SAVE PARLINGTON ACTION GROUP RESPONSE TO INSPECTORS MATTERS, ISSUES AND QUESTIONS LEEDS SITE ALLOCATIONS PLAN EXAMINATION MATTER 5A – M5.7.2 Matter 5A – Revised Submission SAP Infrastructure Issue: Whether the necessary infrastructure will be in place to support the planned development 1. Question 1: For sites which have been brought forward in to Phase 1 in the Revised Submission SAP does the evidence demonstrate that the necessary critical infrastructure will be provided in a timely manner to support the planned delivery of development? (See Appendix 1 for relevant sites). 1.1 SPAG has reviewed the critical local and strategic infrastructure needed in order for the Parlington site to be a successful location for residential accommodation. As there is minimal infrastructure currently, and possibly no infrastructure useful to the delivery of the allocation, implementing the requisite infrastructure will be a complex and difficult process. 1.2 There is little evidence that demonstrates that the critical infrastructure will be provided in a timely manner to support the planned delivery of development of the Parlington site MX2-39. 1.3 Indeed, delivery is unlikely to occur in time for the first occupied dwelling; our comments supporting this statement are below. 1.4 Infrastructure delivery – site specific plans - In LCC’s Background Paper (CD1/35), page 10, point 1.10 the document states that the “most appropriate sites for SAP and AVLAAP allocations have been proposed having regard to planning, highways, environmental and other considerations. The site selection process has been informed by the consultee comments of infrastructure providers or technical planning consultees. Some allocations contain site specific requirements relating to infrastructure. These set out where sites cannot come forward without delivering infrastructure improvements or contributing land or payments towards locally identified priorities.” 1.5 The above is contentious regarding MX2-39. SPAG argues that there is no current infrastructure whatsoever for residential housing. The allocation of MX2-39, therefore, does not have one or two “specific requirements relating to infrastructure”, the site requires all aspects of infrastructure to be delivered before a single resident can move into a single dwelling. 1.6 MX2-39 – an unsustainable site as assessed by LCC, At the last consultation of February 2018, LCC continued to make reference to the Parlington site as: “An Area Of Land For A New Sustainable Settlement Has Been Identified At Parlington (See Plan Edged Orange (Providing For Up To 5,000 Homes)”. 1.7 At that time the Parlington site failed LCC’s own sustainability appraisal and scored badly on almost all of the Sustainability Objectives as set out in LCC’s document CD1-17 Submission Draft Sustainability Appraisal Report May 2017, page 23 section 4.24. SPAG has contended, since the outset of the SAP consultation process in 2016, that MX2-39 was, and remains, an unsustainable site because of the lack of infrastructure at and around the site. 1.8 As the site scores low on all Sustainability Appraisal objectives SPAG contends Amendment 64 for MX2-39a should NOT BE CLASSED in any LCC documentation, and certainly not be orally or verbally described, AS A SUSTAINABLE SITE. ©SPAG Page 1 of 7 JUNE 2018 SAVE PARLINGTON ACTION GROUP RESPONSE TO INSPECTORS MATTERS, ISSUES AND QUESTIONS LEEDS SITE ALLOCATIONS PLAN EXAMINATION MATTER 5A – M5.7.2 1.9 Yet LCC described the site as “… Allocated For The First Phase Of The New Sustainable Settlement (C 1,850 for 792 Dwellings) (114ha) And 5ha Of General Employment Land. A wider area of land surrounding the allocation (outlined in blue) has been designated as a Broad Location for Growth (BL42) and will potentially supplement the initial allocation subject to a further review of the Plan.”. 1.10 Accessibility and the strategic and local road network 1.11 Policy MX2-39 describes a single access road into the site from the B1217. The access road has still to be designed and the planning application process is expected to be long and drawn out. SPAG will describe the detail of the landscape that the access road has to cut into at the EiP. 1.12 LCC’s stated intention is for this access road to connect to the B1217. The B1217 is a single carriageway road that has a large volume of traffic during the working week. 1.13 In order to gain access to MX2-39 a new junction will be needed somewhere along the B1217, and this access will have to be developed from scratch. Furthermore, due to the B1217’s close proximity to the M1 J47, SPAG will explain, at the EiP, that this will create significant impediments to the current flows of traffic both during the course of building the junction, and thereafter. 1.14 Around the Parlington site the strategic road (M1, A1 or M62) and local road (A64, A63, A58 and B1217, Cattle Lane, Long Lane and Great North Road) networks are, at present, not coping with: I. The continuum of increased volume of traffic at peak times; II. The traffic jams on the non-strategic roads when there is an incident on one or more of the strategic roads; III. Traffic jams on the non-strategic roads when there is an incident on the non-strategic roads; 1.15 Strategic road network LCC’s MX2-39 plan appears to be significantly reliant on the access to the M1 at Junction 47. Highways England has stated that the M1 is unable to cope with increased traffic from a number of sources in the emerging East Leeds Extension building programme, which includes the East Leeds Orbital Route (“ELOR”), Thorpe Park (comprising retail, leisure and housing facilities), the Manston Lane Link Road and the 5,000+ houses that are expected to be built on ELOR’s western border. Inherent in LCC’s design for ELOR is access to the M1 (via Thorpe Park). 1.16 Difficulties on the strategic road network are well known and documented. Simon Jones, Spatial Planning Manager (Yorkshire, Humberside and North East) of Highways England stated the following, in his correspondence with Barwick In Elmet and Scholes Parish Council on 21st March 2018, when asked about the ability of the strategic network to cope with traffic at Junctions 46 and 47 of the M1 (his answers are in red text) i. “As further East Leeds Extension housing development comes forward, it will be necessary for site promoters with the Council to identify and mitigate their impact on the M1 in order to ensure that they do not exacerbate current levels of congestion” ©SPAG Page 2 of 7 JUNE 2018 SAVE PARLINGTON ACTION GROUP RESPONSE TO INSPECTORS MATTERS, ISSUES AND QUESTIONS LEEDS SITE ALLOCATIONS PLAN EXAMINATION MATTER 5A – M5.7.2 ii. “As stated in our Route Strategy for London to Scotland East, we are aware that congestion on the local road network causes queuing back to M1 junction 46, leading to issues on diverging slips between junction 46 and junction 47.” 1.17 The ELE does not include the Parlington site and so with Parlington the issues will become greater. However, his statement advises that it will be necessary for the site promotors to identify and mitigate their impact on the M1. 1.18 It should be noted by the Inspector that in point 2 Mr Jones appears to be laying the blame on the local roads for the current queuing of cars on the M1 north carriageway. The queues extend (tailback) from J47 M1 to J46 M1. The reality is that the local and strategic road networks cannot, in combination, cope with the current traffic situation. 1.19 Local road network 1.20 LCC does not offer any local road changes or enhancements in its SAP to accommodate the growth in traffic to and from the Parlington site, whether for building materials or earth moving equipment. Despite there being several small access roads into the site, there is no capacity for the country lanes around Parlington to enable access of heavy machinery. SPAG will explain this further at the EiP. 1.21 The existing road system does not provide easy access to MX2-39’s proposed main access road. As MX2-39’s main access route emanates from the busy B1217, SPAG highlights to the Inspector that this road traverses the M1 at J47. 1.22 SPAG contends that if a new major junction is built on the B1217 between J47 roundabout and Hook Moor, this will increase the congestion that Simon Jones refers to in his point 2 above. 1.23 The layout of the roads around Parlington’s proposed access road means that drivers wishing to access the M1 northbound and southbound can use J47 but it has its constraints and drivers wishing to drive southbound on the A1 will have to travel an extra 5 miles northbound before turning south at A1 J44. 1.24 The restrictions now seen on the poor local road network would take a long time to mitigate due to various factors including the following: I. Existing B roads surrounding the site will need to be significantly enhanced (widened and straightened); II. The strategic road system is at capacity and Highways England has not yet stated proposed any solutions to the cumulative effect of the East Leeds Extension; III. Any new roads will take a long time to plan, consult on and deliver. The exemplar for the length of time taken is the East Leeds Orbital Route (“ELOR”) which has been in the planning stage for over 20 years – as at 13th June 2018, work has still not started on the ELOR; ©SPAG Page 3 of 7 JUNE 2018 SAVE PARLINGTON ACTION GROUP RESPONSE TO INSPECTORS MATTERS, ISSUES AND QUESTIONS LEEDS SITE ALLOCATIONS PLAN EXAMINATION MATTER 5A – M5.7.2 IV.