limited development in locations noted as being `hinterland villages'. The definition of a hinterland village whilst broad brush does enable for each settlement to be considered in respect of the role and function of each village. Naturally each settlement will be different; however the supporting text states that "some villages close to larger centres have a particular role and function". Mr Tom Cook, ID Planning on CSFC/214 Object It is my client's position that recognition Comments noted. By definition, such villages behalf of Landmark Development should be made within the Core Strategy are in proximity to larger centres and Projects (and specifically Policy SS3) that where there therefore, areas of employment. In response is an existing working population, that to the consultation comments, the Draft additional residential, economic, and social Strategy Document merges the categories of development will be supported in order to Secondary Rural Service Centres and assist in supporting important local Hinterland Villages to form Primary Villages. employers. I would conclude therefore that Thus, the approach for Primary Villages is to Woodmansey is a key industrial and support their growth in the order of 10% employment hub and thus further residential over the plan period. This provides clarity on development, economic development and the overall scale of development expected local services are required in order to over the plan period (a figure for each village underpin what is a reasonably large working is provided in the table accompanying Policy Consultee/Agent ID Nature Of Response Officer Comments Response: population. S5 of the Draft Strategy Document).

An amendment should be made to Policy SS3 E to include that the development of new residential properties and local services (as noted in 3) close to major nodes of employment will be supported. Such an amendment will assist the Council in their aim of ensuring that "housing and jobs are provided together". Consultee/Agent ID Nature Of Response Officer Comments Response: Mr Tom Cook, ID Planning on CSFC/224 Observations Policy SS3 does however support economic Comments noted. Policy S4 of the Draft behalf of Landmark Development development within the countryside which is Strategy Document sets out the Projects a wide ranging definition. It would be circumstances where residential development appropriate for this definition to be widened in the countryside is appropriate and seeks to to include other means development such as ensure continued investment in the residential and new local services in order to countryside. ensure that there is additional investment within the District whilst creating more inclusive and sustainable communities. Mr Tom Cook, ID Planning on CSFC/225 Observations Policy SS3 does however support economic Comments noted. Policy S4 of the Draft behalf of Key Growing Limited development within the countryside which is Strategy Document sets out the a wide ranging definition. It would be circumstances where residential development appropriate for this definition to be widened in the countryside is appropriate and seeks to to include other means development such as ensure continued investment in the residential and new local services in order to countryside. ensure that there is additional investment within the District whilst creating more inclusive and sustainable communities. Prof Ian Reid, Beswick Parish CSFC/310 Observations The separate classification of Rural Villages Comments noted. Policy S4 of the Draft Council and "small villages and hamlets" within Strategy Document provides clarity on the Countryside is arbitrary and difficult to differences between the Villages (formerly sustain. Indeed, from the textual description it Rural Villages) and the countryside. Inevitably is almost impossible to assess how the two there will be some forms of development are distinguished in the context of future which would be supported in both. development and the subtlety of the differences will lead to confusion when future The ownership of assets is not necessarily a development proposals are assessed. matter for the Strategy Document.

The criteria for classification - having or not A list of Villages is provided in the appendices having either a village shop, or a village hall or of the Draft Strategy Document. a village school - needs finer tuning. So: Kilnwick will be designated a Rural Village because of the Old School, yet, this facility is Consultee/Agent ID Nature Of Response Officer Comments Response: not owned or controlled by the Parish Council and is a private lease by the Church of England to a group of individuals. Beswick will be designated a Rural Village while Watton will be designated as Countryside, despite having a much larger population and contributing its name to Beswick & Watton School, which lies well outside both villages.

Just as the Principal Towns, Local Service Centres, Primary & Secondary Service Centres and Hinterland Villages have been listed, so should there be lists of proposed Rural Villages and "small villages & hamlets" designated as included in Countryside. Gemma Edwardson, Edwardson CSFC/397 Object Little Driffield Comments noted. The Strategy Document Associates on behalf of S Griffin, preparation process has considered the role PPG13 states that walking is the most of settlements in proximity of larger centres. important form of transport for distances up Little Driffield does not fulfil the criteria to be to 2 km (1.24 miles) and that cycling has the considered as a Primary Village (formerly potential to replace short car journeys of up Hinterland Villages and Secondary Rural to 5 km (3.1 miles) (paragraphs 75 and 78). Service Centres).

Little Driffield is within less than a mile of The development of specific site will be Driffield Town Centre which more than considered through the Allocations satisfies the recommended walking and Document. cycling distances to replace car journeys.

At present, Little Driffield is not a ‘selected settlement’ within the proposed Settlement Hierarchy, despite the sustainability of the settlement’s location through its close proximity to a full range of services in Driffield itself. Consultee/Agent ID Nature Of Response Officer Comments Response:

The proposed amendments to the Core Strategy Further Consultation October 2011 – in particular the proposed and revised Policy SS3 is supported in principle and the introduction of this policy that supports ‘the principle of development’ in ‘Hinterland Villages’.

Hinterland Villages have a different role to Primary or Secondary Rural Service centres due to their close proximity to a Principle Town such as Driffield. Little Driffield fits this description of settlement within the hierarchy as it has a close relationship with Driffield and the services available.

Little Driffield should be identified as a Hinterland Village, as this is exactly what it is. The settlement is a supporting village to Driffield Town. Small scale development of Little Driffield will support the aims of paragraph 3.16 (page 704) of the Core Strategy Further Consultation Document (October 2011):

• Good access to services, facilities and employment opportunities in nearby larger centres (all within less than one mile);

• Opportunities for shorter journeys – potentially by means other than the car (Little Driffield has a regular bus link to Driffield);

Consultee/Agent ID Nature Of Response Officer Comments Response: • Opportunities to support existing services and facilities within the villages; and;

• A continued focused approach to housing distribution throughout the East Riding without diluting the overall strategy.

Little Driffield satisfies these objectives. Paragraph 3.19 also recognises that the ‘presence of services and facilities are perhaps less important for Hinterland Villages’ but continues to require a village shop, a village hall and a primary school to qualify.

Although Little Driffield does not have these services, they are all available within a sustainable walking distance of the site.

In addition to the service provision, the area benefits from ready and immediate access to a wealth of employment opportunities, such as the following:

• Kelleythorpe Industrial Estate – (0.6 miles)

• Driffield – (Less than 1 mile)

• Small Businesses within Little Driffield such as Line Surveys, The Rose and Crown Public House, Thompson Global Logistics and Horse Fair Garage

In order to re-introduce investment into the town, quality residential development is Consultee/Agent ID Nature Of Response Officer Comments Response: essential and this needs to include provision for housing in attractive village locations which will appeal to people seeking to start or relocate a business who regard the availability of housing meeting their aspirations as an important factor in deciding where to set up. The provision of such housing in appropriate locations is critical if Driffield is to successfully compete for footloose inward investment.

Taking these factors into account, it is considered appropriate to regard Little Driffield as a part of Driffield or adjunct to it in terms of planning for housing growth, bearing in mind the location of the village and facilities has on offer within walking and cycling distance and also the function it can serve in meeting a need for quality new housing in an attractive village environment. This is considered vital to add to the appeal of the area to business people looking to locate their business enterprise somewhere which offers top quality attractive homes in pleasant villages like Little Driffield.

Assessment

The Core Strategy confirms that there are significant housing requirements for Driffield within the plan period. Its function as a Principle Town within the East Riding is a true reflection of the town’s current role. However future inward investment is Consultee/Agent ID Nature Of Response Officer Comments Response: essential to support the town’s future. It currently acts as a service hub for a significant rural catchment area and this needs to be maintained by residential growth.

It is key to these initiatives that quality housing provision is made to ensure the investment in Driffield is enhanced and directed inwardly into the town and its immediate environs.

Little Driffield is virtually an annexe to the town in many respects and can serve an important supporting role in providing both for local needs housing and houses to appeal to people seeking a location in which to both live and work, particularly those seeking new premises or to start up a new enterprise. Making positive provision for housing land on sites like these in Little Driffield will enable a mixed, quality housing scheme to be accommodated to suit both of these categories of future residents. The residential development of the land is unlikely to result in any adverse impacts on local amenity and should be more compatible with the neighbouring land uses.

The proposal site is well within the recommended cycling and walking distances identified in national guidance and is in a sustainable location with an extensive range of services and facilities in the town. There would not necessarily be a need to use the Consultee/Agent ID Nature Of Response Officer Comments Response: private car due to the site’s proximity to employment within the town and the strong public transport links in the area.

The allocation of this site for housing is considered an important element in achieving wider objectives whilst making an important contribution to the supply of housing land required over the plan period.

The merits of individual sites – and the benefits of potentially allowing for modest growth in the smaller supporting settlements such as Little Driffield – should be taken into account in addition to general objectives relating to concentrating development to within what may be perceived as the most sustainable settlements.

If there are considered to be overarching concerns with the principle of making provision for housing growth in Little Driffield by regarding Little Driffield as an adjunct to Driffield, it is considered appropriate for Little Driffield to be included in the settlement hierarchy as a Hinterland Village as this is exactly what it is – a supporting village to Driffield. It clearly benefits from facilities in the town and the good bus service. The site will allow a degree of growth to provide housing for those employed in the town and potential future employers considering moving to the area that might prefer to live in a rural, sustainable settlement. The allocation Consultee/Agent ID Nature Of Response Officer Comments Response: of this site for housing is considered an important element in achieving wider objectives whilst making an important contribution to the supply of housing land required over the plan period.

Should there be some factor which stands strongly against either approach outlined above, it remains readily apparent that Little Driffield should not be ascribed Countryside status due to the accessibility of a full range of services within walking distance.

Conclusions

It is suggested that the provision of suitable development sites within Little Driffield should be considered to assist with the provision of housing numbers which have increased dramatically (by over 30%) as part of the more recent figures draft within the Further Consultation, particularly sites such as this that can be made available almost immediately. This site will allow a modest extension to an existing residential area, which is contained and does not encroach on the open countryside.

Quality housing development must be encouraged in Little Driffield to maintain and support the local economy and inward investment into the Town. The site and subject of this submission is ideal to meet this need and so it is requested that it be formally Consultee/Agent ID Nature Of Response Officer Comments Response: allocated for housing purposes.

Mixed housing development must be encouraged in all rural settlements to help the maintenance of sustainable communities. Without this, all settlements which are not included within the proposed hierarchy will be sterilised and become more exclusive for those who already live there.

In the case of Little Driffield, it is considered that an exception to the general policy approach is justified in any event owing to the particular circumstances of that settlement and specific increase in housing needs of Driffield. Little Driffield should be considered to effectively be a part of or adjunct to Driffield in housing policy terms to specifically provide for housing to meet the needs of business people who can then help provide for the economic growth of Driffield and so help meet wider planning objectives of the Council. The site the subject of this submission is ideal to meet this need and so it is requested that it be formally allocated for housing purposes. **please see hard copy of the response for details of the specific site mentioned** Mr Stephen Bond CSFC/400 Object I believe that the development boundary of Comments noted. In those instances where Winestead is to be removed. This may well development limits are removed, the lead to someone in the future applying for countryside element of Policy S4 of the Draft planning permission to build housing, Strategy Document will provide the especially affordable housing. The framework for considering development development boundary was established to proposals. This is a more restrictive approach Consultee/Agent ID Nature Of Response Officer Comments Response: protect and maintain the local character of in terms of housebuilding than that taken for Winestead. It was developed by people with settlements with a development limit. local knowledge and an understanding of local needs. In future this will not be the case. decisions will be made by planning officers with no local knowledge. A specific example of this local knowledge is that most of Winestead does not have a piped gas supply. Most of us have to heat our homes using oil or butane gas. Young people in need of affordable homes will not be able to afford to heat their homes as the cost of the oil is prohibitive. This year I have spent in excess of £2,500 for heating oil. This does not include the cost of electricity. Affordable homes, I think not! Mr Wayne Low, Richmond CSFC/412 Object Core Strategy Further Consultation October Comments noted. The Draft Strategy Properties on behalf of Mr David 2011 Document has been drafted in accordance Watts with the NPPF. There remains a recognition Policy SS3 Development in Hinterland of the importance of the rural economy and Villages, Rural Villages and the Countryside environment. The explanatory text accompanying Policy S4 of the Draft Strategy We object to the revised Policy SS3 on Document sets out those circumstances development in Hinterland Villages, Rural where more than one dwelling may be Villages and the Countryside. The level of appropriate within a Village. development in rural villages is limited by the policy to new housing usually comprising a In response to the consultation comments, single dwelling. This is too restrictive to the Draft Strategy Document merges the cover such large number of settlements. categories of Secondary Rural Service Comparison with the development plans of Centres and Hinterland Villages to form many other local planning authorities, national Primary Villages. Thus, the approach for planning policy and emerging national planning Primary Villages is to support their growth in policy suggest that this policy is far too the order of 10% over the plan period. This restrictive in the level of development it provides clarity on the overall scale of Consultee/Agent ID Nature Of Response Officer Comments Response: allows in rural areas. development expected over the plan period (a figure for each village is provided in the We would like to see more flexibility for table accompanying Policy S5 of the Draft development in rural areas and consider that Strategy Document). this would be in accordance with planning policy in Planning Policy Statement 4: Planning Policy H2 of the Draft Strategy Document set for Prosperous Economies (PPS4). PPS4 out an approach which considers the delivery states in paragraph 10 that to help achieve of market housing alongside affordable sustainable economic growth, the housing in rural areas. governments objectives for planning are to raise the quality of life and the environment in rural areas by promoting thriving inclusive and locally distinctive rural communities whilst continuing to protect the open countryside for the benefit of all. We consider that Core Strategy Policy is too restrictive open countryside can be protected while allowing housing development in or adjacent to rural settlements.

Planning Policy Statement 7: Sustainable Development in Rural Areas (PPS7) also provides support for our arguments in paragraph 9 that “in planning for housing in their rural areas, local planning authorities should apply the policies in PPG3. They should have particular regard to PPG3 guidance on the provision of housing in villages and should make sufficient land available, either within or adjoining existing villages, to meet the needs of local people.” Delivering such a low level of housing in rural villages and with such restrictive criteria cannot meet the needs of local people and Consultee/Agent ID Nature Of Response Officer Comments Response: accord with national planning policy.

The development of new homes and business that until previously would have been possible in rural areas will be restricted by policy SS3. This will result in settlements that are largely made up of houses being preserved in this form for the lifetime of the Local Development Framework. The effect of this will be to ensure that the villages are preserved as unsustainable locations. It will not be possible for them to grow and to become more sustainable. Settlements of this type often attract those who commute to towns or wish to retire to the countryside this excludes those who have grown up locally who become unable to find and afford local homes. As they become more exclusive these villages will lose the local working populations as the lack of facilities makes it harder for people to live and work in the countryside. In areas which are classified as countryside and where development is limited to that necessary for agriculture and forestry, there is a need for development that would allow people to both live and work in all areas of the countryside as has traditionally been possible, while at the same time protecting the countryside.

In the Government Response to the Taylor Review of the Rural Economy and Affordable Housing published by Communities and Local Government in March 2009, the government Consultee/Agent ID Nature Of Response Officer Comments Response: set out recommendations. These included that the government must recognise the need for people in the countryside to have somewhere to live and a job. The recommendations from the Taylor Review included that that rural economies are important, and that all types of businesses and enterprise can be appropriate for rural areas, subject to an assessment of impact based upon local circumstances and conditions. The government agrees with this recommendation in its response. We therefore consider that to be sound and to be in accordance with national planning policy the Core Strategy should go further in the support of business and housing development in rural areas. Without these changes the Core Strategy will not be sound and it will not be the most appropriate strategy when considered against reasonable alternatives and it will not be flexible.

Rural policies such as that proposed in SS3 will prevent rural areas from sustaining themselves as they have done in the past. Policies such as SS3 which seek to achieve sustainable development mean that development in the countryside will be severely restricted. Sustainable development is often interpreted in a way that seeks to put all but essential agricultural development in urban areas. The draft National Planning Policy Framework and other government statements such as “Planning for Growth” Consultee/Agent ID Nature Of Response Officer Comments Response: seek to put economic development at the heart of sustainability. Sustainable development is not possible without economic development and in rural areas this means allowing housing growth.

Policy SS3 part E states that a number of different uses can be accommodated in rural villages including affordable housing. But market housing is also needed to meet the needs of local people. This is recognised in the draft National Planning Policy Framework which in paragraph 112 recognises that “in rural areas, local planning authorities should be responsive to local circumstances and plan housing development to reflect local requirements, particularly for affordable housing. Local planning authorities should in particular consider whether allowing some market housing would facilitate the provision of significant additional affordable housing to meet local needs.”

This demonstrates the difficulty of the Councils approach of severely limiting the delivery of market housing in Rural Villages and focussing on the delivery of affordable housing. Market and affordable housing are often required to be delivered hand in hand if any housing at all is to come forward.

Policy SS3 should be changed to allow the development of more homes including small estate developments within or adjoining Consultee/Agent ID Nature Of Response Officer Comments Response: settlement boundaries so that rural areas can sustain themselves through new development as they always have done in the past. Joanne Hodgson, Yorkshire CSFC/498 Observations The policy should include a statement to say Comments noted. Other policies in the plan Wildlife Trust that development will only be supported in set this out – see policies ENV2 and ENV4 of these areas where it will not have a the Draft Strategy Document. detrimental effect on the landscape or areas of high biodiversity value. Lyndsey Fielding, South Cave CSFC/552 Object 5) There is some argument to be had as to Comments noted. It is agreed that South Parish Council whether South Cave should be included in Cave should be considered as a Hinterland para 3.20 and new policy SS3,B as a Village (now known as Primary Village) due to Hinterland village rather than a SRSC (which its proximity to Elloughton cum Brough. It it is clearly not). The Market place cross meets the criteria established. roads to Brough town Centre as defined in the town centre plans is 4.86km. The arguments against including it as a hinterland village from the criteria list in 3.16 are that; the car is still the only reasonable method of getting to Elloughton Brough to access services. There are some buses but only at peak and Sunday buses no longer run. The former A63 road to Elloughton Brough could not be described as a good pedestrian cycle link to Elloughton Brough. There is limited employment oportunities and Melton Park will not provide the types of employment required to be able to live in South Cave. South Cave is a long distance commuter village. Lyndsey Fielding, South Cave CSFC/553 Object 6) Small scale development restriction would Comments noted. In response to the Parish Council be supported in Hinterland villages, however consultation comments, the Draft Strategy the policy is silent on multiple sites or Document merges the categories of Consultee/Agent ID Nature Of Response Officer Comments Response: numbers over time. Reference to ensure that Secondary Rural Service Centres and the overall spatial strategy is supported is Hinterland Villages to form Primary Villages. fairly broad and unconvincing. Thus, the approach for Primary Villages is to support their growth in the order of 10% over the plan period. This provides clarity on the overall scale of development expected over the plan period (a figure for each village is provided in the table accompanying Policy S5 of the Draft Strategy Document). Lyndsey Fielding, South Cave CSFC/554 Support 7) We support the proposed policy SS3. C to Comments noted. Across the board, the Parish Council involve the Parish Councils in any allocations input of town and parish councils is important in these villages. for the preparation of the Allocations Document which will identify specific sites for development. R J Kingdom, South Cave Active CSFC/610 Object 5) There is some argument to be had as to Comments noted. It is agreed that South Residents whether South Cave should be included in Cave should be considered as a Hinterland para 3.20 and new policy SS3,B as a Village (now known as Primary Village) due to Hinterland village rather than a SRSC (which its proximity to Elloughton cum Brough. It it is clearly not). The Market place cross meets the criteria established. roads to Brough town Centre as defined in the town centre plans is 4.86km. The arguments against including it as a hinderland village from the criteria list in 3.16 are that; the car is still the only reasonable method of getting to Elloughton Brough to access services. There are some buses but only at peak and Sunday buses no longer run. The former A63 road to Elloughton Brough could not be described as a good pedestrian cycle link to Elloughton Brough. There is limited employment oportunities and Melton Park will not provide the types of employment required to be able to live in South Cave. Consultee/Agent ID Nature Of Response Officer Comments Response: South Cave is a long distance commuter village. R J Kingdom, South Cave Active CSFC/611 Object 6) Small scale development restriction would Comments noted. In response to the Residents be supported in Hinterland villages, however consultation comments, the Draft Strategy the policy is silent on multiple sites or Document merges the categories of numbers over time. Reference to ensure that Secondary Rural Service Centres and the overall spatial strategy is supported is Hinterland Villages to form Primary Villages. fairly broad and unconvincing. Thus, the approach for Primary Villages is to support their growth in the order of 10% over the plan period. This provides clarity on the overall scale of development expected over the plan period (a figure for each village is provided in the table accompanying Policy S5 of the Draft Strategy Document). R J Kingdom, South Cave Active CSFC/612 Support 7) We support the proposed policy SS3. C to Comments noted. Across the board, the Residents involve the Parish Councils in any allocations input of town and parish councils is important in these villages. for the preparation of the Allocations Doument which will identify specific sites for development. Gemma Edwardson, Edwardson CSFC/832 Object The comments detailed below are made in Comments noted. The Strategy Document Associates on behalf of Client response to the amended proposed policies provides the strategic steer for guiding Unknown, and changes to the Core Strategy since the development across the plan period. last publication. This submission relates Considering the merits of developing specifically to the settlement of North individual sites without considering the Frodingham and the future of this village for overall strategy is not an appropriate potential housing development in the light of approach. the revised proposed policies. The 5km is not applied to Rural Service NORTH FRODINGHAM SETTLEMENT Centres because they are service centres in themselves and the methodology used is not The revised Core Strategy has taken on seeking to uncover their relationship to larger board concerns raised relating to the future settlements. The Hinterland Villages (now Consultee/Agent ID Nature Of Response Officer Comments Response: of smaller settlements by including two part of the Primary Villages classification) further levels of settlement within the were identified in recognition that Network/Hierarchy. This policy in principle opportunities for certain levels of (SS3) is supported and vital to secure a level development are appropriate in villages close of growth in rural villages. to larger centres which have a larger range of services, facilities and employment The introduction of Hinterland Villages and opportunities. The use of a 5km threshold is Rural Villages is strongly supported. entirely appropriate in this instance. North Frodingham did not meet the criteria for The selection criteria applied to determining either level of the network. Using the criteria, Hinterland Villages is narrow and does not it is neither a Rural Service Centre nor a consider the future vitality and viability of village which benefits from being proximate many rural settlements. The selection process to a larger centre. A 5km distance represents means that North Frodingham, despite the a maximum distance at which most people village’s services and employment would replace a car journey with a cycle opportunities does not qualify as a Hinterland journey. Village. We strongly object to the settlement status of North Frodingham simply being The Draft Strategy Document has taken ascribed “Rural Village” status (Policy SS3: account of the final NPPF. Development in Hinterland Villages, Rural Villages and the Countryside).

This suggested policy approach centres on applying an across the board ‘formula’ taking no account of the overall characteristics and needs of the settlement of merits of individual sites. Some settlements may have the capacity to accommodate more houses without undue detriment as there are several sustainable sites available whilst others may have few opportunities for housing without seriously impacting on its essential character. The detailed site assessment and allocation process may well reveal that releasing more Consultee/Agent ID Nature Of Response Officer Comments Response: land through allocating sustainable sites in some of the Primary and Secondary Rural Service Centres, Hinterland Villages and Rural Villages will avoid the need to allocate far less suitable sites elsewhere, to the benefit of the overarching objectives underpinning good planning.

The detailed analysis of sites at the allocations stage may also indicate that the smaller settlements can offer a more sustainable development option than simply expanding the major settlements and principal towns onto peripheral green field sites. Being able to walk into a smaller settlement to use and support the various services and facilities in the village is likely to often prove more sustainable than people living on housing developments remote from a town centre where all services are only realistically accessible by private car. It is suggested, therefore, that the proportion of new houses to be provided for in the various settlement categories should not be prescribed at this stage but would best be determined following the more detailed assessment of the comparative benefits of developing the many housing land options/sites available across the area.

The introduction of Revised Policy SS3 is supported in principle along with the removal of the originally proposed policy that only affordable and/or local needs housing will be Consultee/Agent ID Nature Of Response Officer Comments Response: appropriate; however, the proposed status of North Frodingham is not.

HINTERLAND VILLAGES SELECTION CRITERIA

Hinterland village status must be given to settlements that have good provision of and access to services, facilities and employment opportunities in nearby larger centres. North Frodingham does have a good provision of services, facilities and employment in the village itself and nearby.

The proposed criteria stipulates that Hinterland Villages must be within 5km of a Major Haltemprice Settlement, Regional City, Principal Town or Local Service Centre. This is considered too restrictive and is also not applied to Secondary or Primary Rural Service Centres.

Settlements such as North Frodingham which have their own services and employment opportunities must not be prohibited from becoming a Hinterland Village simply because of being outside of a nominal 5km distance to a larger settlement. Particularly in North Frodingham many smaller local businesses are operated either from home or business premises providing immediate local employment and include:

• Renewable Energy Business Consultee/Agent ID Nature Of Response Officer Comments Response: • Public House • Post Office/Village shop • Cherry’s Hardware and Agricultural Services and Fuel Station • Fruit and Vegetable Farm Shop • Various Farm Businesses and Agricultural Operations • Deep litter Poultry • Plumbing and Electrical Services • Building Services (Various) • MOT and Car Repairs (Garage Services) • Turf and Landscaping Business • Carpet and Upholstery Business • General Odd Job/Services • Painting and Decorating • Cleaning Services • Playgroup • Primary School • Social Centre and Children’s playground • St Elgin’s Church • Playing/Sports/Football/Cricket Grounds

The village has a community which works from home and provides mobile services to the local area. This community service and level of self employment is characteristic of the village and other similar settlements. It is essential that this settlement is therefore recognised as an employment generating area independently and defined at least Hinterland Village status.

Although the village is not within 5km of the larger centres – it is still a sustainable location Consultee/Agent ID Nature Of Response Officer Comments Response: and future development would not be “unsustainable”. It is closer to the principal town of Driffield than the Rural Service Centres like Beeford, Wetwang and Kilham and, on the face of it, is equally or more sustainable than these settlements and so warrants a status as a Rural Service Centre.

The presence of services and facilities should not be considered “less important for Hinterland Villages”. This comment is strongly resisted. The future growth of settlements is essential in order to achieve the overall aim of the policy: “to support a vibrant Countryside”. This community is vibrant and must therefore be supported by allocating future growth.

North Frodingham does satisfy the remaining criteria. The village does have a village shop, village hall and primary school – as well as many more services.

NATIONAL PLANNING POLICY CHANGES

The amendments to PPS3 including the downgrading of garden land to greenfield status and the relaxation of high density thresholds means that the potential for windfall housing is significantly reduced in rural settlements. In the light of these National Planning Policy changes it is therefore nonsensical to prohibit the future Consultee/Agent ID Nature Of Response Officer Comments Response: housing allocations of a settlement such as North Frodingham so significantly.

The application of a restrictive policy simply allowing single dwellings in all settlements within this category does not consider the settlements identity, requirements or likely future prospects. Each settlement should be considered individually, as previously handled in order to establish future levels of growth for example; the services such as primary schools, infrastructure and housing demand should not be ignored.

CONCLUSIONS

North Frodingham is a self-sufficient and sustainable village that should at least be defined as a Hinterland Village or a Primary/Secondary Rural Service Centre.

The application of the selection criteria is narrow and rules out this thriving settlement due to its proximity to the larger settlements being over 5km. In reality, North Frodingham has a high level of services – which are very important as well as a high level of self employment which is characteristic of the East Riding.

In addition, the proposed “Hinterland Villages” are all located in the Beverley and West Hull (Swanland and North Ferriby) areas. There is limited provision for Consultee/Agent ID Nature Of Response Officer Comments Response: Hinterland Villages in the Driffield and Hornsea area other than Nafferton. This is not acceptable and it is felt that these areas will be disadvantaged as a result.

It is hoped that this response to the proposed changes is considered and supported by Officers. Gemma Edwardson, Edwardson CSFC/833 Object The comments detailed below are made in Comments noted. The Strategy Document Associates on behalf of Client response to the amended proposed policies provides the strategic steer for guiding Unknown, and changes to the Core Strategy since the development across the plan period. last publication. This submission relates Considering the merits of developing specifically to the settlement of Rudston and individual sites without considering the the future of this village for potential housing overall strategy is not an appropriate development in the light of the revised approach. proposed policies. The 5km is not applied to Rural Service RUDSTON SETTLEMENT Centres because they are service centres in themselves and the methodology used is not The revised Core Strategy has taken on seeking to uncover their relationship to larger board concerns raised relating to the future settlements. The Hinterland Villages (now of smaller settlements by including two part of the Primary Villages classification) further levels of settlement within the were identified in recognition that Network/Hierarchy. This policy in principle opportunities for certain levels of (SS3) is supported and vital to secure a level development are appropriate in villages close Consultee/Agent ID Nature Of Response Officer Comments Response: of growth in rural villages. to larger centres which have a larger range of services, facilities and employment The introduction of Hinterland Villages and opportunities. The use of a 5km threshold is Rural Villages is strongly supported. entirely appropriate in this instance. Rudston did not meet the criteria for either level of The selection criteria applied to determining the network. Using the criteria, it is neither a Hinterland Villages is narrow and does not Rural Service Centre nor a village which consider the future vitality and viability of benefits from being proximate to a larger many rural settlements. The selection process centre. A 5km distance represents a means that Rudston, despite the village’s maximum distance at which most people services and employment opportunities does would replace a car journey with a cycle not qualify as a Hinterland Village. We journey. strongly object to the settlement status of Rudston simply being ascribed “Rural Village” The Draft Strategy Document has taken status (Policy SS3: Development in Hinterland account of the final NPPF. Villages, Rural Villages and the Countryside).

This suggested policy approach centres on applying an across the board ‘formula’ taking no account of the overall characteristics and needs of the settlement of merits of individual sites. Some settlements may have the capacity to accommodate more houses without undue detriment as there are several sustainable sites available whilst others may have few opportunities for housing without seriously impacting on its essential character. The detailed site assessment and allocation process may well reveal that releasing more land through allocating sustainable sites in some of the Primary and Secondary Rural Service Centres, Hinterland Villages and Rural Villages will avoid the need to allocate far less suitable sites elsewhere, to the benefit of the Consultee/Agent ID Nature Of Response Officer Comments Response: overarching objectives underpinning good planning.

The detailed analysis of sites at the allocations stage may also indicate that the smaller settlements can offer a more sustainable development option than simply expanding the major settlements and principal towns onto peripheral green field sites. Being able to walk into a smaller settlement to use and support the various services and facilities in the village is likely to often prove more sustainable than people living on housing developments remote from a town centre where all services are only realistically accessible by private car. It is suggested, therefore, that the proportion of new houses to be provided for in the various settlement categories should not be prescribed at this stage but would best be determined following the more detailed assessment of the comparative benefits of developing the many housing land options/sites available across the area.

The introduction of Revised Policy SS3 is supported in principle along with the removal of the originally proposed policy that only affordable and/or local needs housing will be appropriate; however, the proposed status of Rudston is not.

HINTERLAND VILLAGES SELECTION CRITERIA Consultee/Agent ID Nature Of Response Officer Comments Response:

Hinterland village status must be given to settlements that have good provision of and access to services, facilities and employment opportunities in nearby larger centres. Rudston does have a provision of services, facilities and employment in the village itself and nearby.

Settlements such as Rudston which have their own services and employment opportunities must not be prohibited from becoming a Hinterland Village. Particularly in Rudston many smaller local businesses are operated either from home or business premises providing immediate local employment and include:

• All Saints Church • Garage / Motor Repairs Business • Shop • Bosville Arms -Public House and Country Hotel / restaurant • Thorpe Hall • Thorpe Hall Caravan and Camping Site • Village Hall – recently refurbished Consultee/Agent ID Nature Of Response Officer Comments Response: • Pre School Club in the Village Hall – Local School is Boynton • Hairdressing Salon • Tony Hogan Studio & Art Gallery • Archomai – Based at East Farm, Rudston

Local people are employed in the immediate area and the assumption that those who live in these types of settlement will travel to nearby Towns such as Bridlington for work is not a true reflection of the sustainability of the area. Although Bridlington is only 7km (4.4 miles) from the village, many residents either work from home or are employed locally.

Villages such as Rudston have a community that also works from home and provides mobile services to the local area. This community service and level of self employment is characteristic of the village and other similar settlements. It is essential that this settlement is therefore recognised as an employment generating area independently and defined at least Hinterland Village status.

Although the village is not within 5km of the larger centres – it is still a sustainable location and future development would not be “unsustainable”. It has public transport links via the 124 bus to Driffield and Bridlington.

The presence of services and facilities should not be considered “less important for Consultee/Agent ID Nature Of Response Officer Comments Response: Hinterland Villages”. This comment is strongly resisted. The future growth of settlements is essential in order to achieve the overall aim of the policy: “to support a vibrant Countryside”. This community is vibrant and must therefore be supported by allocating future growth.

Rudston does satisfy the remaining criteria apart from the primary school requirement. Boynton School is the nearest primary school which is only 2 miles away and within cycling distance of the village. The village does have a village shop, village hall and pre-school service available at the Village Hall itself– as well as many more services.

NATIONAL PLANNING POLICY CHANGES

The amendments to PPS3 including the downgrading of garden land to greenfield status and the relaxation of high density thresholds means that the potential for windfall housing is significantly reduced in rural settlements. In the light of these National Planning Policy changes it is therefore nonsensical to prohibit the future housing allocations of a settlement such as Rudston so significantly.

The application of a restrictive policy simply allowing single dwellings in all settlements within this category does not consider the Consultee/Agent ID Nature Of Response Officer Comments Response: settlements identity, requirements or likely future prospects. Each settlement should be considered individually, as previously handled in order to establish future levels of growth for example; the services such as primary schools, infrastructure and housing demand should not be ignored.

CONCLUSIONS

Rudston is a self-sufficient and sustainable village that should at least be defined as a Hinterland Village or a Secondary Rural Service Centre.

The application of the selection criteria is narrow and rules out this settlement due to its proximity to the larger settlements being over 5km. In reality, Rudston is a village community with a level of services which are very important. The settlement as has a level of self employment which is characteristic of villages in this part of the East Riding.

It is not a true reflection of the East Riding to expect that all employment will be generated in the Principal Towns and Service Centres. In fact, a large proportion of employment is generated through small rural businesses which are based either from home or out of small rural offices.

The East Riding has no City, Airport or major rail link to any of the regional centres and this Consultee/Agent ID Nature Of Response Officer Comments Response: is why so many people chose to live and work in rural areas. This is in itself can be a sustainable and it is unrealistic to expect all future growth, for housing and employment to be focused in the few Principal Towns, Major Haltemprice Settlements and Local Service Centres.

In addition, the proposed “Hinterland Villages” are all located in the Beverley and West Hull (Swanland and North Ferriby) areas. There is limited provision for Hinterland Villages in the Driffield and Bridlington area other than Nafferton. This is not acceptable and it is felt that these areas will be disadvantaged as a result.

In principle, the introduction of new settlement categories is supported but those selected do not provide a balanced geographical coverage of the East Riding. The criteria that requires the village to be within 5km of a Principal Town, etc is limiting the selection of other worthy settlements such as Rudston. Mr Paul Forshaw, BNP Paribas CSFC/976 Support CSL’s previous representations to the Core Comments noted and support welcomed. Real Estate on behalf of Centrica Strategy requested that changes were made Storage Limited (CSL) to Policy SS3 to allow for the development of essential infrastructure in the countryside. In particular, CSL requested that the policy was amended to provide flexibility to allow for the development of energy related uses and associated infrastructure in countryside locations. Consultee/Agent ID Nature Of Response Officer Comments Response:

As this stated above, this change was requested because such uses often require rural locations and are not always suitable in urban areas. CSL’s previous representations pointed to the fact that gas energy will remain a considerable part of the UK’s energy mix for the foreseeable future. Representations therefore requested that this policy allowed for general energy developments in the countryside and did not restrict this to renewable energy developments only.

The requested changes have been made to this policy, and CSL now therefore supports Policy SS3. It is considered that the changes made to the policy provide the flexibility to allow for energy development and related infrastructure in rural areas, and therefore assists in ensuring that energy needs of the Region and the UK are met. As such, the policy as amended is now considered to be sound.

Question 3

Mr Pete Sulley, Barton Willmore CSFC/821 Support Settlement Network – Question 3: There is Comments noted and support welcomed. on behalf of The Kingswood general support for the revised approach to Parks Development Company Hinterland Villages, Rural Villages and the Ltd Countryside. Mrs Elizabeth Rogers CSFC/17 Support with Close scrutiny and detailed supporting Comments noted and support welcomed. conditions evidence of some of the proposed development criteria in section E will be Consultee/Agent ID Nature Of Response Officer Comments Response: necessary to ensure that only genuine applications are approved. Mr Brian May CSFC/24 Observations Watton and Beswick share facilities that Comments noted. Facilities some distance would make the difference between being a from the Village are not counted. Watton has Rural Village or Countryside. In the case of been identified as a Village (formerly known Beswick and Watton School, the school is as Rural Village) whereas Beswick has not. between both villages but comes under Beswick Parish. This could lead to the anomally of the physically larger village of Watton being considered Countryside whilst the smaller Beswick is seen as Rural. Recognition of shared amenities should be taken into account in this sort of case. Mrs M. Greenwood, North CSFC/56 Observations The Parish Council assumes that under the Comments noted. In response to Dalton Parish Council new hierarchy it would be classed as a Rural consultation comments, public houses have Village since it has a village hall. been included in the list. North Dalton has been identified as a Village (formerly known The Parish Council thinks that you should as Rural Village). also consider public houses as apposite pertinent features when assessing whether villages are Rural Villages or Open Country. Mrs Claire Boston, Bempton CSFC/62 Support We strongly agreed with the removal of the Comments noted and support welcomed. Parish Council 'local needs clause'.

Bempton needs the flexibility with the plans between being a rural village and boarding on being a 'Hinterland' village. Mr James Fielden CSFC/78 Object No I do not agree - much more Comments noted. See other comments in information/clarification is required as response to Mr Jame Fielden. mentioned in my specific comments. Ms Nicola Salvidge, Seaton PC CSFC/87 Observations As before you need to remove this groups Comments noted. A strategic steer needs to Consultee/Agent ID Nature Of Response Officer Comments Response: and treat each as an individual this can not be set out to provide a consistent framework work as a blanket document. for decision making. Pat Lambert, North Ferriby CSFC/94 Support with We feel that as there is no sites allocated in Comments noted. In response to the Parish Council conditions North Ferriby at present and none are consultation comments, the Draft Strategy proposed, the practical implications of the Document merges the categories of policy as stated are not much different from Secondary Rural Service Centres and the previous draft. However, the overall Hinterland Villages to form Primary Villages. numerical assumptions suggest that there Thus, the approach for Primary Villages is to could be large amounts of housing support their growth in the order of 10% development in some Hinterland villages, and over the plan period. This provides clarity on imply more development than may be the overall scale of development expected achievable under the terms of the detailed over the plan period (a figure for each village policies for individual villages. Therefore, in is provided in the table accompanying Policy addition to reducing the numbers of houses S5 of the Draft Strategy Document). to be accommodated in this general category, we would like to see a commitment to establishing an overall maximum number of houses in the plan period in each of the Hinterland villages, to be agreed with parish councils. Mr P. Crossland, Rudston Parish CSFC/123 Observations When development limits are bieng drawn Comments noted. The development limits of Council for the village, we would want the Parish villages will be determined through the Council to have a substantial involvement in Allocations Document. The parish council will the decision on where the line is drawn, and have an opportunity to input into this. would like that to be stated explicitly in the LDF document. Mr P. Crossland, Rudston Parish CSFC/124 Object We are very concerned that the LDF does Comments noted. Policies in the Draft Council not intend to delineate areas within the Strategy Document set out a range of criteria countryside where development should be for considering development proposals in restricted. Whilst we appreciate that there different parts of the East Riding. For are national policies that could overule local example, Policy ENV2 identifies important policies, we believe that not drawing up landscape areas and Policy ENV5 sets out an Consultee/Agent ID Nature Of Response Officer Comments Response: guidelines for the development of energy and approach to safeguarding important nature economic developments causes substantial conservation sites. aggravation and cost. We strongly believe that there should be areas of the East Riding, especially the Wolds, that should be given protection from developments that detract from the current landscape and views. Mr J Winterbottom CSFC/130 Observations The sensible approach would be to restrict Comments noted. The focus on promoting development to the areas which are in a development in areas which have a degree of reasonable position to connect with transport public transport links can be seen through the routes. As with the "Principal" towns, many of Draft Strategy Document. the villages are also totally unconnected in feasibility for expansion as per my assessment in question 4. Mrs S Farrar CSFC/145 Object I see no benefit from having separate rules for Comments noted. In response to the rural villages and those you term Hinterland consultation comments, the Draft Strategy Villages. A village is a pre-existing settlement. Document merges the categories of Where development is within the confines of Secondary Rural Service Centres and the village devlopment boundary line, with Hinterland Villages to form Primary Villages. preference to infill and brownfield, in keeping with the character and apearance of the Policy S4 of the Draft Strategy Document neighbouring dwellings and village as a whole, provides the framework for considering it should be supported. All villages are dying development in Villages (formerly Rural because of the strangle hold the LPA has Villages) and the Countryside which includes placed on it over the last few years. New life supporting infill development. is needed and new development brings with it employment opportunities for tradesman living in these villages, as well as supports local services. Scrap the term of Hinterland altogether, and consider all villages in the same way. Mr J. Willingham, Bilton Parish CSFC/151 Observations Bilton is surrounded with agricultural land to Comments noted. The Draft Strategy Consultee/Agent ID Nature Of Response Officer Comments Response: Council the north, south and east of the village. We Document does not support large scale would like some clarity that these parcels of housing developments around Bilton. No land are not up for change of use to allow allocations are proposed on the basis current large scale housing development to be built evidence regarding the level of flood risk in within the time scales of this Core Strategy the village. (2028) also 3.20 mentions permissible infill developments. B.P.Council have previously Proposals for the development of gardens map planning applications for developments would need to satisfy a number of policies in within gardens which have been declined. We the Draft Strategy Document including Policy hope this trend will continue, we would ENV1 on integrating high quality design. welcome a definition of infill. The above concerns also apply to Wyton and Ganstead which are also within our parish. Mr R Andrew CSFC/154 Object (i) Why do we have villages? Historically Comments noted. The overall strategy seeks these were built to house the workforce (eg. to minimise the need to travel and ensure agriculture, coal mining, fishing) that homes and jobs are provided in close proximity. The overall figure for Howden is (ii) How many people today work in the place largely determined by the numbers of homes where they live? already with planning permission.

(iii) What are the figures for Howden? Why build 893 houses?

(iv) Rural post offices, shops and pubs are closing. Cllr John Whittle CSFC/178 Observations We need to accept that development should Comments noted. The Strategy Document take place in the smaller settlements on a provides a framework for considering basic level of need. The Sustainability Matrix proposals in a consistent manner which is was too stringent and ran the risk of essential for a functional planning system. The becoming a “self-fulfilling prophecy” or a Draft Strategy Document has been drafted in “Catch 22”. I feel that, after viewing a manner which represents the ‘development numerous planning applications passed against management’ approach as opposed to the the the Officers’ recommendation on the grounds ‘development control’ approach. Consultee/Agent ID Nature Of Response Officer Comments Response: of “infill”, “local need”, “planning gain” etc., that a common sense approach is required. The arbitrary judgements of village halls, shops, pubs, garages and primary school are a rule of thumb, but cannot convey the “feel” of the community. This is where local knowledge and Ward Members’ input is invaluable. With reference to “Hinterland Villages”, I could argue the case for Seaton and Sigglesthorne in my Ward. They share a garage and garage shop (“Mace”), they have a footpath directly into Hornsea, Sigglesthorne has a Primary School and Seaton has a pub and Village Hall. There are regular bus services, a.m. and p.m. Neither settlement could be considered unsustainable; indeed Sigglesthorne has a fairly large housing development in situ.

However if one was to accord these two villages a “hinterland” status, how long would it be before unacceptable development linked the two and they lost their discrete identities? Perhaps it would be better to maintain them as mere “Countryside”, with the option for acceptable low-level development on an ad hoc basis. Mrs Sara Towne, Skirlaugh Parish CSFC/216 Support Skirlaugh PC agrees with all of these Comments noted and support welcomed. Council proposals Mr Tom Cook, ID Planning on CSFC/226 Support with With respect to Question 3 therefore my Comments noted and support welcomed. behalf of Landmark Development conditions client welcomes a number of points however Projects further changes should be made to the Core Strategy top enable a more flexible approach Consultee/Agent ID Nature Of Response Officer Comments Response: to development to be achieved based on the merits of each proposal. Policy SS3 therefore requires further amendment for greater flexibility in order to support existing sites and locations that have a large working and resident population. Mr Tom Cook, ID Planning on CSFC/227 Support with With respect to Question 3 therefore my Comments noted and support welcomed. behalf of Key Growing Limited conditions client welcomes a number of points however further changes should be made to the Core Strategy top enable a more flexible approach to development to be achieved based on the merits of each proposal. Policy SS3 therefore requires further amendment for greater flexibility in order to support existing sites and locations that have a large working and resident population. Mr Mark Nicholson, Smiths Gore CSFC/254 Support with We also welcome the proposal that some Comments noted. Shiptonthorpe does not on behalf of Client Unknown conditions limited form of development; individual meet the full criteria for consideration as a houses as well as affordable housing might be Primary Village (formerly Hinterland Villages permitted on the edge of Rural Villages. and Secondary Rural Service Centres). There is no primary school in Shiptonthorpe. We accept that it may not be possible to 'name' all potential 'Rural Villages' at this stage but are surprised that Shiptonthorpe has not been included in the list of potential 'Hinterland Villages'.

Shiptonthorpe

- Strategically located close to the junction of the A1079 and A614; -Conveniently situated about 3,2kms from Market Weighton and 8kms from Pocklington Consultee/Agent ID Nature Of Response Officer Comments Response: [both Local Service Stations]; - Has a good range of local services which includes a village hall, two restaurants and a public house, a garage and a 'Garden Centre' the facilities of which include a restaurant, a coffee shop, and a `Farm Shop' -selling every day items-in addition to the `Garden Centre Shop', and - Has good public transport links.

To reiterate, although we welcome the Council's proposals for `limited form of development' in 'Rural Villages' our contention is that the Council should adopt a more `reactive and flexible policy' to development and consider each scheme on its' own merits, taking into account the design, size, scale and specific location of each proposal in relation to the village. Elizabeth Woollias CSFC/257 Object I note that under this new designation our Comments noted. In those instances where small village of Winestead-which is in a development limits are removed, the Conservation area- is to have its development countryside element of Policy S4 of the Draft boundary removed and this proposal- to Strategy Document will provide the remove development boundaries-is proposed framework for considering development for other villages and hamlets re-defined as proposals. This is a more restrictive approach "Countryside". in terms of housebuilding than that taken for settlements with a development limit. I also note that in the Countryside there are 10 exceptions to the rule that no forms of development will be supported and one of these is, "affordable housing for local people".

It is therefore likely that, in the future, someone will propose building affordable Consultee/Agent ID Nature Of Response Officer Comments Response: housing in Winestead and when they do so the village will not be protected by a development boundary. If you look at the map, the Patrington-Winestead Inset map which can be found at http://www.eastriding gov. uk/planning/pdf/holderness/frset.html you will see that the development boundary covers a much smaller area than the conservation area boundary. It most particularly prevents development along the east side of Bydales Lane and also prevents any development stretching back on the western side.

This development boundary was established with local knowledge of the character of housing in Winestead- and has served as a protection to maintain its local character. In future times, planning officers with no knowledge of local planning history and who are, understandably, using most of their resources to investigate major developments, will-be considerably handicapped from making informed decisions.

I have looked at the maps showing the development boundaries of other small- villages and it is very clear that they have proved a most effective protection from sprawling development.

Why remove a safety net that has protected villages from inappropriate development?

Consultee/Agent ID Nature Of Response Officer Comments Response: Please will the Council reconsider its proposal to remove development boundaries from all small settlements which are to be designated as "Countryside", Stephen Worth CSFC/258 Object I enclose a copy of the letter sent to you by Comments noted. In those instances where Elizabeth Woollias concerning the removal of development limits are removed, the the development boundary in Winestead. Ms countryside element of Policy S4 of the Draft Woollias that, if possible, this boundary Strategy Document will provide the should be kept in place. The special framework for considering development characteristics of the village have been, by and proposals. This is a more restrictive approach large, well protected by existing development in terms of housebuilding than that taken for boundary, why change what is working well? settlements with a development limit. Cllr Iain McKechnie, Wilberfoss CSFC/269 Object The significant increase in allocations is likely Comments noted. The Strategy Document Parish Council to lead to ‘un-controlled’ housing growth provides the strategy for considering with little or no ‘local need’ being identified. development so that it is not ‘un-controlled’. Rosemary Jordan-Jackson, CSFC/289 Object Swanland Parish Council has severe concerns Comments noted. In response to the Swanland Parish Council over the complete reversal of our position consultation comments, the Draft Strategy with regard to further development in the Document merges the categories of village through the suggestion in the Core Secondary Rural Service Centres and Strategy to designate Swanland as a Hinterland Villages to form Primary Villages. “Hinterland Village”. Until October 2011 we Thus, the approach for Primary Villages is to were advising applicants that no increase in support their growth in the order of 10% the number of houses would take place in the over the plan period. This provides clarity on village for the foreseeable future. Several the overall scale of development expected recent planning applications for extra houses over the plan period (a figure for each village were refused on this basis. Indeed an extant is provided in the table accompanying Policy planning permission which came up for S5 of the Draft Strategy Document). renewal this year was also refused. The scale of housing development proposed The Parish Council had now reached a point through the Draft Strategy Document is where we can say categorically that there will lower than previous rates of development. be no further development for the short to Consultee/Agent ID Nature Of Response Officer Comments Response: medium term. We are defined under policy The Infrastructure Study has considered the DS4 and H7 of the Joint Structure Plan (JSP) impact of furture development on the as being a village where effectively no market infrastructure of Swanland and further work housing increase can take place. This is in will be undertaken through the preparation of response to input from many people in the the Allocations Document. village asking for a slow down in the pace of development and to pause so that the village Proposals for the development of gardens can mature, taking in the rapid change over would need to satisfy a number of policies in the recent years. There have been large the Draft Strategy Document including Policy numbers of houses built on several estates ENV1 on integrating high quality design. over the last two decades expanding the village to its present size. In the last two big Across the board, the input of town and developments in the village; parish councils is important for the preparation of the Allocations Document • the Parish Council had to fight to reduce which will identify specific sites for the number of dwellings the developer development. The allocation of sites, which wanted to put on the Westfield Farm Estate may accommodate more than 5 dwellings will Final Phase as the number being proposed provide a greater opportunity to deliver would take the combined total well above the much needed affordable housing in the village number set out in the original planning in comparison to smaller infill plots. permission for the whole of the site. • on St Mary’s Walk in the large garden of the main house and the subsidiary bungalow, 37 units were built.

There was strong opposition in the village to the size and scale of both of these developments and particularly the effect on the environment of the loss of green space in the village centre. In the end the PC were unable to prevent the conversion of the garden to this house.

The effect of these decisions was to galvanise Consultee/Agent ID Nature Of Response Officer Comments Response: opposition to further development and a heightened awareness of the changes to the landscape of the village centre. Whilst currently we are told that the health provision is able to cope, the school is under severe pressure for places for children in the village and this has been put forward in the past as justification for refusal of planning permission for extra dwellings in Swanland. The infrastructure is also under pressure and we have problems with drain covers being forced off in stormy weather and in parts of the village there is very low water pressure. Any significant increase in the number of dwellings in Swanland would require further investment in utilities. Land values in Swanland are very high and there is continual pressure from developers to build as there is always demand for more luxury dwellings in the village. The recent history of planning in Swanland is that there have been permissions for the demolition of dwellings for rebuilding and also the extension of bungalows by creating a first floor to convert to a larger house. The adoption of the policy DS4 of the JSP gave a clear demarcation on where and what could be built and so any application which resulted in increasing the number of units in the village was able to be refused. This was supported by the results of Appeals to the Planning Inspectorate.

The Parish Council would want to retain this situation where we can control the number Consultee/Agent ID Nature Of Response Officer Comments Response: of sites coming forward. The Council is in the best position to understand the feelings of the residents and determine the amount of development in the future. Nationally there is pressure to devolve decision making to the lower tiers of government and the Parish Council should have more say in the way that the planning system controls the expansion of the settlement.

The publication of the draft Further Consultation on the Core Strategy which redefines Swanland as a Hinterland Village and therefore a village which can support further development, has already resulted in approaches being made by several developers who wish to take advantage of the change in village status. The first planning application quoting the new Policy SS3 of the Core Strategy has been received only 6 weeks after the publication of the revised Policy. It is expected that further applications will be made in the near future.

Whilst the Parish Council would not want the village to be “preserved in aspic”, the development pressure is such that any relaxation of the status conferred by DS4 of the JSP will be difficult to control unless there is a protocol in the Planning Department on how many units of housing can come forward in any one year of the plan period. At present all rural villages under the proposed Policy SS3 would have a very small increase in Consultee/Agent ID Nature Of Response Officer Comments Response: housing of single units. If Swanland had the Hinterland Village designation removed there would still be small scale development in the village under the new policy but the larger developments would be restricted. The Parish Council needs a definition on how many units in total can be built over the plan period.

This also applies to the suggestion that Hinterland Villages can support the development of sites for up to five houses. What is not defined is whether this is five dwellings per year or five over the plan period. Assurances have been given verbally that it does not mean five per year but no other control has been specified. In the case of Swanland, it is anticipated that there will be pressure to build up to the maximum.

Swanland has a relatively high number of large executive style houses in comparison with surrounding villages. The land available is so valuable that developers find that they have to build this type of house rather than a larger number of smaller houses as in the past. There is a shortage of affordable homes and social housing for young people who want to stay in the village as they are unable to get on the property ladder. The building of houses with shared equity and other arrangements would help to alleviate this problem and this should be explicitly encouraged in the policy.

At the Forward Planning Consultation event Consultee/Agent ID Nature Of Response Officer Comments Response: for Parish and Town Councils, the concerns of the parish over the pressure for development were raised. The only suggestion put forward to control the amount of new housing coming forward was to designate more parts of the village as “Areas of Common Character”. The Parish Council have found in the past that this is not clearly defined and provided the proposed housing is on a large plot the planning officer has difficulty in refusing the application and risking a later approval by the Planning Inspector. A clearer definition is needed to determine that any housing built as infill or on available plots is in keeping with the size and distribution of the existing housing stock. The use of the term “Area of Common Character” has been found to be defective in preventing plot splitting/ infill in the past in areas of the village with that designation.

The definition of a Hinterland Village is defective in practical terms. In the case of Swanland, Para 3.16 states that “sustainable development will be supported in selected 'Hinterland Villages' that are within 5km of the centre of a Major Haltemprice Settlement or the Regional City, a Principal Town, or a Local Service Centre. This 5km zone reflects the maximum cycling distance set out in the LDF Site Assessment Methodology (March 2011)”. Swanland is within 5 km of the Major Haltemprice Settlements but to rely on the fact that it is possible, though quite Consultee/Agent ID Nature Of Response Officer Comments Response: dangerous, to cycle to these settlements is not taken into account. Very few cyclists would attempt to go in to Anlaby, our nearest point, by cycling down Tranby Lane particularly at peak times when there are large numbers of parents in big cars rushing to get their children to the private school on this road. There is a bus service which takes some passengers in to Hull to work but the vast majority (>90%) leave the village by car and add to the traffic pressure on the surrounding roads and tow/city centres. The adoption of a policy to increase the number of houses in commuter villages will only exacerbate this problem and greatly increase the amount of commuting.

No definition of what is “sustainable development” is given and in the case of Swanland all village services are viable and in some cases over subscribed. It would therefore be wrong to believe that the village needs further housing to maintain these services.

Many of the concerns outlined in our response could be reduced if there was a change to the wording of Para C. in Policy SS3. It states: “Residential allocations for development will be considered favourably in these villages where they are promoted by the Parish Council.” The inclusion of the word “only” between “villages” and “where” so that the paragraph would read “Residential Consultee/Agent ID Nature Of Response Officer Comments Response: allocations for development will be considered favourably in these villages only where they are promoted by the Parish Council.”

This would give a greater degree of confidence that the future growth of the village could be controlled by the Parish Council with its local knowledge and ability to respond to local opinion and needs. Developers would have to come forward with proposals that had the support of the village rather than Policy interpretations from a distance. This would also chime with the Localism Agenda now being promoted by central Government

We would ask that::

• the inclusion of Swanland as a Hinterland Village is dropped from the Core Strategy. • the Parish Council is given a greater control in allowing development to take place. • clearer definitions are needed of the terms used in Policy SS3 to describe the number of dwellings to be built in the plan period. • A reduction in the amount of commuting should be one of the objectives of the new policy Mr Robert J Tulpin CSFC/292 Other I am writing to express my concerns Comments noted. In those instances where regarding proposed changes to the development limits are removed, the development boundary in relation to small countryside element of Policy S4 of the Draft villages. Local Development Framework: its Strategy Document will provide the effects on small villages and hamlets to be framework for considering development Consultee/Agent ID Nature Of Response Officer Comments Response: reallocated as countryside. My main concern proposals. This is a more restrictive approach is for my own village of Winestead (which is a in terms of housebuilding than that taken for designated conservation area) is to have its settlements with a development limit. development boundary removed under this proposal. I am concerned that in future this may lead to the development of affordable housing for local people. As a resident of the village and a qualified conservationist I find this very difficult to accept. The development boundary and conservation area status is fundamentally important because it proptects the heritage of the village. I see no sensible reason to make these changes as there is no demand for affordable housing in the village itself due to a lack of industry. The infrastructure is inadequate to support development of this type. If anything, the Council should be seeking to increase the protection and conservation of this area and the surrounding small villages and hamlets. Winestead has a mixture of woodland, open farmland and properties with sizeable gardens, making it a genuine haven for wildlife. Please reconsider the proposal to remove the development boundary from all small settlements and the reallocation to countryside. Angela Wilkinson, East Riding CSFC/301 Support The East Riding Transport Partnership Comments noted and support welcomed. Transport Partnership welcomes the support for certain forms of development in the Countryside, in that this will benefit the rural economy with only a marginal increase in vehicle movements. Mrs Joy B Harris, North CSFC/302 Other 1. The Council is broadly in agreement with Comments noted and support welcomed. Consultee/Agent ID Nature Of Response Officer Comments Response: Frodingham Parish Council the Core Strategy but deplores the decision The criteria in relation to ‘demonstrating a to remove 'need for' as a criteria for local need’ on an individual property basis is development. 2. The Council is in agreement potentially inconsistent with national policy. with the designation of North Frodingham as a non-selected settlement for development. The Strategy Document will set the planning The village/parish is still trying to overcome framework and the purpose of the problems caused by its considerable consultation is to solicit views from a wide expansion when developers were allowed to range of people including parish councils and build small estates of 4/5 bedroom houses on developers. The Draft Strategy Document the old pig farms, when the need was for balances the views and responds to the smaller, less expensive properties. 3. The evidence to set the framework. Council wonders how this elaborate strategy will be enforced if the developers are not in A delivery and monitoring section in the agreement. Will they build where you want Publication Draft Strategy Document sets out them to, or will they target the more a number contingencies. profitable open countryside? Will there be carrots and sticks applied? 4. On a general Information from the Infrastructure Study has point, having read through the statistical considered the issues such as the capacity of analysis on which this strategy is based, the schools. Council wondered what contingency plans you have made if the forward projections are The development limits of villages will be wrong? 5. You seem to have applied three determined through the Allocations criteria to some of your decisions, presence Document. The parish council will have an of a school, village hall and shop, have you opportunity to input into this. considered the quality, capacity, or viability of each in your long term strategy?

These were the main points discussed at its meeting last evening; the Council also urged that the development boundaries be reviewed as soon as possible and would very much like to meet with a planner for preliminary discussions. Mark Lane, DPP on behalf of Mr CSFC/305 Other We do not object to this policy indeed we Comments noted. Consultee/Agent ID Nature Of Response Officer Comments Response: Jonathan Atkinson, J G Hatcliffe actually support the principle as rural villages and Partners also need some development in order to ensure that these settlements remain vibrant and attractive places in which to live. However we seriously question the appropriateness of making an allowance for such development in Policy SS4 we will turn to this in relation to question 4. Mr P. Wharton, Skidby Parish CSFC/320 Support The Council has considered the consultation Comments noted and support welcomed. Council documents and tow members have taken the opportunity to attend the seminar.

We are pleased that Skidby is to be designated as a Rural Village and that the only development which would be considered is small scale infill. The infrastructure within the village, especially foul water drainage, would not support anything larger. John Downing, Rollits Solicitors CSFC/338 Support We agree with the changes to the rural Comments noted and support welcomed. on behalf of East Riding settlement policy as it is re-formulated. Securities Limited Economic activity needs to be enhanced throughout the rural hinterland to ensure it wellbeing. Development activity is one ingredient in a successful local economy. This policy shift should contribute to this end. N Rowland, Savills CSFC/392 Support with We welcome the recognition that is now Comments noted and support welcomed. conditions given in the Council’s revised Core Strategy The Draft Strategy Document has been document to the fact that there are a range prepared to offer clarity on the approach. It of villages which lie within the hinterland of re-classifies Hinterland Villages and Secondary the regional city (Hull and the Haltemprice Rural Service Centres as one category – settlements) which have a distinct role to play Primary Villgaes. The policy approach for the in delivering sustainable development for the former Secondary Rural Service Centres has Consultee/Agent ID Nature Of Response Officer Comments Response: future. been taken forward for this category (10% growth or 85 over plan period). This provides We also note that the Council considers that a guide for the scale of development these villages have a particular role and supported over the plan period. function and that they are able to accommodate small scale residential development and help promote a continued focused housing distribution across East Riding. The recognition that Swanland is one such village is also welcomed in principle on this basis.

However, we are concerned at the rather artificial distinction the Council is seeking to draw between these villages and other villages across East Riding and we consider the identification of this additional tier has resulted in a rather confused settlement hierarchy.

In order for the Core Strategy to be found sound it needs be justified and have a credible evidence base. The Council needs to justify why this distinction needs to be made, particularly when taking Swanland as an Consultee/Agent ID Nature Of Response Officer Comments Response: example, this significant settlement with a population of 3,500 (some 1500 dwellings) containing a range of facilities and local employment, scores highly in terms of providing a sustainable location for future development. Indeed, it has been recognised in previous Local Plans as providing a sustainable location for development, (with the allocation of housing sites) and it lies in a key public transport corridor and has a school. It clearly performs a function as a service centre, independent of the regional city. Given the role that this settlement performs it should be able to accommodate housing growth in a similar way to the Secondary Rural Service Centres.

Furthermore, whilst we agree that Hinterland Villages should be identified within the Core Strategy we have concerns regarding the wording of Policy SS3 which states that residential developments will be small scale and ‘usually no more than 5 dwellings’.

The 5 dwellings limit has not been justified by any evidence that this restriction on numbers in such settlements is necessary. The Council notes that development will come forward with ‘the redevelopment of existing sites and infill opportunities on sites within these villages’. On this basis there is no reason to impose an artificial restriction on numbers. If the site presents a sustainable development opportunity within the built up area of a Consultee/Agent ID Nature Of Response Officer Comments Response: settlement and is supported by relevant development management policies then it should be allowed to come forward for development.

We note that the Council’s policies in respect of Primary and Secondary Rural Service Centres seek to limit the growth to such villages and appendix 1 sets out the implications for each settlement over the plan period. It is not clear however, from SS3 whether a cap is intended to apply to the Hinterland villages. I note table 3 sets out that the hinterland villages, rural villages and the countryside will accommodate 12% or some 3060 homes to 2028. This level of housing is supported, but it is clear that the policy approach towards the Hinterland Villages needs to be unambiguous to set a robust framework for development management decisions, particularly as SS3 states that housing allocations will be considered favourably where they are promoted by a Parish Council.

In addition, we have some difficulty with the proposed wording of SS3 in respect of the approach to housing allocations as it suggests that they will only be permitted if they are ‘promoted’ by Parish Councils, when clearly there may be other individuals, private landowners who would seek to bring land forward, which may gain local community support, but may be prevented from doing so Consultee/Agent ID Nature Of Response Officer Comments Response: on the strict interpretation of this wording.

Moreover, there may be sites such as previous Local Plan Allocations in village locations (such as Swanland) which have been supported in the past and which can be rolled forward and do not necessarily need to be explicitly ‘promoted’ by the Parish Council in order to be favourably considered. We are concerned therefore at the overly restrictive use of the word ‘promoted’. Whilst there is no doubt that neighbourhood planning is part of the new planning system, it may not be relevant in all cases that a Parish Council is equipped able/willing to promote a site. We can understand the emphasis for local support in the policy, but it would be unreasonable to restrict suitable sites which meet sustainable development objectives from being allocated. Again the policy needs to be unambiguous in this respect. Ms Felicity Clayton, Hornsea CSFC/386 Support Yes Comments noted and support welcomed. Area Renaissance Partnership Miss K. E. Laister, Ferriby CSFC/401 Support with 1. It seems sensible to separate these Comments noted and support welcomed. In Conservation Society conditions Hinterland Villages from more rural villages. response to the consultation comments, the Draft Strategy Document merges the 2. It is good to see (in part C) "favourable categories of Secondary Rural Service consideration" being given to "residential Centres and Hinterland Villages to form development where promoted by the parish Primary Villages. Thus, the approach for council". It is important to take local views Primary Villages is to support their growth in seriously. the order of 10% over the plan period. This provides clarity on the overall scale of 3. Does "in the development limints" (in part development expected over the plan period Consultee/Agent ID Nature Of Response Officer Comments Response: B) refer to the present limits? In the case of (a figure for each village is provided in the North Ferriby, this is important. We feel table accompanying Policy S5 of the Draft strongly that there should be no more Strategy Document). development between the present main village built-up area and Hessle; nor should As a result, the extent of development limits there be any encroachment on open spaces of villages will be revised through the to the west and north. Allocations Document. The parish council will have an opportunity to input into this. 4. Within the present limits of North Ferriby village there is very little land available for development. Unless other villages under Policy SS3 have much more land available, it seems that it will not be possible to find enough land for the number of new houses now suggested for these villages and countryside. Ms Sarah Belton, Airmyn Parish CSFC/419 Object Do not agree. Comments noted. Council This is too open ended and does nothing to protect rural villages from business invasion. It appears that anything goes. Ms Rachel Douglas, Gladman CSFC/420 Object Residential development within the Comments noted. A delivery and monitoring Hinterland Villages, Rural Villages and the section in the Draft Strategy Document sets Countryside should be considered by the out a number contingencies. Council where there is evidence to demonstrate a shortfall in supply and there are no available, suitable or sustainable sites in accordance with the settlement hierarchy set out in Policy SS2 or the Contingency Policy promoted by the representation to Policy SS4.

Resoned Justification Consultee/Agent ID Nature Of Response Officer Comments Response:

The proposed changes to Policy SS3 seek to clarify the type of development that will be considered acceptable within Hinterland Villages, Rural Villages and the Countryside. Whilst we support the Council’s approach to controlling the form and scale of development in these locations it should be recognised that during the plan if there is a shortfall in housing delivery then residential development in the locations should be considered.

If there is evidence to demonstrate that there is a shortfall in housing delivery (ie. less than 5 year supply) and there are no available, suitable or deliverable sites in accordance with the settlement hierarchy set out in Policy SS2 or the Contingency Policy proposed by our representation to SS4, then sites within Hinterland Villages, Rural Villages and the Countryside should be considered to see whether they are capable of meeting the identified housing need. In order for development to be acceptable in such locations it would be necessary to demonstrate the development would be sustainable and there would be no adverse impacts on the environment. Mr C. Cromack, Preston Parish CSFC/440 Support Yes - subject to affordable housing meeting Comments noted and support welcomed. Council the needs of the residents of Preston. J T Smallwood, CSFC/457 Object May I appeal for the relaxation of village Comments noted. Policy S4 of the Draft developments to allow selected sites within a Strategy Document sets out the framework Consultee/Agent ID Nature Of Response Officer Comments Response: non development village to be privately for supporting development in small villages developed. Sites which would not extend or and the countryside. detract from the "village scene"

Sites to be under the control of village parish councillors.

This type of development would prevent this type of village becoming museums to the 70s & 80s.

To stifle all development until at lest after 2028 will result in a stagnant village scene.

I maintain decisions should be made by local people who have an interest in their village and not in by councillors etc. in remote offices, who have not got a local knowledge.

This relaxation would also create work for small local builders,(I was one but am now retired) who cannot take on larger local authority works. Mr & Mrs Harrison CSFC/459 Object I have read the Core Strategy Consultation Comments noted. The risk of flooding and Summary Document and note that Preston is infrastructure issues have been considered again mentioned for possible further building through the preparation of the Strategy development. Document.

I must stress that the infrastructure in Preston cannot cope with further development of any size. The road network is very poor and parking is becoming a major problem with many now parking on pavements. The main street through Preston Consultee/Agent ID Nature Of Response Officer Comments Response: is clogged up several times a day with all the school traffic, school buses and heavy goods vehicles which use Staithes Road/Weghill Road as a designated HGV route. The pavements in the Main Street are very narrow and more traffic can only cause further problems especially for school children walking to both South Holderness and Preston Primary schoosl.

It must be noted that parts of Preston have been flooded in the recent past and no remedial action has been taken to alleviate the problem.

There is an on going problem with the drains on East End Road/Weghill Road and any further building working which would link up with the existing drains can only compound the problems.

I hope the Council will have re‐ think about further development in Preston. Mr John Ackerley, Yapham cum CSFC/464 Support with Yes, but could be too restrictive. Rural Village Comments noted and support welcomed. Meltonby Parish council conditions development limits require re-examination - many of these villages need additional properties to bolster churches, village halls, bus routes (existing but empty in many cases), postal services, general community activities, etc. Also many of these villages have empty/brownfield sites suitable for odd properties - aiding all above plus providing houses that are NEEDED in these places. Consultee/Agent ID Nature Of Response Officer Comments Response: Mr Geoff Prince, Geoffrey Prince CSFC/465 Object We also consider that the RSCs and Comments noted. The Draft Strategy Associates Ltd on behalf of Supporting Villages (SVs) should be merged Document amends the names of the Client Unknown, into one category – these settlements are all categories to help understand the different fairly similar in terms of size, role and roles. Rural Service Centres (formerly function – the Council are trying to be too Primary Rural Service Centres) are those clever in trying to distinguish between them! villages which complement the network of The new category of Hinterland Villages higher order centres in locations which (HVs) should also be incorporated into this provide a geographic spread. They support a category of RSCs, and also relabelled Service small rural catchment beyond their own Villages. Again they all have similar range of communities. Primary Villages (formerly services and population – in some cases the Secondary Rural Service Centres and HVs are larger than the RSCs listed in Table Hinterland Villages) are those villages which 1. If these HVs are only allowed to grow by 5 have basic services and facilities but which are dwellings over the plan period, then it is clear not necessarily geographically positioned in that they will gradually lose services – they terms of meeting needs beyond their own will be unable to rejuvenate themselves and communities. Some of the Primary Villages the they will develop increasingly older (formerly the Hinterland Villages) also benefit population age profiles. It is important that from good access to larger neighbouring such settlements are kept alive, and do not centres which do perform a service centre just become dormitory settlements for role. neighbouring PTs. Comments noted. In response to the Rather than determining the scale of consultation comments, the Draft Strategy development in such settlements (refer Document merges the categories of Annex A), the market should be allowed to Secondary Rural Service Centres and determine the level of housing in these Hinterland Villages to form Primary Villages. settlements within broad parameters. We Thus, the approach for Primary Villages is to propose that all RSCs, SVs and HVs should be support their growth in the order of 10% encouraged to grow by between 10% and over the plan period. This provides clarity on 20% over the plan period in terms of overall the overall scale of development expected increase in the number of dwelling units over the plan period (a figure for each village based on market interest and availability of is provided in the table accompanying Policy suitable sites. Why, for example, should S5 of the Draft Strategy Document). growth in South Cave be limited to less than Consultee/Agent ID Nature Of Response Officer Comments Response: 10% when it is one of the most attractive The approach for Primary Villages (formerly places to live, close to the strategic road Secondary Rural Service Centres and network and jobs along the A63/M62 Hinterland Villages) is now set out in Policy 3 corridor, and where there are already an of the Draft Strategy Document. excellent range of shops, services and also good public transport links. Similarly why limit Further guidance on the approach to growth in Woodmansey to just 5 houses over supporting economic development in rural the plan period –the settlement is effectively a areas is set out in Policy EC2 of the Draft suburb of Beverley with two major Strategy Document. employment parks (Tokenspire and Lakeside), with excellent public transport, walking and cycle path links to Hull and Beverley along Hull Road, and boasting a good range of local services.

Policy SS3 should also be revised to omit Hinterland Villages, as these will now be included in Policy SS2 as Service Villages.

With regards to Section E of Policy SS3 , we note and welcome the inclusion of economic development as development which will be supported in the countryside. We would like to see further amplification of this reference to economic development in the supporting text, as follows:

‘Proposals for economic development in the countryside will be supported , particularly where it can be demonstrated that the proposed development is in a sustainable location, with good public transport links and walking and cycling connections to nearby population centres, and also where it involves Consultee/Agent ID Nature Of Response Officer Comments Response: providing alternative jobs to those which have been lost in recent years, particularly in the agricultural and horticultural industries. The Council will also welcome proposals for economic development which result in environmental improvements arising from the demolition of former glasshouses which have reached the end of their economic lives. In order to ensure the viability of such proposals, some higher value uses may be permitted to enable improvements to the local infrastructure to be funded.’ Mr Malcolm Shute, Malcolm N CSFC/474 Support with We in principle agree with and support the Comments noted. In response to the Shute on behalf of Mr & Mrs A conditions amended approach to the Hinterland and consultation comments, the Draft Strategy W Kay Rural Villages policy SS3 but note an apparent Document merges the categories of contradiction to the approach to policy SS2 Secondary Rural Service Centres and that seeks to impose an annual limit on Hinterland Villages to form Primary Villages. development in terms of % or numbers of Thus, the approach for Primary Villages is to units. No such restriction is suggested for the support their growth in the order of 10% Hinterland villages, with SS3 part (b) only over the plan period. This provides clarity on limiting units to "usually no more than 5 the overall scale of development expected dwellings" this creates the potential effect over the plan period (a figure for each village that Hinterland Villages could grow more is provided in the table accompanying Policy rapidly than SRCS which appears to be S5 of the Draft Strategy Document). inconsistent with the intended hierachy. Mr M Bottomley, Dacres CSFC/486 Object We note that the proposed Policy approach Comments noted. In response to the Commercial on behalf of Redrow to the Hinterland Villages would allow small consultation comments, the Draft Strategy Homes (Yorkshire) Ltd scale residential development of up to 5 Document merges the categories of dwellings and potentially supports the Secondary Rural Service Centres and allocation of housing land where supporting Hinterland Villages to form Primary Villages. by the parish council. We would express Thus, the approach for Primary Villages is to concern that this approach has potential to support their growth in the order of 10% overlap with the approach to the Secondary over the plan period. This provides clarity on Consultee/Agent ID Nature Of Response Officer Comments Response: Rural Service Centres which would further the overall scale of development expected encourage dispersed patterns of residential over the plan period (a figure for each village development within rural areas. We is provided in the table accompanying Policy recommend that this approach is reviewed in S5 of the Draft Strategy Document). order to better reflect the spatial hierarchy set up under proposed Policy SS2. Keith and Lyn Gilby, CSFC/494 Object Having read this proposed planning Comments noted. The risk of flooding and consultation, I wish to put forward my infrastructure issues have been considered concerns with regards to further house through the preparation of the Strategy bilding in the village of Preston. I see on page Document. 6 Preston is classified as a hinterland village an as such the proposals are for less than 5 The approach to supporting affordable dwellings, small scale developments to housing is similar to the approach currently involvethe redevelopment of existing sites or used. infill opportunities. With affordable housing possibly being supported on the edge of For the purposes of the Local Plan, reference hinterland villages. There are already existing to Preston regards Preston village (north). affordable homes within this village that remain empty, any further building of new homes will put the infrastructure of this village underextream pressure. The roads are already over crowded, more housing equals more pressure on a school that is not big enough as itis. This village has flooded in the past, more homes puts more pressure on the drainage system, and increases the risk of further flood risks. Preston is a village of 2 halves, one half (Preston South) does have access to amenities such as shops, petrol station, bus rutes and easy access into Hull, but the other half of the village (Preston North) does not. Mrs Moira Gittins CSFC/503 Object I would like to comment on the above Comments noted. For the purposes of the Consultee/Agent ID Nature Of Response Officer Comments Response: consultation re- Hinterland Village PRESTON. Local Plan, reference to Preston regards Preston village (north). The village of Preston is a village that is in two parts Preston (north) and Preston South. I The risk of flooding and infrastructure issues live in Preston (north) this part of the village have been considered through the has a major traffic problem, a crossroads with preparation of the Strategy Document. lights in the centre of the village that is so narrow that the traffic lights have to operate The development of specific site will be by letting traffic through the village one road considered through the Allocations at a time. There are 4 (B) roads that meet at Document. this point. The paths are also very narrow. I would object to any building in Preston (north) due to the major problem we already have with the road network.

The village has in the past flooded and further development would put extra strain on the already streched drainage system.

The fields around Preston are full of History and wildlife again this would be destroyed by further building.

The nearest large supermarket ,petrol station and main bus route is NOT located in this part of the village,it is 3 miles away in Preston South.

Again not walking distance and would generate the use of private cars adding to the existing problem with traffic in the village.

There are whole developments in this village that are stood empty and have been for some Consultee/Agent ID Nature Of Response Officer Comments Response: time. Property prices here are cheap and there are many properties for sale here. Why build more ????

I would object to further building in Preston and hope the forward planning team will consider the points I have made. Mr Tom Cook, ID Planning on CSFC/505 Support with Policy SS3 sets out the consideration of Comments noted and support welcomed. behalf of Ben Bailey Homes conditions development in locations noted as being (Yorkshire) Limited `hinterland villages'. The definition of a hinterland village whilst broad brush does enable for each settlement to be considered in respect of the role and function of each village. Naturally each settlement will be different; however the supporting text states that "some villages close to larger centres have a particular role and function".

It is my client's position that recognition should be made within the Core Strategy (and specifically Policy SS3) that where there is an existing living and working population, that additional residential, economic, and social development will be supported in order to assist in supporting important local employers.

I would conclude therefore that Melton is a key industrial and employment hub and thus further residential development, economic development and local services are required in order to underpin what is a reasonably large working population.

Consultee/Agent ID Nature Of Response Officer Comments Response: An amendment should be made to Policy SS3 E to include that the development of new residential properties and local services (as noted in 3) close to major nodes of employment will be supported. Such an amendment will assist the Council in their aim of ensuring that "housing and jobs are provided together".

One area of concern is however para 3.20, which states;

"Small-scale residential development, which generally means proposals of no more than 5 dwellings, will be supported in Hinterland Villages. It is expected that most proposals will involve the redevelopment of existing sites and infill opportunities. Sites will not be specifically allocated for residential development unless the local community - through the parish council - wish to promote the development of a specific site or sites in the Allocations DPD or a Neighbourhood Development Plan."

Please note that my client does not support the wording of pars 3.20.

Policy SS3 reiterates the threshold of five dwellings being appropriate in hinterland villages. We would recommend that this threshold is removed and wording inserted that at least allows for;

Consultee/Agent ID Nature Of Response Officer Comments Response: "Each case on its own merits dependent upon the benefits of the wider proposals".

Policy SS3 does however support economic development within the countryside which is a wide ranging definition. It would be appropriate for this definition to be widened to include other means development such as residential and new local services in order to ensure that there is additional investment within the District whilst creating more inclusive and sustainable communities.

With respect to Question 3 therefore my client welcomes a number of points, however further changes should be made to the Core Strategy to ensure a more flexible approach to development can be achieved based on the merits of each proposal.

Policy SS3 therefore requires further amendment for greater flexibility in order to support existing sites and locations that have a large working and resident population. Mr Tom Cook, ID Planning on CSFC/512 Support with Policy SS3 sets out the consideration of Comments noted and wupport welcomed. In behalf of Manor Grange (Melton) conditions development in locations noted as being response to the consultation comments, the Limited `hinterland villages'. The definition of a Draft Strategy Document merges the hinterland village whilst broad brush does categories of Secondary Rural Service enable for each settlement to be considered Centres and Hinterland Villages to form in respect of the role and function of each Primary Villages. Thus, the approach for village. Naturally each settlement will be Primary Villages is to support their growth in different; however the supporting text states the order of 10% over the plan period. This that "some villages close to larger centres provides clarity on the overall scale of have a particular role and function". development expected over the plan period Consultee/Agent ID Nature Of Response Officer Comments Response: (a figure for each village is provided in the It is my client's position that recognition table accompanying Policy S5 of the Draft should be made within the Core Strategy Strategy Document). (and specifically Policy SS3) that where there is an existing living and working population, Melton village does not currently have the that additional residential, economic, and services and facilities required of a Primary social development will be supported in order Village (formerly Secondary Rural Service to assist in supporting important local Centres and Hinterland Villages). employers.

One area of concern is however para 3.20, which states;

"Small-scale residential development, which generally means proposals of no more than 5 dwellings, will be supported in Hinterland Villages. It is expected that most proposals will involve the redevelopment of existing Consultee/Agent ID Nature Of Response Officer Comments Response: sites and infill opportunities. Sites will not be specifically allocated for residential development unless the local community - through the parish council - wish to promote the development of a specific site or sites in the Allocations DPD or a Neighbourhood Development Plan."

Please note that my client does not support the wording of pars 3.20.

Policy SS3 reiterates the threshold of five dwellings being appropriate in hinterland villages. We would recommend that this threshold is removed and wording inserted that at least allows for;

"Each case on its own merits dependent upon the benefits of the wider proposals".

With respect to Question 3 therefore my client welcomes a number of points, however further changes should be made to the Core Strategy to ensure a more flexible approach Consultee/Agent ID Nature Of Response Officer Comments Response: to development can be achieved based on the merits of each proposal.

Policy SS3 therefore requires further amendment for greater flexibility in order to support existing sites and locations that have a large working and resident population. Mr David Farnsworth, East CSFC/514 Observations The ERoYRP has some concerns in relation Comments noted. Riding of Yorkshire Rural to the identification of, and development Partnership policies relating to, lower tier settlements. The levels of development allowed in a Hinterland versus a Rural village mean this label is likely to be challenged at local level. Also what constitutes a Rural village may not always stand up to local knowledge (e.g. the lack of a school does not necessarily indicate the lack of a village - some examples of village schools located in isolated locations). Ms Cathy Lloyd, Tickton & CSFC/522 Object This Parish Council does not agree to the Comments noted. In response to the Routh Parish Council amended approach to developments in the consultation comments, the Draft Strategy hinterland villages. Document merges the categories of Secondary Rural Service Centres and Hinterland villages are defined as being Hinterland Villages to form Primary Villages. relatively accessible to larger centres and with Thus, the approach for Primary Villages is to a basic level of services to support their support their growth in the order of 10% communities. The Parish Council feels it is over the plan period. This provides clarity on important to look beyond the services to the the overall scale of development expected infrastructure such as electrical supply, over the plan period (a figure for each village sewerage and drainage systems and whether is provided in the table accompanying Policy the road network that connects them to the S5 of the Draft Strategy Document). larger centres is capable of carrying the extra load of not just the hinterland development The table accompanying Policy S5 of the Draft but all other development along that route to Strategy Document sets out the overall scale Consultee/Agent ID Nature Of Response Officer Comments Response: the larger centre. Looking at the availability of of development supported in the Primary cycle paths is not really realistic as the Villages. For Tickton, no specific allocations greatest increase will be in road transport. for residential development will be made due The marginal cost of development of the to the level of flood risk in the area. infrastructure may far exceed the levy a developer could be expected to contribute. Infrastructure issues, including costs, have This marginal cost needs to be factored into been considered through the preparation of the calculation and affordability of investing the Strategy Document. that amount in the infrastructure needs to be taken account of. The development limits of villages will be determined through the Allocations The reference to proposals for small scale Document. The parish council will have an developments of less than 5 dwellings is not opportunity to input into this. helpful. An exact target needs to be stated and as hinterland villages differ in size it would be better to recognise this in the targets. The mathematics suggests that approximately 1411 dwellings need to be built in 14 hinterland villages over the next 17 years which averages out at almost 101 per village. This Parish Council does not recognise that as small scale development.

Another concern is the reference to the Development Limits – the implication is that they will be redrawn. This should be available for consultation at the same time as this document as it would show the scope for development in individual parishes.

Tickton is included in the list of potential hinterland villages. The redevelopment of existing sites and infill will not generate anywhere near 101 houses. To do this the Consultee/Agent ID Nature Of Response Officer Comments Response: concern is that the development limits will be substantially redefined. The main services available to the village are a shop and a school. The school is already over capacity, and is on the face of it, incapable of expansion. Currently children do attend from outside the village and the school could once again become a ‘village school’ but this would take some time to work its way through and the period of transition would be very disruptive with numbers particularly at key stage 2 being unacceptable.

Similarly there is great concern about the local infrastructure’s ability to cope with any expansion let alone expansion on this scale. The quality of the drainage and sewerage systems (due in no small way to the low lying nature of many parts of the village as well as the make‐ up of the infrastructure) and the electricity supply are currently unacceptable. To support anything other than minimal limited developments would require substantial investment.

In the next few years there is no doubt that the main artery to Hull and Beverley for the residents of Tickton will become increasingly clogged up without this scale of development in Tickton due to the building of the by‐ pass, the hospital development, planned building development in Leven and Brandesburton. Although there is a cycle route this will only account for a small part of this additional Consultee/Agent ID Nature Of Response Officer Comments Response: traffic. The cost of public transport and the infrequent nature of the service – especially at peak evening times makes it extremely unlikely that all but a small number will use cars.

The Parish Council believe that Tickton is more suited to be a rural village where development would be limited to around 25 additional residences over the 17 year period. In the insurers/governments’ view we are in grave danger of flooding and do not think planning policy should allow for more properties than infill, particularly as this would inevitably be on some land that currently allows some ‘soak away’, thus increasing the risk. Lyndsey Fielding, South Cave CSFC/547 Support with PARTLY Comments noted and support welcomed. Parish Council conditions Lyndsey Fielding, South Cave CSFC/548 Support 1) We support the retention of Village Comments noted and support welcomed. Parish Council Development limits Lyndsey Fielding, South Cave CSFC/549 Object 2) We are worried that at this late stage with Comments noted. The introduction of Parish Council no real policy foundation, a new category of Hinterland Villages in the Further "hinterland village" is suddenly announced. Consultation Core Strategy was in response to comments received to previous consultation documents. Lyndsey Fielding, South Cave CSFC/551 Support with 4) We are pleased to seem some credible Comments noted. For clarity, villages are Parish Council conditions distance which is based on something other considered as Primary Villages (formerly than an arbitary judgement has been used in Secondary Rural Service Centres and Primary setting 5km as a distance. It is unclear Villages) where their development limit is set however that, while the Centre of the larger within 5km of the larger settlement’s town settlement is defined in the town centre centre boundary. The whole village does not Consultee/Agent ID Nature Of Response Officer Comments Response: proposals maps, the distance between is not have to be within the 5km. identified i.e. is it up to the smaller villages development limit, The village centre (if so what is that), or the entire village that is to be within the 5km? Ms Laura Mepham, John R Paley CSFC/591 Support We agree with this approach. Comments noted and support welcomed. Associates on behalf of Ms Jayne Hudson, Hull and East Yorkshire Hospitals NHS Trust R J Kingdom, South Cave Active CSFC/604 Support with PARTLY Comments noted and support welcomed. Residents conditions R J Kingdom, South Cave Active CSFC/605 Support 1) We support the retention of Village Comments noted and support welcomed. Residents Development limits R J Kingdom, South Cave Active CSFC/606 Object 2) We are worried that at this late stage with Comments noted. The introduction of Residents no real policy foundation, a new category of Hinterland Villages in the Further "hinterland village" is suddenly announced. Consultation Core Strategy was in response to comments received to previous consultation documents. R J Kingdom, South Cave Active CSFC/609 Support with 4) We are pleased to seem some credible Comments noted. For clarity, villages are Residents conditions distance which is based on something other considered as Primary Villages (formerly than an arbitary judgement has been used in Secondary Rural Service Centres and Primary setting 5km as a distance. It is unclear Villages) where their development limit is set however that, while the Centre of the larger within 5km of the larger settlement’s town settlement is defined in the town centre centre boundary. The whole village does not proposals maps, the distance between is not have to be within the 5km. identified i.e. is it up to the smaller villages development limit, The village centre (if so what is that), or the entire village that is to be within the 5km? Ms Annie Smith, Kilham Parish CSFC/644 Support Yes Comments noted and support welcomed. Consultee/Agent ID Nature Of Response Officer Comments Response: Council Mr David Hickling, Hickling Gray CSFC/654 Support with Policy SS3 seems generally reasonable - but Comments noted. Policy S4 of the Draft Associates conditions we question why employment-generating uses Strategy Document considers the re-use of are considered to be acceptable in isolated existing buildings for residential use as well as locations when residential uses are not. community and economic uses. Surely, an office /workshop use will generate far higher levels of traffic and other activity than a private dwelling? For this reason we consider that there should be some mention of residential uses being acceptable when other uses are not viable in Policy SS3(E)(1). Perhaps some form of distance / accessibility related criteria could be added that favours conversion to employment uses in locations close to existing settlements, but allows residential use elsewhere? Ms Jenny Waddell, George F CSFC/669 Object Primary Rural Services Centres play a vital Comments noted. White on behalf of Mrs M Peach role in supporting Hinterland, Rural Villages and the Countryside. Additional housing should be allocated to such areas, including Bubwith, in order that they can fulfil their role of supporting the more remote areas. Ms Jenny Waddell, George F CSFC/674 Support with Primary Rural Services Centres play a vital Comments noted. White on behalf of Mr P conditions role in supporting Hinterland, Rural Villages Middlewood Esq and the Countryside. Additional housing should be allocated to such areas, including Kilham, in order that they can fulfil their role of supporting the more remote areas. Mr Ian Burnett, East Riding of CSFC/677 Observations I just wondered whether Swinefleet could Comments noted. The extent of the ‘hazard’ Yorkshire Council possibly be classified as a Hinterland Village, area identified in the Level 1 Strategic Flood as I think it's just within 5km of Goole and Risk Assessment means that supporting meets other criteria. development in Swinefleet (in terms of the Consultee/Agent ID Nature Of Response Officer Comments Response: approach used for Primary Villages – formerly Secondary Rural Service Centres and Hinterland Villages) is not appropriate. R Syrat CSFC/710 Object I am a concerned resident of Byedales Lane, Comments noted. In those instances where Winestead and would like to register my development limits are removed, the objection to the proposed removal of the countryside element of Policy S4 of the Draft development boundaries. I feel this will be Strategy Document will provide the detrimental to Winestead and would like the framework for considering development Council to reconsider this proposal. proposals. This is a more restrictive approach in terms of housebuilding than that taken for villages and towns with a development limit. Mr Michael Turnbull, Skeffling CSFC/721 Support Yes. The amended approach uses more Comments noted and support welcomed. Parish Council common sense Jane Allen, Fangfoss Parish CSFC/730 Object Fangfoss Parish comprises 3 villages: Fangfoss, Comments noted. In those instances where Council Spittal and Bolton. Under the revised Policy development limits are removed, the SS3 Fangfoss would be in the category 'Rural countryside element of Policy S4 of the Draft Villages' and would maintain its development Strategy Document will provide the limits. This we find acceptable. However, framework for considering development Bolton and Spittal would be placed 'in the proposals. This is a more restrictive approach countryside'. The removal of development in terms of housebuilding than that taken for limits from villages placed in 'the countryside' villages and towns with a development limit. could lead to unsuitable development which would not happen if development limits were maintained. Having read what forms of development will be supported in The Countryside, such as sizable agricultural and economic developments, it seems clear that any villages within this grouping will have had their safeguards withdrawn, especially those that apply to residential settlements.

Those villages were previously assessed as Consultee/Agent ID Nature Of Response Officer Comments Response: non-selected settlements where there were development limits in place and only in-fill allowed. They were the most protected groups. If they are placed in 'The Countryside' they will lose this protection. Although it may not be the Council's intention to allow these small villages to be developed, Fangfoss Parish Council feels that unless they are protected within this Framework there is no guarantee that unsuitable development may not occur over the next 17 years.

To avoid this situation, we suggest that the villages that are proposed to be placed in 'The Countryside' group are put, as they always have been, in a group of their own with their development limits intact. This is only way to safeguard these villages in the future. Mr Andy Booth, Globe CSFC/737 Support Support Comments noted and support welcomed. Consultants on behalf of Mr R Beal, Beal Developments Ltd Mr D J Lord, Halifax Estates CSFC/753 Support with The Estate welcomes the revised settlement Comments noted and support welcomed. conditions hierarchy and the planned increase in housing Policy S4 of the Draft Strategy Document provision in rural areas, together with the refers to single dwellings as the starting point abolition of a “local needs” test for new for decisions in Villages (formerly Rural housing in rural villages. In recent years it has Villages). The supporting text accompanying become evident to us that the poor the policy sets out the types of circumstances availability of housing in rural areas has been a where proposals for more than one plot will significant constraint on both existing and be supported. proposed rural enterprises. In our experience, many people are unwilling to set Policy S4 also sets out the uses appropriate up businesses, or come to work for for the conversion of rural buildings in the Consultee/Agent ID Nature Of Response Officer Comments Response: established enterprises, if they cannot find countryside. suitable housing to either purchase or rent in the immediate vicinity.

Consequently, we consider that the “single dwelling” presumption for development in rural villages is too constraining, especially where there is a suitable site and evidence of need for more substantial levels of new housing (as at Manor Farm, Bishop Wilton where the LPA has quite recently approved a scheme promoted by the Estate for 6 conversions and 4 new build houses).

In our opinion, a phrase such as “appropriate scale” or “small scale” would provide a more flexible criterion to determine the level of new housing in rural villages, leaving precise numbers to be negotiated depending on needs, and local circumstances.

Although the Estate has also promoted limited scale residential development in a number of other rural villages over recent years, these schemes have been opposed on “sustainability” grounds - yet there remains an urgent need for affordable housing in these villages. Had these schemes been supported, the supply of homes in these settlements could have been increased thereby helping to satisfy local needs and maintain a healthy local economy.

We support the general approach towards Consultee/Agent ID Nature Of Response Officer Comments Response: the provision of affordable housing in rural villages and in the open countryside, but cannot see the need, or justification, for allocating sites for affordable housing within rural service centres or hinterland villages. In our view, residential development within established settlements should be subject to the 25% requirement, not 100%, as would appear to be the case if the site were to be allocated specifically for affordable housing.

If allocations are to be made specifically for affordable housing they should be located outside settlement limits in the open countryside where residential development would not normally be allowed.

We understand the need to restrict new development in the open countryside and generally support the draft policy approach in this respect. However, where there are existing buildings, and these are capable of being converted to either commercial or residential use, we are firmly of the opinion that new uses, including residential, should be encouraged, with no presumption in favour of any particular use. Mr Alex Codd, Hull City Council CSFC/770 Support Provided that any such development is at an Comments noted and support welcomed. appropriate scale, and that the Strategic Housing Protocol, or any subsequent replacement of the protocol is followed, Hull has no issues with this policy. Mr David Hand, Scarborough CSFC/778 Support No objections Comments noted. Consultee/Agent ID Nature Of Response Officer Comments Response: Borough Council Mr Pete Sulley, Barton Willmore CSFC/792 Support Settlement Network – Question 3: There is Comments noted and support welcomed. on behalf of Central Land general support for the revised approach to Holdings Hinterland Villages, Rural Villages and the Countryside.

3.4 Central Land Holdings is generally in support of the Hinterland Villages element of Revised Policy SS3, for the reasons set out in Barton Willmore’s representations on Policy SS2 in the Preferred Approach Core Strategy (paragraphs 4.10 – 4.17 of those representations).

In summary, these comments are that villages Consultee/Agent ID Nature Of Response Officer Comments Response: close to larger settlements, such as Nafferton (in relation to Driffield), Tickton (in relation to Beverley) and Bilton (in relation to Hull), are too close to these major centres to enable them to perform a significant service centre role in their own right. Consequently, only development appropriate to the size, role and function of those settlements is considered appropriate. Mr Pete Sulley, Barton Willmore CSFC/802 Support 3.4 Our client is generally in support of the Comments noted and support welcomed. on behalf of Trustees of the Hinterland Villages element of Revised Policy Needler Settlement SS3, for the reasons set out in Barton Willmore’s representations on Policy SS2 in the Preferred Approach Core Strategy (paragraphs 4.10 – 4.17 of those representations).

3.4 Our client is generally in support of the Consultee/Agent ID Nature Of Response Officer Comments Response: Hinterland Villages element of Revised Policy SS3, for the reasons set out in Barton Willmore’s representations on Policy SS2 in the Preferred Approach Core Strategy (paragraphs 4.10 – 4.17 of those representations).

3.5 In summary, these comments are that villages close to larger settlements, such as Tickton (in relation to Beverley) and Bilton (in relation to Hull), are too close to these major centres to enable them to perform a significant service centre role in their own right. Consequently, only development appropriate to the size, role and function of those settlements is considered appropriate. Mr Pete Sulley, Barton Willmore CSFC/824 Support 3.4 KPDC is generally in support of the Comments noted and support welcomed. on behalf of The Kingswood Hinterland Villages element of Revised Policy Parks Development Company SS3, for the reasons set out in Barton Ltd Willmore’s representations on Policy SS2 in the Preferred Approach Core Strategy (paragraphs 4.10 – 4.17 of those representations).

3.5 In summary, these comments are that villages close to larger settlements, such as Nafferton (in relation to Driffield), Tickton (in relation to Beverley) and Bilton (in relation to Hull), are too close to these major centres to enable them to perform significant service centre roles in their own right. As such only development appropriate to the size, role and function of those settlements is considered appropriate. Consultee/Agent ID Nature Of Response Officer Comments Response: Mr Zulficar Ali, Environment CSFC/854 Support with We agree with the amended approach to Comments noted and support welcomed. A Agency conditions development within the Hinterland Villages. separate policy on flood risk and the approach to the Sequential Test, which would We welcome Para 3.21, and the need to apply across the East Riding, is provided in apply the sequential test. It would be the Draft Strategy Document (Policy ENV6). advisable if reference to the para 3.2.1 is referred to within this policy. Mr Chris Calvert, Pegasus CSFC/875 Observations It is my client's position that North Comments noted. The development limits of Planning Group on behalf of Mr Frodingham should be considered within the villages will be determined through the N. Muirhead settlement network as part of Policy SS2, Allocations Document. however at present it would be defined as a Rural Village under Revised Policy SS3. It is noted that only "very small scale" development is proposed to be acceptable within the development limits of Rural Villages and residential land allocations will not be identified. My client believes North Frodingham is an appropriate location for residential development in order to sustain the village's existing services.

My client questions whether the Authority are proposing to revisit the development limits of 'Rural Villages' from its Local Plans, some of which are in excess of 13 years old? Without up-to-date development limits there is no certainty as to how the settlement can accommodate the small scale development proposed in Rural Villages.

My client supports the removal of the requirement to apply a 'local needs' condition to new residential development granted in those smaller settlements outside the Consultee/Agent ID Nature Of Response Officer Comments Response: Settlement Network. Mr Chris Calvert, Pegasus CSFC/887 Observations My client believes North Frodingham is an Comments noted. The development limits of Planning Group on behalf of WC appropriate location for residential villages will be determined through the Watts Estate & Mr D Watts development in order to sustain the village's Allocations Document. existing services. My client's position is that North Frodingham should be considered within the settlement network as part of Policy SS2, however at present it would be defined as a Rural Village under Revised Policy SS3. It is noted that only "very small scale" development is proposed to be acceptable within the development limits of Rural Villages and residential land allocations will not be identified.

My client supports the removal of the requirement to apply a 'local needs' condition to new residential development granted in those smaller settlements outside the Settlement Network. Mr Michael Glover, Michael CSFC/922 Object The exor believes the scale of permitted Comments noted. In response to the Glover LLP on behalf of Exors of residential development in the villages is too consultation comments, the Publication Core Sydney Howard Deceased , restrictive. Whilst it is appreciated that the Strategy merges the categories of Secondary Robsons Chartered Accountants emphasis has been placed on the major Rural Service Centres and Hinterland Villages Consultee/Agent ID Nature Of Response Officer Comments Response: settlements, there are so many work based to form Primary Villages. Thus, the approach practices that now revolve around broadband for Primary Villages is to support their utilisation and the significantly reduced need growth in the order of 10% over the plan to travel to work . The limited travelling period. This provides clarity on the overall associated with school bus travel and other scale of development expected over the plan journeys such as weekly shopping trips set period (a figure for each village is provided in against the well - being associated with a rural the table accompanying Policy S4 of the life style, does suggest that greater Publication Core Strategy). opportunity should be provided for people to be able to live in a rural environment , particularly in villages that are on or very close to major transport routes between key centres, such that public transport capability can be delivered very economically. No great change is considered appropriate to housing numbers in very rural areas but hinterland villages , it is considered, should see a doubling of the 5 unit allowance proposed. This would assist in maintaining the essential character of the East Riding area- namely that of a rural county. Mr John Brown, Pocklington and CSFC/926 Observations On balance the recognition of a hierarchy of Comments noted. Wolds Gateway Partnership smaller settlements can be seen as a useful general guide to the amount and type of development to be encouraged/allowed. Within the hierarchy in particular places there will be overlap of function and capacity to sustain development, the implication of which is to remind decision makers that a useful general guide will be subject to local scrutiny and potential departure what from might be judged as the ‘norm’ . This could in turn lead to precedents being established which would influence debate and decision. Consultee/Agent ID Nature Of Response Officer Comments Response: There is probably no avoidance possible of this issue. Mr Chris Calvert, Pegasus CSFC/944 Support with HINTERLAND VILLAGES Comments noted. In response to the Planning Group conditions consultation comments, the Draft Strategy Pegasus welcome the Authority's willingness Document merges the categories of to take on board the comments from the Secondary Rural Service Centres and Preferred Options consultation in respect of Hinterland Villages to form Primary Villages. the need to support rural villages which are Thus, the approach for Primary Villages is to sustainably located in relation to the support their growth in the order of 10% Haltemprice settlements and the Principal over the plan period. This provides clarity on Towns. the overall scale of development expected over the plan period (a figure for each village It is understood that the Authority does not is provided in the table accompanying Policy propose to allocate sites (other than S5 of the Draft Strategy Document). community-led schemes) within Hinterland Villages or to revisit development limits from those in the respective Local Plans. On a practical note, without the release of allocations or extensions to development limits, what mechanisms will be put into place to ensure that appropriate growth in Hinterland Villages will be delivered and, conversely, that the overall spatial strategy for the District will not be undermined ?

Part B) of Policy SS3 does not make clear whether a single small scale development scheme (up to 5 dwellings) will be supported annually or if numerous small scale schemes (of up to 5 dwellings) can come forward in any given year. This needs to be expressly stated in the policy.

Part c) of Policy SS4 should include Consultee/Agent ID Nature Of Response Officer Comments Response: development promoted by Neighbourhood Forums, in addition to development promoted by Parish Councils. Mr Chris Calvert, Pegasus CSFC/946 Support with RURAL VILLAGES Comments noted and support welcomed. A Planning Group conditions list of Villages (formerly Rural Villages) is We support development of an appropriate provided in the appendices of the Draft scale which is appropriate to a rural village Strategy Document. location.

The Local Authority have committed to identifying development limits for Rural Villages, therefore it should not be overly onerous to identify in the Core Strategy, as an appendix for example, those villages at adoption which are defined as 'Rural Villages'. Mr Chris Calvert, Pegasus CSFC/947 Support COUNTRYSIDE Comments noted and support welcomed. Planning Group We support the removal of the requirement to apply a 'local needs' condition to new residential development granted in those smaller settlements outside the Settlement Network. Mr Matthew Naylor, Yorkshire CSFC/1013 Support Policy SS3 – Yorkshire Water strongly Comments noted and support welcomed. Water supports part E of the policy which recognises the need for essential infrastructure in a countryside location. Due to the nature of our operations most of our existing assets and associated infrastructure are within the countryside. Therefore any investment required on existing sites and/or new facilities will generally be in a rural location. Consultee/Agent ID Nature Of Response Officer Comments Response:

This policy should therefore help us to continue to provide the essential services of clean drinking water and disposal and treatment of waste water. Mrs J Gill, Welton Parish Council CSFC/1019 Support Rural Villages Comments noted and support welcomed.

Assuming that our villages fall within this category, we support the revised policy for rural villages, particularly the identification of development limits and the proposal for one infill dwelling Mr David Graham, Nathaniel CSFC/1034 Object For the reasons set out above we would Comments noted. Lichfield & Partners Ltd on bahelf request that North Ferriby is no longer of Mr S Prosser, St Modwen Plc identified as a Hinterland Village under Revised Policy SS3. Mr Barry Lee, Roos Parish CSFC/1053 Observation Tunstall, with a village hall meets the criteria Comments noted. The development limits of Council outlined in Rural Villages Para. 3.22 Villages will be determined through the “Development limits will be identified for Allocations Document. The parish council will 'Rural Villages' where they have one of the have an opportunity to input into this. following services: a village hall (meeting rooms)”......

“ Development limits will be drawn round the settlements outlining the area within which development will generally be acceptable.. Sites for housing will not be specifically allocated in Rural Villages”.

Who draws the limit, is the limit established following consultation with residents and/or the Parish Council? Consultee/Agent ID Nature Of Response Officer Comments Response: Mr Barry Lee, Roos Parish CSFC/1054 Support Roos Parish Council supports the view that Comments noted and support welcomed. Council all areas that are outside the development limits are treated as Countryside. Mr Tom Woolley, Marine CSFC/1073 Observations The MMO has no comment as to the revised Comments noted. Management Organisation SS3 policy. However, in the context of marine planning, it notes that in the countryside essential infrastructure, energy development and associated infrastructure, as well as specific economic development requiring direct access to water transport infrastructure will be supported. Mr John Smith, Walkington CSFC/1084 Observations At the last meeting of the Parish Council Comments noted. In response to the Parish Council Members considered the latest consultation consultation comments, the Draft Strategy on the LDF Core Strategy. A Parish Document merges the categories of Councillor reported orally following his Secondary Rural Service Centres and attendance at the consultation event on 10th Hinterland Villages to form Primary Villages. November 2011 and stated that Walkington Thus, the approach for Primary Villages is to was now classified as a `hinterland village' and support their growth in the order of 10% that the number of houses to be provided for over the plan period. This provides clarity on by the LDF framework had increased by 600 the overall scale of development expected to over 3000 new homes. It was suggested over the plan period (a figure for each village that the Parish Council should seek is provided in the table accompanying Policy clarification as to what was being suggested S5 of the Draft Strategy Document). for Walkington and that the existing envelope of the village should not be broadened. Please could you perhaps clarify what the proposed LDF framework means for Walkington and note that the Council is concerned that the existing envelope of the village should not be broadened. Ms Janet Murray, Withernsea & CSFC/1085 Support Yes Comments noted and support welcomed. Southern Holderness Consultee/Agent ID Nature Of Response Officer Comments Response: Regeneration Partnership