Defence Infrastructure Organisation Base Support Wing Headquarters RAF Brize Norton Carterton, Oxfordshire OX18 3LX United Kingdom Telephone: Ref: Dishforth/HBC-SA/May19 E-mail: Gill Ritchie Principal Planner Planning Department – Place-shaping & Economic Growth Harrogate Borough Council P.O. Box 787 Harrogate HG1 9RW By email only to: 23 May 2019 Dear Gill, HARROGATE BOROUGH COUNCIL EMERGING LOCAL PLAN – SUSTAINABILITY APPRAISAL - DISHFORTH Further to your email dated 13th May 2019 on the above matter requesting comments on the Sustainability Appraisal in respect of the Dishforth site. We thank the Planning Authority for this opportunity to comment and please see below observations made on behalf of the Secretary of State for Defence. Whilst we have been very critical of the approach taken in respect of the SA for Dishforth, we welcomed the Planning Authorities commitment to work with the MOD to bring forward proposals for the redevelopment of the site. Our comments should therefore be read in that context – to set the tone for the future work appropriately. We have no wish to delay the adoption of the Local Plan whilst such changes are being made / further work is undertaken to revise the SA. If you have any questions arising, please contact me on in the first instance. Yours sincerely, Stephen J Barrington Harness Chartered Town Planner, MSc MRTPI FWCMT 20190513 Dishforth Further Sustainability Appraisal work - OC18 Overall At the earlier stages of the Local Plan preparation we commented that the Sustainability Appraisal did not include a supporting “key” and “definitions” to assist in its scrutiny and interpretation. Again, at this stage the document does not include such information. This unnecessarily opaque approach fetters proper engagement. Why are the scores omitted for many elements without justification? That will bias assessments. Without such definitions, the danger is that an inconsistent approach could be applied between sites unduly penalising some opportunities compared to others. As you will see from the comments below, that appears to have been the case for the Dishforth assessment. No scope for mitigation of any impacts identified appears to have been included in the SA. Such an approach appears to run contrary to the aim of the Local Plan. Such strategic locations, by virtue of their size will have obvious scope to contain elements which will mitigate the impacts identified. Indeed, the Planning Policies contained elsewhere in the existing and emerging Plans would require such provision – for example, the provision of school facilities to accommodate the needs arising from the development. Due to the scale of the Dishforth site, had the MOD been consulted during the preparation of the SA; it would have been happy to confirm that the identified issues in the SA could be mitigated. No account appears to have been taken in the SA of the need to positively plan for the future of this available site and replace the skills and employment being lost to the local economy if the site was to close without a new use having been supported through the Local Plan. As such the assessment will be unduly skewed towards the development of greenfield locations. At paragraph 1.10: We would request evidence to support the statement that a “small area of land has been made available”. We would point to the fact that the area of land made available is over 106 Hectares. Bigger than many strategic sites emerging in Local Plans across the country. So by no means could be termed a “small area”. The DF7 site as you will be aware is around 107 Hectares, so the amount of land represents a 100% increase – again not a “small” addition. We suggest that this paragraph should be reworded to represent this being a major strategic level addition and the assessment reflects that throughout. Page 13 – Dishforth OC18 appraisal We would welcome greater clarity on why the ”scores” identified for Dishforth do not appear to have been applied consistently when compared to other proposed sites. For example, for SA objective 4, the site has been classed as R due to the perceived “adverse impact on local schools” but that is not backed by any evidence base or consultation with the MOD. No reference to school needs is included for the same SA objective for OC12, but that has not been explained. As stated above, the MOD would expect to provide school facilities to meet the needs arising from any houses being provided on-site. Those would be well related to the houses. The increased provision of housing in this area would mean that access to secondary schooling would become more viable again benefitting the wider community. The score should therefore be DG. For SA objective 2 a score of R has been included as it “contains features of recreation or amenity value”. That statement is not based on any evidence provided or consultation with the MOD. The site is an Airfield, as such has no public sporting or recreational facilities or public access. Should it be brought forward for redevelopment the MOD would provide for the necessary sporting and recreational facilities needed to support the development in line with Local Plan policies. Due to its scale those could be provided on-site in excellent relation to any houses being provided, also bringing benefits to the local area. The score should therefore be DG. For SA objective 6: Several scores of R have been included as it is perceived to have “Poor accessibility to all local services”. That statement is not based on any evidence provided or consultation with the MOD. It is unclear what local services are being referenced without any definition. Equally it is unclear why the score has been repeated 7 times with only one objective and only one un-evidenced justification such an approach would add undue weight to that SA objective. It can only be assumed that the same is true for the surrounding housing areas including Dishforth village in the Planning Authorities opinion. If this is an issue locally, the bringing in of additional development at Dishforth could help to address that wider issue due to economies of scale and in line with Planning Policies. In the absence of any evidence or definition from the Planning Authority the score should therefore be DG. For SA objective 7: A score of R has been included with the justification that the school “is at or near capacity and likely to require expansion”. Due to the scale of the site, should additional housing be provided, there would be scope to provide for school needs either on the site, or as an extension to the existing school supporting its role and the wider community in line with Local Plan policies. The score should therefore be DG. It is unclear why the other scores are left blank against this objective. Recognition should be included in the SA of the positive contribution that could be made through positively planning for the future of this site to support the wider community, jobs, training and skills through a mixed-use development across this strategic site. Without such scores the SA will be unduly skewed towards greenfield sites and will not have fulfilled the role of the Planning Authority to positively plan for the future of available brownfield sites. For SA objective 8: The MOD provided evidence on the biodiversity of the site as part of the local plan process – it is largely unconstrained due to its use as an Airfield. It is unclear how the Planning Authority has arrived at the scores outlined as we are not aware of them undertaking any site surveys. They can only therefore be assumed to be uninformed desktop opinions and not evidence based. A range of scores nevertheless have been applied against this objective: 1. “Some potential adverse effects on biodiversity but mitigation should enable development” in this score reference is made to mitigation potential – this differs from the approach taken elsewhere in the SA. Given the evidence provided by the MOD and its use as an Airfield, it is unclear on what this statement has been based. The score should be DG 2. “Need not lead to the loss of woodland or trees /potential for new woodland creation” – the site is an Airfield, as such is free of woodland. Provision of new woodland (see below) would therefore be a significant biodiversity gain. The score of DG is therefore appropriate. 3. “Site large enough to incorporate new natural greenspace and add to green infrastructure” again refers to mitigation inconsistent with the SA elsewhere, but appropriate. The score of DG is therefore appropriate. 4. “There are public rights of way within or close to the site” this statement is factually incorrect and inconsistent with the approach taken above. Not only would the development of this site allow the restoration of access across areas not currently publicly accessible (mitigation / enhancement); but would also link public rights of way across this area improving access for the local community. There are a number of public rights of way immediately adjacent and close to the site. Perhaps the scoring person has got confused between designated long-distance footpaths and other rights of way, for example footpaths on Highways Land? 5. “Environment Agency - impacts cannot be predicted at this stage” again without a definition of this scoring approach commenting is made difficult. By reference to the EA we presume that the range of responsibilities of that agency are part of the scoring. The MOD provided evidence in the Local Plan process on the unconstrained nature of the site. The Planning Authority has not provided any counter evidence. As such the score should be DG.