Ref: PNW00177 HMCA\Topic: Outer North East Subject: Site in the plan Site: MX2-39 - Parlington Estate, Aberford Agree with proposed use? No Soundness Consider the plan sound? No Test of soundness addressed: Positively prepared Effective Justified Consistent with NPPF Changes required to make sound: n/a Issues Issue: Other - flood risk, loss of argicultural land Flood Risks Water from the Parlington Estate drains into the Cock Beck predominantly with lesser volumes draining in to the Crow Beck. Both flow through Aberford; their confluence is close to the centre of the village. Aberford has been flooded regularly in recent years. Increasing the volume of water discharging into these rivers would increase the risk of flooding not only at Aberford but also further downstream at Tadcaster where the Cock Beck meets the river Wharfe. Tadcaster has been severely affected by flooding as recently as December 2015. The submission relating to site MX2-39 proposes the use of a ‘former “ornamental” lake’ to balance surface water run off. The lake lies within Parlington Hollins an area designated as part of the Leeds Wildlife Habitat network, a site of ecological and geological importance and an ancient woodland, thereby being a UK priority habitat. The increased risk of flooding both locally and further afield and the inadequate plans for mitigating this means this site should not be allocated. Loss of arable land Contrary to the statement in the submission by M&G UK property fund that the agricultural land is of little value Natural England’s map ‘Yorkshire & The Humber Region 1:250 000 Series Agricultural Land Classification’ indicates that land in this area is of very good quality. National Planning Policy guidance paragraph 112 says “…local planning authorities should seek to use areas of poorer quality land in preference to that of higher quality.” Building on site MX2-39 would directly contradict this guidance. Issue: Highways and transport The promoters of MX2-39 anticipate that 97% of the trips made by vehicle from the new town would leave via a single access point towards junction 47 of the A1/M1 link road and that presumably the return trips would be made in the same way. Currently at peak travel times junction 47 is dangerously inadequate to manage the volume of traffic flow. Vehicles exiting here from the direction of Leeds (67% of the predicted trips) routinely have to queue on both the hard shoulder and lane 1 of the motorway. A minimum planned build of 1850 homes would, at a conservative estimate, generate 2775 trips each morning and evening (assume an average of 1.5 journeys per household). This would increase the traffic volume at junction 47 by 1859 trips which is unsustainable. Traffic heading south east on the A656 would increase by 222 trips. This road has a junction with Church Lane Micklefield where sight lines are very restricted and a junction with Peckfield Lane industrial site which is heavily frequented at peak times by HGVs. All other roads around the proposed development are classified as B roads or are unclassified. On the B1217, Aberford Road/ Collier Lane there are two locations where traffic accidents regularly occur; Hook Moor crossroads and close to Wakefield Lodge. Increased traffic use would further increase the risk of serious accidents. The promoters of MX2-39 suggest that 2% of traffic might leave the site via Parlington Lane on to Long Lane/Barwick Road and towards Garforth. Long Lane/Barwick Road is an unclassified country road. At two points between the proposed egress and Garforth it is single lane (crossing Cock Beck and passing under the Leeds-York railway line. At Town End Garforth this road joins the A642. This is a busy and heavily used road particularly at peak times and could not meet the increased traffic demands effectively. Clearly Parlington’s location does NOT provide excellent strategic road access. Public transport Site MX2-39 is located in the Outer North East HMCA as identified by Leeds City Council. There are no rail stations within the Outer North East area. The nearest rail station at Garforth does not have the capacity to cope effectively with current levels of use at peak times. There is insufficient parking for rail users. Trains are regularly over crowded. Increasing the number of commuters using rail services is unsustainable. There is one bus service per day which passes the proposed site entrance. Accessing other bus services would require walking at least a mile. This would not be feasible for the elderly or disabled or parents with young children. Thus residents of the new town would be dependent on car travel and would exacerbate the road traffic problems identified above. Developing this site would require very significant investment in road and rail infrastructure and major improvements in public transport services. None of these are within the remit of the proposers of the development. The plan is unsound. Issue: Schools Secondary school provision in the locality is already oversubscribed. Local authorities are no longer able to open new schools. There are no plans for how secondary age pupils living in the new development will receive an education. The NPPF states that infrastructure must be in place first. New primary school places would also be required. This is alluded to only in terms of a contribution within the proposal. The plan is poorly prepared and unsound. Issue: Greenbelt The Parlington Estate is a key component of the Leeds Green Belt, serving an important function in ensuring the city and its satellite communities do not merge with consequent loss of greenfield land. It is a particularly important part of the Green Belt due to it containing Grade A agricultural farm land and several Grade II and II* listed buildings. It is a designed landscape unchanged over centuries. The proposed site contains Ancient Woodland and any change of status would damage this, and a designated site of Special Environmental and Geological Interest (SEGI) and is an integral part of the Magnesian limestone Green Infrastructure corridor as defined by Natural England and incorporated within Leeds City Councils’ Adopted Core Strategy; Building a new town at MX2-39 a few hundred metres from Barwick and Aberford is a gateway for future encroachment and the merging of Barwick, Aberford and Garforth. The NPPF and Leeds City’s own core strategy state that one purpose of Greenbelt is to stop communities from merging. The proposed arbitrary extents of MX2-39 in our view, are not defensible planning barriers and as such provide a vehicle for encroachment, coalesce and merging in the future. Land to the east of Wetherby currently locally designated as 'rural land' is not an equivalent or appropriate substitute for the prime green belt of Parlington. The greenbelt land containing MX2-39 should not be subject to a selective, isolated greenbelt review, and full and sequential review should be taken on all greenbelt in the HMCA area and the whole of the principle authority area. LCC has identified only 6% of its allocation target from brownfield land for the Outer North East Area. This is not consistent with its own register of available brownfield sites which identifies 30,000 homes as being deliverable on brownfield sites (45% of the 66,000 identified in its own core strategy). MX2-39 is unsound as any sequential test would propose brownfield, then greenfield before Green Belt. Section 9, paragraphs 79 to 92 of the NPPF articulate the clear importance ascribed to green belt land, the requirement for them to not be used for development with only limited ‘exceptional circumstances’ to this rule. These ‘exceptional circumstances’ have not been adequately defined as part of this development proposal. The use of green belt within this proposal is attempted to be addressed by the proposal itself against the 5 purposes of the green belt, as defined in paragraph 80 of the NPPF, but I do not believe these to be correct: Green Belt serves the following five purposes: 1. to check the unrestricted sprawl of large built-up areas – this proposal will increase the ‘sprawl’ of Garforth and East Garforth into the neighbouring villages (particularly when considered against the planning applications for the Garforth area) as well as a continuation of the East Leeds conurbation from say Colton and Seacroft; 2. to prevent neighbouring towns merging into one another – this proposal will have the effect of merging Barwick in Elmet, Aberford, the proposed Parlington new townand Garforth as well as linking more closely with Colton; 3. to assist in safeguarding the countryside from encroachment – this proposal will only exacerbate the likelihood of encroachment from the aforementioned areas in Garforth and even Colton. The proposed ‘defensible buffer’ is not sufficient to prevent this and will be managed by the same land holders as the proposed development with no recourse to prevent further development; 4. to preserve the setting and special character of historic towns – as discussed above the limited impact on the historic neighbouring villages is predicated on flawed assessments of traffic flows using modelling techniques that do not reflect reality and also based upon a single entry/exit point which the highways agency has assessed as being inadequate; 5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land – the use of this green belt land runs contrary to this principle as there are alternative sites such as the brownfield sites at Thorpe Arch that could take a significant proportion of house building without recourse to destroying existing green belt land; If any greenbelt land is to be considered for allocation, it should be at an appropriate percentage and on an infill basis adjoined to existing settlements and NOT a country estate containing grade II* and II listed buildings of national heritage value; All land in the ONE HMCA area should be sequentially tested in order to establish the most suitable land for development.LCC has identified only 6% of its allocation target from brownfield land for the Outer North East Area.