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YORKSHIRE LAND Limited YORKSHIRE LAND Limited CONSULTEE ID: 23082 BARNSLEY LOCAL PLAN EXAMINATION 2017 STATEMENT REGARDING MAIN MATTER 10: “ARE THE PROPOSED EMPLOYMENT ALLOCATIONS SOUNDLY BASED AND DELIVERABLE WITHIN THE PLAN PERIOD?” (POLICIES E1, E2 & EMPLOYMENT SITE POLICIES) A BRIEF INTRODUCTION Yorkshire Land Limited has been successfully developing in and around Penistone and the Western Villages for almost 30 years, during which time it has brought tens of millions of pounds of investment and betterment into the local economy. The Directors, Mr & Mrs Green, were born, bred and educated in Barnsley in the early 1960’s and have gained a vast and valuable experience of the Borough’s strengths and weaknesses and are highly knowledgeable of the area’s capacity to accommodate housing and employment allocations. Whilst Yorkshire Land Limited is represented by Peter Brett Associates & PB Planning at Stage 3 of the Barnsley Local Plan Examination in Public and comprehensive Hearing Statements responding to the Main Issues and Questions for Stage 3 have been submitted by these representatives, we provide our own focussed response herein to Main Matter 10 of the Inspector’s MIQ’s, highlighting serious failings with regard to the Employment Site Selection Process insofar as it affects Penistone and the Western Part of the Borough, which serves to substantiate our professional opinion that the Local Plan cannot be found sound unless Main Modifications are made by the appointed Inspector, Mrs Sarah Housden BA (Hons) MRTPI. ISSUE - WHETHER OR NOT THE ALLOCATIONS FOR EMPLOYMENT ARE BASED ON A ROBUST ASSESSMENT AGAINST RELEVANT CRITERIA 10.1 IS THE SITE SELECTION PROCESS FOR THE EMPLOYMENT ALLOCATIONS SOUNDLY BASED, INCLUDING SUSTAINABILITY APPRAISAL AND THE TESTING OF REASONABLE ALTERNATIVES? Penistone East and West Wards account for approximately 10% of the Borough’s population. The settlement services the rural hinterland and provides the main focus of employment opportunity within the Western Rural area of the Borough. Importantly, Penistone and the Western Rural Area of the Borough geographically form approximately half of the land mass within the Borough. In consideration of the above, the only proposed employment site for Penistone (Reference P2) is insufficient to meet employment needs of the area in the Local Plan Period to 2033 and therefore further land needs to be identified. Site P2 has several constraints which will in our opinion affect the deliverability of the whole site area and hence the ability to meet employment needs in full. These constraints are detailed within the Main Matter 3 Hearing Statement submitted by PB Planning but briefly include, topography, the presence of large high voltage electricity lines/pylons traversing the site and a Council identified requirement for a landscape buffer. We therefore do not consider that the Site Selection process has tested reasonable alternatives, for instance, our proposals for the Blackmoor Business Park adjoining Oxspring were rejected within three and a half working days by the Council on the basis that the site is located in a Western Village where the Council do not propose development on the premise that development is not sustainable. Correspondence between Yorkshire Land and The council regarding this matter can be found online at: www.BlackmoorBusinessPark.co.uk The Inspector has now identified the need for the Council to identify housing site allocations in the Villages. As a consequence it seems logical and reasonable to consider the delivery of appropriate employment allocations in such locations where they are sustainable. Whilst we acknowledge it is not part of the Inspector’s role to examine the soundness of rejected or alternative sites, we consider it prudent to identify our proposed solution to the issues raised in this statement with regard to meeting the employment needs of Penistone and the Western part of the Borough. Especially considering we are not aware of any other competing sites for employment being proposed to meet the needs of Penistone and the Western villages. 1 10.2 IS THE SITE SELECTION METHODOLOGY BASED ON AN APPROPRIATE SET OF CRITERIA? The Council have not properly considered sites outside of the Principal Town of Penistone on the premise that the Western Rural villages are not sustainable. However, sites in such locations may provide a reasonable alternative and additional capacity to meet employment needs, particularly where proposals benefit from sustainable transport connections to Penistone and other surrounding villages. For instance, the proposed Blackmoor Business Park site is a previously developed site in the Green Belt, approximately 10 Hectares (25 Acres) in size and located just 2.5 miles from the Town Centre of Penistone, the proposed site adjoins the villages of Oxspring and Thurgoland. Oxspring is the only Western Village adjoining the Penistone Principal Town. We are not aware of any other potential employment sites having been proposed to meet the Needs of Penistone and the Western Villages during the Local Plan Period. 10.3 ARE THE REASONS FOR SELECTING THE PREFERRED SITES AND REJECTING OTHERS CLEAR AND JUSTIFIED? We do not believe that the reasons for selecting the preferred sites and rejecting others are clear and justified. Not only do we believe additional employment land should be identified to meet the needs of Penistone, but as set out above, we also consider there to be deliverability issues associated with the only proposed employment allocation to meet the needs of Penistone and the Western Part of the Borough, site reference P2, which has several constraints, detailed in the Main Matter 3 Hearing Statement submitted by PB Planning. We have also submitted compelling evidence to the Council which evidences several factors affecting the deliverability of site reference P2. These include the presence of two large electric pylons carrying high voltage cables which hang low over the site. The supporting text within the Publication Version Local Plan also identifies constraints associated with mature trees on the site’s north eastern boundary and the need to provide of a buffer strip. Furthemore, as set out within the Main Matter 3 Hearing Statement submitted by PB Planning, we are also aware of one other key restriction associated with the development of site P2, related to the accessibility for high sided delivery vehicles. 2 The Council have failed to address this evidence or to consider the allocation of a further less constrained site, to ensure that sufficient land is allocated during the plan period to help meet the employment needs of the area. We have proposed a potential employment site in the form of the Blackmoor Business Park in Oxspring, which is a brownfield site within the Green Belt, unlike site reference P2 which is a Greenfield and Green Belt site. However, the Council has simply discounted this proposal on the basis that it is located on the edge of a Western Village were new development is not currently proposed. The Council’s position in this regard conflicts with its decision to allocate site P2 for employment use to meet the needs of Penistone and the Western Part of the Borough, as that site is actually located within the village boundary of Oxspring. There are therefore serious implications associated with the deliverability of proposed employment allocation P2, leading to serious implications associated with the ability of the PDLP to meet the employment needs of Penistone and the wider rural hinterland which it serves. ISSUE - WHETHER OR NOT THE ALLOCATIONS FOR EMPLOYMENT ARE SOUNDLY BASED AND DELIVERABLE WITHIN THE PLAN PERIOD 10.4 THE FOLLOWING THREE QUESTION APPLY TO EACH OF THE SITES PROPOSED FOR EMPLOYMENTAS SET OUT BELOW: A. IS THE TYPE AND AMOUNT OF DEVELOPMENT PROPOSED FOR EACH SITE JUSTIFIED HAVING REGARD TO ANY CONSTRAINTS AND THE PROVISION OF NECESSARY INFRASTRUCTURE? We do not believe that the Council have properly considered the identified constraints, outlined above, which will limit the type and amount of any development at Site P2. The Council identify in paragraph 5.56 of the Local Plan that Penistone is the main centre for the surrounding villages and we want to consolidate this role through the plan period. Furthemore, the Council’s adopted Core Strategy at section 7 (Spatial Portrait) sets out in paragraph 7.79 the need to provide between 4.5 and 6.5 hectares of Employment Land in Penistone over the Core Strategy Plan Period (2008 to 2026). The PDLP now extends to 2033 and therefore at least a proportionate amount of additional employment land will be required to ensure that needs will be met over the extended plan period. 3 Notwithstanding the above, Policy E2 of the Local Plan only seeks to distribute 1% of the Borough’s future employment land opportunity to Penistone (3.3ha of a total 309.4ha). This in our opinion is a bizarre situation, particularly when the evidence provided by the Barnsley Development Agency (enclosed at Appendix A) is taken into consideration. In addition to this evidence, the Local Plan is proposing housing growth to the Principal Town of Penistone, which will ultimately result in a population increase and a greater requirement for local employment opportunities. It is also important to note that since the adoption of the Barnsley UDP in December 2000, Penistone has lost a considerable amount of employment land, which is attributable to three factors. Firstly, Accessibility, as several low bridges restrict access and egress to/from Penistone and those large vehicles which can access the town are required to navigate through the town centre via high street/market place (square about) and Green Road, causing much disruption. Secondly, the introduction of policy PPG 3 which encouraged new housing development on previously developed sites and thirdly, the Councils adoption of Planning Advice Note (PAN) 30. This Local Plan therefore provides the opportunity to provide sufficient additional or alternative employment land in a suitable location, not restricted by low bridges.
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