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Date: 8Th March 2018 Our Ref: APC00004 Planning Policy Team, Harrogate Borough Council, PO Box 787, Harrogate, HG1 9RW

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Date: 8Th March 2018 Our Ref: APC00004 Planning Policy Team, Harrogate Borough Council, PO Box 787, Harrogate, HG1 9RW Addison Planning Consultants Ltd Date: 8th March 2018 Our Ref: APC00004 Planning Policy Team, Harrogate Borough Council, PO Box 787, Harrogate, HG1 9RW Dear Sir/Madam, RE: HARROGATE DISTRICT LOCAL PLAN PUBLICATION DRAFT 2018 RE: DRAFT POLICY GS1: PROVIDING NEW HOMES AND JOBS RE: DRAFT POLICY GS2: GROWTH STRATEGY RE: DRAFT POLICY GS4: GREEN BELT RE: DRAFT POLICY DM1: HOUSING ALLOCATIONS: SITES PN17, PN18, PN19, PN20 – PROPOSED ALLOCATIONS AT PANNAL RE: OMISSION SITE – LAND TO THE SOUTH OF PANNAL We act on behalf of Forward Investment LLP (‘FI’). FI own major land interests in Harrogate District including the former Dunlopillo site at Pannal (referenced in the Local Plan as Mixed-Use Allocation PN15 and EC1p) and the major strategic business park known as Flaxby Green Park (referenced as EC1q) amongst many other land holdings and interests. FI object to the above listed Policies of the draft Local Plan on the basis they are UNSOUND. POLICY GS1 FI object to the Draft Policy GS1. Our Representation is that the proposed Policy is UNSOUND because: • Policy GS1 is ineffective and inconsistent with the Framework. It is ineffective because it fails to set out how the minimum housing requirement for the Plan Period will be met. No reference is made to the component parts of the proposed supply such as commitments, windfalls and allocations that the Council is relying on to deliver the minimum requirement. That information is buried in Appendix 1. The information at Appendix 1 is unclear and fails to set out the assumptions the Council is using to ensure the minimum requirement is delivered over the Plan Period. Addison Planning Consultants Ltd Registered Company Number: 08945769 VAT Registration: 186373672 • The information at Appendix 1 indicates that the Council considers its supply for the Plan period will be 16077 dwellings – set against a minimum requirement of 14,049 as set out in Policy GS1. That supply of 16077 appears to rely on 1455 dwellings through windfalls; all existing sites with Permission being delivered in full over the Plan Period; and all allocations being delivered in full over the Plan Period. It also assumes a significant contribution of 1080-dwellings from a new settlement, and 349 dwellings in the highly sensitive Crimple Valley (PN17 and PN19). • Policy GS1 will therefore be ineffective and contrary to the Framework because it fails to provide sufficient flexibility and choice; and fails to acknowledge that not all of the identified sites will come forward, to meet the minimum requirement. If for example, a new settlement cannot be delivered – reducing the supply by 1080 dwellings makes it highly unlikely that the Council has identified sufficient smaller and medium sized allocations to ensure delivery against the housing requirement. Similarly, a number of the proposed Allocations have significant constraints to delivery – and not all will be delivered. • FI are particularly concerned by the proposed Allocations PN17, PN18, PN19, PN20 – which are located in the highly sensitive Crimple Valley. These sites are one case in point – where significant constraints to delivery exist. • The list of proposed Allocations at DM1 form one component of the supply referenced in GS1 – and the proposed Allocation appears to place an over reliance on larger sites being delivered out in full by volume housebuilders; – and fails to consider the importance of identifying a significant range of smaller and medium sized sites to stimulate a resurgence in small and medium sized housebuilders. Policy GS1 Providing New Homes and Jobs - needs to be expanded to clearly set out the assumptions on which the Council is relying to deliver the minimum housing requirement over the Plan Period. From the data buried in Appendix 1 – it appears the Council is being over optimistic about its delivery trajectory and assumptions that all commitments and allocations, and a sizeable part of a new settlement will be delivered in full. Policy GS1 should also be amended to provide for greater flexibility and choice by referring to the role of small and medium sized Allocations as an essential component of the growth strategy to deliver the minimum housing requirement. This itself could do more to stimulate sustainable housing development in the District – rather than over reliance on a new settlement strategy that is fraught with difficulties. The Policy should be amended to clearly set out the approach to supply, and to introduce an emphasis on the need for smaller and medium sized allocations to stimulate choice and competition in the housing market, as well as provide a significant buffer to the minimum requirement. In short – more small and medium sized allocations are needed if the Council’s minimum housing requirement is to be realised. POLICY GS2 FI object to Draft Policy GS2. The Policy ignores the unique locational characteristics of Pannal. Whilst Pannal is identified as a Primary Service Village – it is one of the few locations in the District focused around a main transport hub of Pannal Railway Station and with excellent transport connectivity between Leeds and Harrogate. Ignoring this unique locational characteristic is a fundamental flaw in the Growth Policy and makes the Policy ineffective. Policy GS2 should be amended to set out the unique locational characteristics of Pannal; and look to direct growth towards the south of the village which is extremely well located to the existing transport infrastructure. The south of the village also benefits from new infrastructure, including 2 | P a g e a major new road to service the redevelopment of Site PN15. This infrastructure is in place and now uniquely located to accommodate additional growth. POLICY GS4 FI objects to Policy GS4. The Council has failed to undertake even a selective review of the existing Green Belt boundaries in locations which are highly sustainable. The consequence of this policy approach is that proposed allocations have been pushed to less sustainable locations. The policy is UNSOUND because: • As no review of the Green Belt has been undertaken the Council has failed to establish an evidence base to test the sustainability credentials of competing sites. The policy is therefore ineffective, because it has resulted in sites (such as PN17 and PN19) being selected as Preferred Allocations whilst competing sites (as set out below) which are more sustainable (better located to transport infrastructure with less impact on landscape) have been ignored. • The Policy of maintaining the existing Green Belt boundary isn’t justified – because the Council has failed to assess whether any sites within the Green Belt and immediately adjacent to principal growth areas, still meet the purposes of Green Belt policy. The evidence set out below suggests that selective Green Belt release to the south of Pannal would have less impact on the purposes of the Green Belt than the Allocation of the sites identified by the Council. POLICY DM1 FI are owners of proposed Mixed-Use Allocation PN15. Site PN15 (the former Dunlopillo site) is currently being redeveloped. Phase 1 (the Vida Grange care home) and main access road through the Green Belt has been completed. Phase 2, a residential development of 128 homes, has recently been sold to Bellway Homes; Reserved Matters permission has been granted and work is due to commence shortly on delivery of the 128 homes. FI either owns outright or holds options over all the land (identified on the plan below as Sites F3A, F4, F5 and F3B) bordered by the A61, railway line, Buttersdyke Bar roundabout and the former Dunlopillo site. FI objects to the identification of Sites PN17, PN18, PN19 and PN20 as proposed Allocations in the Draft Local Plan. Our Representation is that the proposed inclusion of these sites under Policy DM1 is UNSOUND because: • Insufficient smaller and medium sized allocations have been identified around the key transport node of Pannal Station to provide flexibility and choice to meet the minimum housing requirement. • The identified supply for this Primary Service Village are located in the highly sensitive Crimple Valley and are unlikely to be deliverable. • There are other available sites in Pannal that are more sustainable than the sites proposed as Allocations by the Council. Sites F3A, F4, F5 and F3B are significantly more sustainable than the Council’s own proposals within the Crimple Valley; and • There are exceptional site-specific circumstances to justify allocating Green Belt land as part of the Local Plan process (without undertaking a comprehensive Green Belt Review). This Representation sets out: • Details of a proposition to allocate land to the south of Pannal instead of land in the Crimple Valley and to protect the Crimple Valley from future development. • A summary of independent evidence that has been prepared to assess all of the development options in Pannal against landscape and Green Belt tests 3 | P a g e • The exceptional circumstances to justify the allocation of Green Belt land in this case without undertaking a comprehensive Green Belt Review THE PROPOSITION We are aware that the proposals to develop land owned by Harrogate Borough Council (PN19) in Crimple Valley are meeting with extremely stiff opposition from residents’ keen to retain the integrity of Crimple Valley and preserve the identity of Pannal as a village. The Council faces an extremely difficult challenge to deliver a lot of new houses over the next 20 years and Pannal, like a lot of other villages, will be expected to accommodate some of that growth. We consider that there is a potential scenario where the village can accommodate some growth whilst preserving the Crimple Valley. The FI proposition is: • FI would purchase the land currently proposed within Crimple Valley from Harrogate Borough Council and gift this land to the community such that it could be afforded a protected status similar to that of the Stray and made accessible as a public open space.
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