City Council Site Allocations Plan Examination

Matter 7: Selection of sites allocated for

development – East:

Main Issue 1 Main Issue 2 Additional Site Specific Questions

Doc No. M7/1c

Leeds Local Plan

Page 1 of 14 Main Issue 1: For each Housing Market Characteristic Area, are the individual sites selected sound?

1 Are the selected sites justified having regard to the site selection methodology and process, paying particular attention to the deliverability of the allocated sites?

1.1 Yes. The Council’s response to Matter 6 details the overall site assessment and selection process used for allocation of sites in the Plan. The Council considers that this approach is the most appropriate in terms of meeting CS aims and objectives for the MD as a whole and that the selection of sites is justified. This response to Matter 7 sets out how the overall methodology and process has applied in the East HMCA. It highlights the specific characteristics of and evidence relating to East and notes whether there are any specific issues arising.

1.2 Further to paragraph 3.3 of the Submission SAP CD1/1, East has the largest housing target set out within the Core Strategy, a target of 11,400 new dwellings equating to 17% of the overall housing requirement. East is an area of contrasting character areas reflective of its location sandwiched between the Inner area of Leeds and the outer rural areas of the Outer North East, Outer South East and Outer South, most of which is Green Belt. A significant amount of housing within East Leeds is post-war Council-built housing, focused around areas such as , Stanks and Swarcliffe. This is contrasted with areas such as Colton and Wellington Hill which are characterised by a mix of pre-war and modern, private housing. and Halton are the identified town centres within East and house and grounds provides the largest greenspace within the area. In East major strategic highway infrastructure, the East Leeds Orbital Road (ELOR), will be delivered during the plan period (expected completion date 2021) to enable the delivery of significant housing growth. Combined with the Manston Lane Link Road this strategic infrastructure will enable the development of sites HG1-288 East Leeds Extension, HG2-119 Red Hall Offices & Playing Field, HG2-120 Manston Lane – former Vickers Tank Factory Site, Cross Gates, MX1-25 Land bounded by Park Approach and Barrowby Lane off Manston Lane, Manston, Leeds, MX2-38 Barrowby Lane, Manston and EG2-27 Manston Road, Leeds.

1.3 The methodology as outlined in Matter 6 is considered robust. In East in terms of new housing allocations 29 sites were put forward for consideration, 15 of which are in or partly in Green Belt. In East there are:

a) 8 housing allocations (2 of which are Green Belt/part Green Belt)

b) 1 mixed use allocation (MX2-38 Green Belt)

c) 20 sites are rejected (12 of these are Green Belt).

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The reasons for allocation and rejection of sites are detailed at Appendix 2, pages 98 to 110 in the Housing Background Paper CD1/34

1.4 In terms of office and general employment allocations, 9 sites were put forward for consideration in East. In East there are:

a) 1 general employment allocation (EG2-27)

b) 1 Mixed use allocation (MX2-38 – Green Belt)

c) 7 rejected sites

Reasons for allocation and rejection of sites are detailed at Appendix 1, page 30 to 32 of the Employment Background Paper CD1/29.

1.5 Within the context of the NPPF CD3/1, the deliverability of sites concerns whether they are suitable, available and achievable. Paragraphs 5.5 to 5.17 of the Housing Background Paper CD1/34 considers this at a strategic level, paragraphs 5.6 to 5.8 looking at suitability, paragraphs 5.9 to 5.10 availability and 5.11 to 5.17 achievability. The appropriateness of employment sites is explained in the Employment Background Paper CD1/29 and also in response to Matter 2, Question 9.

1.6 Deliverability In terms of suitability, the site assessment process has considered an individual site’s suitability for development including physical constraints such as access, infrastructure, flood risk, ecology and heritage considerations alongside compliance with the CS. The Site Assessments document CD1/38 provides the full site assessments for all allocations in East (both housing and employment). Where necessary specific site requirements have been applied to sites where mitigation measures are necessary to ensure a site remains suitable for development.

1.7 In terms of the availability of sites, as paragraph 5.10 of CD1/34 and paragraph 3.13 of CD1/29 details, the sites have generally been submitted to the Council for consideration for the allocated use therefore there is landowner intention to release the sites for that purpose. Where this is not the case the Council has contacted the landowners of allocated sites. No evidence has been received that any of the proposed allocations will not be made available. As the sites are considered to be policy compliant and suitable, any lack of response from a landowner has been deemed to mean that the land remains available and the allocation is justified. The Council is actively preparing Planning Briefs for a number of allocated sites (HG2-119 Red Hall Offices & Playing Field LS17, HG2-122 Cartmell Drive, and HG2-210 St Gregory’s Primary School, Stanks Garden, Swarcliffe) with a view to inform future land disposals. A number of the sites are already being actively promoted by the agents/developers as evidenced in representations received. In addition there

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are planning applications pending determination on sites HG2-120 Manston Lane – former Vickers Tank Factory Site, Cross Gates (14/02514/OT) and HG2-121 Bridge – Wykebridge Depot (14/03958/OT). An update on planning permissions on sites, since 1/4/16 will be sent to the Inspector before the commencement of the hearing sessions.

1.8 In terms of achievability, the Council’s response to Matter 6 Question 7 explains how viability has been tested and how the Council will respond to any future changes. There is no evidence and no landowner representations have been received on any particular site to suggest that development is not viable.

2 Are sufficient sites identified in the HMCA consistent with the CS?

2.1 Please see the Council’s response to Matter 2 Question 9.

2.2 East is 1,714 under the indicative target of 11,400 as illustrated in the table below.

Extract from Table 1 Housing Distribution by Housing Market Characteristic Area (HMCA), paragraph 2.27 of the Submission Draft Plan CD1/1

Housing Core Percentage Existing Proposed Total +/- Market Strategy supply allocations housing Target Characteristic Housing (‘Identified supply Area Target sites’)

East 11,400 17% 6,133 3,553 9,686 -1,714

2.3 Due to a number of factors, including the significant Green Belt restrictions in the area and the need to balance the purposes of the Green Belt against the CS target, East is significantly under the CS target (this is evidenced through the Council’s reasoning for not allocating sites set out within the Housing Background Paper CD1/34 pages 106-110). In addition, as outlined within the Council’s response to Question 11 of the Inspector’s Initial Questions EX2 the total proposed supply of housing in East has been reduced due to comments from statutory bodies such as Historic which have reduced site capacities, reductions in site capacities within the Aire Valley Leeds Area Action Plan (which contributes to the East target) and other factors as set out in the response. The Council have outlined how it will address this shortfall in our response to Matter 2 and in EX2, response to Question 11.

2.4 As regards employment sites there is no specific HMCA target. Provision and distribution of employment sites is addressed in the Council’s response to Matter 2, Question 9.

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3 On identified sites where planning permission has expired, is there very convincing written or verbal evidence that the intentions of the owners/developers have changed? (Please see schedule 1)

3.1 The Council’s response to ‘Further Questions to the Council’ (7th August 2017) EX2c, response to Question 1 provides a narrative in relation to Schedule 1 and gives a detailed response for each expired permission. Since 2012, the base date of the plan, some sites have inevitably expired. This, which is common to all authorities, is a general reflection of the recent state of the market and ‘turn over’ of planning permissions. The Council considers that relying on such sites forming part of supply is justified because: a) of the evidence that sites with expired permissions are developed (see paragraphs 1.1 to 1.4 of the Council’s response to ‘Further Questions to the Council’ 7th August 2017) EX2c, and b) these sites remain suitable, available and achievable. Whilst expiration of planning permissions may have implications for a 5 year land supply assessment and the demonstration that sites are available now, it does not follow that such sites, given Core Strategy aims and objectives and the scope of the SAP, will not come forward over the plan period.

3.2 In East, 3 identified sites are listed on Schedule 1 of the Inspectors Matters and Issues. The status of each of these sites is set out in the Council’s response to further questions 7th August EX2c and Appendix 1 of the Council’s response to the Inspector’s Initial Questions June 2017 EX2. In East there is 1 site with expired permission, HG1-303 Cartmell Drive, Halton Moor. The evidence as to the intentions of owners/developers is already provided in the Council’s response to question 1 ‘Further questions to the Council (7th August 2017) EX2c.

3.3 As noted in paragraph 2.3 above, the identification of employment land allocations and floorspace is a District-wide rather than apportioned by HMCA. As part of the Employment Land Assessment Update 2017, EB3/7, the Council wrote to landowners in December 2016 (which includes Identified sites with expired planning permission), to make informed decisions as to how sites contribute to the future supply of employment land through an assessment of availability. The Council updated the ELR EB3/7 according to the landowners intentions for the site including confirmation that development for employment purposes could be delivered within the plan period to 2028. In response to that process, one main modification (to site EG1-48 Opposite Ravell Works, Gelderd Road in Wortley, in Outer South West HMCA) is proposed to delete part of the site from the boundary following confirmation that this part of EG1-48 will not be available for the delivery of employment land.

4 Is the proposed mix of uses on mixed use allocated sites justified?

4.1 Yes. As explained in paragraph 2.42 of the Submission SAP CD/1/1 capacities for housing sites use a standard methodology used in the SHLAA, which applies

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a standard density multiplier, which varies according to location, to the net area of a site. Where a mix of residential and other uses is proposed, the approach has been to take half of the calculated housing capacity and half of the general employment (or other use) capacity/area, unless there is a specific reason for varying from this approach. For example, in the city centre, ground floor office and town centre uses may be appropriate with residential on upper floors, so the housing capacity will be more than half the standard methodology, or a development brief may exist that suggests a mix of uses. The approach to mixed use is considered by the Council to be a justified and sound approach for Leeds, in not only providing the necessary quantum of development overall but also allowing for flexibility in responding positively to market conditions.

4.2 As CD1/1 states ‘capacities can only be an indication of what could be achieved on a site’. There is 1 mixed use allocation in East, site MX2-38 Barrowby Lane, Manston. The mix of uses does not follow the standard methodology explained in paragraph 4.1 above, as a range of on-site constraints such as proximity to the M1 motorway and the Leeds-Selby/York railway line, as well as the potential presence of a high-pressure gas pipeline underneath part of the site means that the balance of uses lends itself more towards general employment than an even split of residential and employment. This results in an estimated capacity of 150 housing units and 10 hectares of general employment land. The site benefits from close proximity to the mixed use site of MX1-25 Land bounded by Park Approach and Barrowby Lane off Manston Lane, Manston, Leeds which, when complete, will have a range of uses including housing, offices, retail and leisure. When the Manston Lane Link Road is complete the site will also benefit from very good access to the M1 motorway (Junction 46). Given the mix of uses in the surrounding area and the excellent access to the national motorway network it is considered that the mix of housing and general employment uses on the site is appropriate and justified.

4.3 Mixed use sites are detailed in the Plan in the same format as other allocations, with both the housing capacity and site capacity for general employment or office use given along with any specific site requirements.

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5 Where the development of a site relies on the delivery of critical infrastructure (e.g. new roads, new water and waste water infrastructure, significant pre-commencement work), does the evidence support that the infrastructure will be in place to support the timely development of these sites?

5.1 Yes. Please see the Council’s response to Matter 5 Infrastructure. In addition, CD1/35 identifies infrastructure requirements across the District and potential sources of funding/provision, and includes sections on transport modelling and school provision – from looking at the cumulative effect of the proposed allocations, what the infrastructure needs are in terms of the highway network and school provision. Strategic and site specific infrastructure needs are identified, both through the Infrastructure Delivery Plan and in site specific site requirements where necessary.

5.2 In terms of new water and waste water infrastructure there are no site specific requirements within the Plan. Water has been involved in the Plan throughout its preparation. Provision for new water and waste treatment infrastructure can be delivered subject to further feasibility work to look at capacity of existing systems. Yorkshire Water are currently analysing the requirements for water and waste water infrastructure and will look to work with and developers to ensure its timely provision. Yorkshire Water raised no objections during the formal consultation stages of the Plan and have confirmed their agreement to this statement.

5.3 Where other critical infrastructure including a new road or other pre- commencement works are required, these are detailed in the site requirements for specific sites.

5.4 In East, some identified and allocated sites will require the timely delivery of the East Leeds Orbital Road and/or the Manston Lane Link Road critical infrastructure, before the sites can be delivered. These sites are HG1-288 East Leeds Extension, HG2-119 Red Hall Offices & Playing Field LS17, HG2-120 Manston Lane – former Vickers Tank Factory Site, Cross Gates, MX1-25 Land bounded by Park Approach and Barrowby Lane off Manston Lane, Manston, Leeds, MX2-38 Barrowby Lane, Manston LS15 and EG2-27 Former ice cream factory, Manston Road. The Manston Lane Link Road is currently under construction and is due to complete by 2018. There is no evidence to suggest that this is likely to be delayed. A planning application for ELOR is pending determination and is due to be complete in 2021. The Council is therefore confident that this critical infrastructure will be complete to enable the timely delivery of the developments.

5.5 Transport modelling has considered the cumulative impact of proposed allocations upon the road network, in particular the A6120 (Ring Road) and

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Junction 46 of the M1, and where necessary site requirements for contributions to mitigate any impacts are attached to specific sites; HG2-120 Vickers Tank Factory1, Cross Gates, MX2-38 Barrowby Lane, Manston and EG2-27 Former Ice Cream factory, Manston Road.

5.6 The site requirements are considered justified and no evidence has been received to suggest that they cannot be delivered. The Council is therefore satisfied that the site requirements will ensure timely delivery of infrastructure.

6 Are the identified Protected Areas of Search sites justified?

6.1 N/A. There are no UDP PAS sites in East and no proposed safeguarded land designations in the SAP.

1 Site HG2-120 is subject to a proposed Major Modification to alter the wording of this requirement to be consistent with other sites in the area. Please see table of proposed Major Modifications.

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Main Issue 2: For each site, are the policies and specific site requirements sound?

1 Are the general policies and site requirements relating to all sites positively prepared, justified and effective (are they clearly expressed so they can be applied in day to day decision-making?) and consistent with national policy?

1.1 Yes. The general policies for each site include policy HG2 and policies HG3, HG4 and HG5 where applicable on sites allocated for housing, policy EO2 on office allocations, and Policy EG2 on general employment allocations. The Council considers that the SAP has been positively prepared on the basis that it is delivering a strategy which seeks to meet objectively assessed development and infrastructure requirements, and is consistent with achieving sustainable development principles (NPPF, CD3/1). As outlined in CD1/28, City Region authorities have been involved through the Duty to Cooperate process and consultation stages of the Plan. In certain cases, where allocation of sites have the potential to impact upon infrastructure in neighbouring authorities, site requirements have been applied to specific sites to mitigate the impact . The SAP is set within the context of the adopted CS and the Council considers that its policies and site requirements are justified. They have been based on up to date evidence, and all reasonable alternatives have been assessed, through the site assessment process and the sustainability assessment of sites. (See the Council’s response to Matter 6).

1.2 The general policies have been positively prepared, in accordance with this approach and are considered justified and effective. The policies are considered to be unambiguous to enable decision makers to apply them in dealing with specific planning applications. Please see also the Council’s response to Question 4 below. The response to this question regarding site requirements is given under Question 2 below. Not all sites have specific site requirements over and above the general policy requirements. Assessment of applications on these sites will therefore rely on policies elsewhere in the Local Plan to guide decision making, all of which have been found to be sound.

2. Are the specific site requirements relating to individual sites justified and effective (are they clearly expressed so they can be applied in day to day decision-making?) and consistent with national policy? For example, many suggest that ‘consideration’ should be given to various matters as part of proposals / planning applications but does not explicitly require anything further to be done beyond that.

2.1 Yes. The site requirements are considered to be justified, effective and consistent with national policy CD3/1, and clearly expressed. Where sites listed

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within the general policy (see response to Question 1 above) have specific requirements, these are listed as site requirements under the allocation concerned. The site requirements are considered necessary in order to make the site sound and enable the delivery of sustainable development in accordance with the policies in the NPPF CD3/1. For example, site requirements concerned with conservation areas and listed buildings will help deliver section 12 of the National Planning Policy Framework.

2.2 See the response above to Main Issue 1, Question 5 regarding critical infrastructure site requirements. In addition to requirements for infrastructure provision, sites have requirements where heritage, ecology or other factors need to be taken into account in ensuring development is sustainable. Certain site requirements have been triggered where a site lies within a certain distance of a designation, such as a Conservation Area or Listed Building, or where a culvert or pipeline crosses or incurs into a site boundary. Where any such trigger is present, we have consulted appropriate bodies further on such sites – for example, on sites adjacent to Conservation Areas or Listed Buildings, the Council’s heritage officers have been consulted and involved in the production of site requirements and the Heritage Background Paper, and Historic England have been involved in both the production of the Background Paper and consulted on the site requirements. The site requirements stem from NPPF guidance, including on flood risk (paragraphs 100 to 104 NPPF), section 11 on conserving and enhancing the natural environment and section 12 on conserving and enhancing the historic environment.

2.3 However, with regard to site MX2-38 Barrowby Lane, Manston LS15 there are unresolved objections from Historic England and the Archaeological Service that concern the absence of a site requirement stating that regard should be had to the setting of the Schedule Monument in the vicinity of the site. The Council agree with Historic England and West Yorkshire Archaeological Service that such a site requirement should be included, and as such we are proposing it as a Major Modification to the Plan (a table of modifications to the Plan is to be sent to the Inspector no later than 4 weeks before commencement of the hearings).

2.4 With regards to the Inspector’s reference in this question to site requirements which refer to ‘consideration’ being given rather than an explicit requirement, across the Plan as a whole there are 554 specific site requirements (attached to 208 sites). Only 48 site requirements have wording referring to ‘consideration should be given……’ and most of these (39) relate to a site requirement for re- opening or restoration of culverts.

2.5 In East, 7 housing and employment allocations (and mixed use allocations), have specific site requirements, which amounts to 21 individual site requirements. As with the general policies, the site requirements are considered to be

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unambiguous, to enable decision makers to apply them in dealing with specific applications. Only 1 individual site requirement in East has wording referring to ‘consideration should be given to…. ‘. This is HG2-123 Colton Road East LS15 which has a site requirement for culverts and canalised watercourses which states “The site contains a culvert or canalised watercourse. Development proposals should consider re-opening or restoration in accordance with saved UDP Policy N39B”. To use the word ‘consider’ in this context is considered appropriate as the opening of culverts needs to take full account of public safety considerations, and in some cases development cannot be achieved through opening a culvert. The wording allows for the implementation of the UDP policy.

3. Does the evidence demonstrate that the deliverability and viability of the allocated sites is not prejudiced by the site requirements, particularly those that have been subject to additional / revised requirements as a result of consultation during the plan process?

3.1 Yes. See the Council’s response to Question 1, paragraph 1.7 above and to Matter 6, Question 7. There is no evidence that any of the site requirements would unduly affect deliverability of the sites or that viability would be prejudiced and no representations have been received on any particular site to suggest that development is not viable. As stated, the online PPG CD3/2 states “Assessing the viability of plans does not require individual testing of every site or assurance that individual sites are viable” (Paragraph 006 Reference ID: 10-006-201440306 revision date 06 03 2014). If any detailed viability issues do arise over the plan period these would be assessed at planning application stage and be subject to full viability appraisals.

3.2 In East, 3 housing allocations have been subject to additional/revised site requirements which were advertised as pre-submission changes to the Plan in February 2017. These are:

Site ref and Pre submission changes to site requirement/additional site address requirement added as pre-submission change

HG2-119 Red Hall Revised Greenspace requirement so that provision of greenspace Offices & Playing could be determined through the Planning Brief for the site. Field LS17 Revised and additional wording to the Listed Buildings site requirement to provide greater detail on how future development of the site should respond to Red Hall itself.

An additional Ecology site requirement to ensure that an Ecological Assessment is undertaken.

HG2-122 Cartmell Revised ecology site requirement to reflect that a buffer should be provided to the south of the site, rather than the west and south west

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Drive, Halton Moor as previously stated.

An additional Historic Parks and Garden site requirement to reflect the site’s proximity to Temple Newsam.

HG2-123 Colton Deleted Local Highway Network site requirement to reflect the Road East, Colton reduction in size and scale of the proposal. LS15 Revised Listed Building site requirement to reflect the reduction in size and scale of the proposal.

Revised Conservation Area site requirement to reflect the reduction in size and scale of the proposal.

Additional Highways Access to Site requirement to reflect the likely change in highways access location to the site.

3.3 All the changes to site requirements listed above have given more clarity as to the specific requirements, but are not considered to unduly affect viability or deliverability of the sites concerned and no representations have been received suggesting this.

4. Some sites are identified as being suitable for older persons / independent living. (a) Whilst a preference is highlighted on some sites, it does not appear to be expressed as a requirement. Will Policy HG4 therefore be effective in the delivery of this type of housing? (b) Is the identification of these sites justified?

4.1 There are no sites identified as being suitable for older persons/independent living within the East HMCA.

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Additional Site Specific Questions

1 In relation to HG2-119 do the site requirements clearly express what would be expected for a planning brief?

1.1 The Council is of the view that the site requirements for site HG2-119 Red Hall Offices & Playing Field LS17 clearly express the factors affecting development on the site, allowing the Planning Brief and future planning applications to be prepared in full awareness of those factors. In some aspects of future development it will be for the Planning Brief to provide further guidance on how certain factors, such as Greenspace, should be addressed in detail. However, this will be within the context of adherence to existing Core Strategy policy.

1.2 One of the most important factors for consideration for future development on site HG2-119 is the impact on Listed Buildings, in this case Red Hall (Grade II). The site requirements give clear and concise guidance on how the built form should respond to the sensitivities of the heritage assets on site. As stated in the site requirements this guidance is derived from the Heritage Background Paper (CD1/33) (pages 64-69).

1.3 As such, the allocation - together with the site requirements - gives clear guidance on the quantum and potential form of development on the site. However, the Council is of the view that further clarity could be provided with regards to the link between the site requirements and the planning brief. As such the Council proposes a main modification to clarify the factors that the Planning Brief shall provide further guidance on. Subject to the modification the introductory text would now read “The Red Hall site will be the subject of a detailed planning brief (this includes site HG1-284 the remainder of the Red Hall site) which shall provide further guidance on design, landscaping, heritage and greenspace. Development will be subject to the provision of the section of the East Leeds Orbital Route which will run through the northern part of the site. The site contains a Safeguarded Municipal Waste site in the Natural Resources and Waste DPD, but this is being reprovided as part of the relocation of the Council operation, so will not affect development on the site”. The latter sentence will replace the discreet site requirement labelled as ‘Natural Resources and Waste DPD’ in the Submission draft as on reflection the Council is of the view that this statement is included for information rather than as a discrete site requirement.

1.4 Subject to the proposed modifications being agreed the Council is satisfied that they provide clear guidance as to what is expected in the planning brief which, together with the site requirements will help inform any future planning applications.

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2 In relation to HG2-123 a number of amendments have been made to the site requirements. Does the site remain deliverable?

2.1 Yes. Site HG2-123 Colton Road East, Colton LS15 has been reduced in size and scale from 165 units to 14 units. Commensurate revisions to the site requirements enable the deliverability of the site.

2.2 Site requirements have been changed so that the site will no longer have to make contributions to any future Junction 46 of the M1 improvements. Due to the significant alterations to the site boundary, the site is no longer within the Colton Conservation Area nor is it prominent from the Registered Park of Temple Newsam, and as such these requirements have been altered accordingly. Requirements relating to ‘Culverts and Canalised Water Courses’ and ‘Scheduled Ancient Monuments’ remain unchanged. The only new requirement relates to a modest re-alignment of the existing bus stop and traffic calming measures in order to achieve access to the site. It is not considered that this will unduly affect the deliverability of the site, given the relatively minor nature of such work.

2.3 It is worth noting, that the Publication Draft of the Plan included an Ecology site requirement, which was then omitted in error from the Submission Draft (NB CD1/2 Tracked change version of the Plan is correct in this regard). This omission in CD1/1 was not the subject of a Pre-Submission Change. The Council therefore propose to rectify this omission via an additional modification to the Plan. In terms of deliverability it should be noted that the requirement only requires an ecological assessment to be carried out. Only if mitigation is required and appropriate should it be provided. It is considered that the smaller boundary of the site has far less ecological impact than the previous larger site, as ecological features such as dykes, ditches, hedgerows and tree lines which were previously within the boundary of the site at multiple points, are now either not present or restricted to the boundary of the site.

2.4 The site is flat, greenfield and in a high value market area. It is considered that as a result of the altered site boundary the new site requirements are less onerous.

2.5 For information the Council propose a main modification to be made to the capacity of the site from 14 to 17 units as a result of an error in calculating the capacity of the reduced iteration of site HG2-123. This amendment will have a modest beneficial impact on the deliverability of the site and is fully in line with the standard methodology for calculating site capacity.

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