North Ferriby Parish Council Interim Objection Pg 1 North Ferriby Parish Council (NFPC) submits an Interim Strong Objection to P.A. 20/03555/STPLF on the following grounds and will maintain this position until all the questions and points raised below (highlighted in blue) have been satisfactorily addressed directly to NFPC and on the Planning Portal or appropriate Planning Conditions are recommended by officers. FAILURE TO CONSULT The applicant failed to consult according to ERYC guidelines on the major proposal between July and late October before application and since submission in late October has only undertaken one presentation which did not allow for full engagement with the Parish Council and residents in a meaningful manner. Prior questions submitted were not fully answered or answered at all and the time allotted for residents to ask questions at the event was limited and they were unable to make their views heard. We refer to National Planning Policy Framework: Pre-application engagement and front-loading: points 39 – 42: Early engagement has significant potential to improve the efficiency and effectiveness of the planning application system for all parties. Good quality pre- application discussion enables better coordination between public and private resources and improved outcomes for the community. Local planning authorities have a key role to play in encouraging other parties to take maximum advantage of the pre-application stage. They cannot require that a developer engages with them before submitting a planning application, but they should encourage take-up of any pre-application services they offer. They should also, where they think this would be beneficial, encourage any applicants who are not already required to do so by law to engage with the local community and, where relevant, with statutory and non- statutory consultees, before submitting their applications. The more issues that can be resolved at pre-application stage, including the need to deliver improvements in infrastructure and affordable housing, the greater the benefits. For their role in the planning system to be effective and positive, statutory planning consultees will need to take the same early, pro-active approach, and provide advice in a timely manner throughout the development process. This assists local planning authorities in issuing timely decisions, helping to ensure that applicants do not experience unnecessary delays and costs. The participation of other consenting bodies in pre-application discussions should enable early consideration of all the fundamental issues relating to whether a particular development will be acceptable in principle, even where other consents relating to how a development is built or operated are needed at a later stage. Wherever possible, parallel processing of other consents should be encouraged to help speed up the process and resolve any issues as early as possible. Please explain why such a pitiful level of consultation is acceptable for a development of this magnitude? This is the largest single development in the East Riding for decades. ERYC LOCAL PLAN The application is considered incongruous with the 2016 Local Plan and ignores the Local Plan expectation of Long Plantation, Open Space and equivalent landscaping area previously provided for and the PC maintains is extant under 08/30799/CONDET, started by the then landowner when initiating the landscaping bund to the South of Plot E. Please explain how the development meets all the above aspects of the Plan? North Ferriby Parish Council Interim Objection Pg 2 CONTRARY to POLICY NFPC concurs with comments of North Ferriby resident Mr Richard Palmer – Portal date 3rd January 2021 “1. Planning Policy EC1 - In the Council's Planning Policy EC1, it states that development must be 'suitable to the location'. Para A1 refers to 'the diversification of the local economy'. Para A2 refers to a number of 'key employment sectors', which are listed. None of these include Storage & Distribution. Para A3 refers to 'employment opportunities in deprived areas'. I do not consider that the proposed development, which has attracted widespread disquiet and objection from local residents (many of whom would be directly affected by it) is in conformity with this Policy. There is no doubt that the land has for many years been zoned for business use. However, in considering possible business uses, the Planning Authority must have regard to its own policies, and the justified concerns of local residents and the Parish Council. The proposed development is for a single use, as opposed to a number of smaller units required for a variety of uses. It represents an opportunist and ill-considered rush to develop a huge site for a single use. Graduates from the West Hull villages can seldom find good quality jobs in this area. Yet it is not a 'deprived area' where low-skilled jobs will benefit the local workforce. The jobs promised would not necessarily be local, and would be of poor quality. It would be much better to allow development on the site over a period of years, according to the needs of local businesses; to encourage high tech businesses bringing quality jobs to the area; and to develop the site so that the units closest to the Long Plantation and the village are of a size and for a purpose which would not adversely affect the amenities of local residents. The current demand for large warehouse space is a phenomenon of our time. Who knows what may be the case in 10, 20 or 30 years' time when these warehouses may no longer be needed? A mixed-use organic development would provide much greater flexibility. 2. Planning Policy ENV1 - This policy includes the aim 'to safeguard and protect the diverse character and appearance of the area'. Regard is to be had to the 'site's context and the character of the surrounding area'. Development is required: to 'incorporate an appropriate mix of uses'; 'to have an appropriate scale, density, massing, height and materials'; 'to have regard to the amenity of existing/proposed properties'; 'to promote safe access movement and use'; and ;to safeguard views where necessary'. It is apparent from the plans and illustrations accompanying the Application that the proposed development seriously breaches this policy in a number of important respects. It is wholly out of context with the adjoining woods and nearby dwellings; is for a single use; is quite out of scale with the locality; and brings risks associated with vehicle movements which have, in my opinion, been glossed over in assessments submitted with the Application. Others have commented about these matters, and I merely mention that the development is for these reasons also in breach of the Policy. I have therefore concluded that the development is in breach of the Council's own Policies. And further the A63-Grade Separated Junction Scheme Report- ERYC 9 Material Consideration) PPG-13 reiterates the need for integration between planning and transport and states that developments generating substantial freight movements, such as distribution and warehousing should be located away from congested central and residential areas.” A response is requested on how this development is within policy on the aspects raised above? VISUAL Despite on 24th November promising Ward Councillors, who particularly asked for views of the site from residents’ gardens viewing westwards, no visual montages have been provided, by the applicant, to date. Placing this on the portal without time for Statutory Consultees to comment is not acceptable. North Ferriby Parish Council Interim Objection Pg 3 North Ferriby Parish Council has taken independent advice from a landscape consultancy (2B Landscape Consultancy Ltd) who state :- “I broadly concur with the findings of the TLP Review of the Application LVA, and would support its recommendations. [See Open Space section on Page 5] Visualisation In addition, I am surprised that the level of visualisation has been considered acceptable by the landscape consultant, FPCR, for the purposes of either assessing the potential impacts or communicating those effects to the Council's decision makers, or to stakeholders such as local people. As part of the team which produced the Landscape Institute's Technical Guidance Note, TGN 06/19 Visual Representation of Development Proposals Visualisation, it is disappointing to see the limited extent to which it has been adopted in this application. The document may be downloaded here https://www.landscapeinstitute.org/visualisation/ and you will see that it "was published on 17 September 2019 in support of GLVIA3". The landscape consultants are obviously aware of TGN06/19, as their viewpoint images use its descriptions of "Type 1 Visualisations". However, there is no evidence that they have implemented its key recommendations, such as: 1.1.1 This document aims to help landscape professionals, planning officers and other stakeholders in the selection, production and presentation of types of visualisation appropriate to the circumstances in which they will be used. 1.1.2 In all instances, the principles of clear, open and transparent communication and fitness for purpose should apply. Visualisations produced in accordance with this guidance should assist in informed decision-making. 1.2.9 Visualisations should provide the viewer with a fair representation of what would be likely to be seen if the proposed development is implemented and should portray the proposal in scale with its surroundings. In the context of landscape / townscape and visual impact assessment, it is crucial that visualisations are objective and sufficiently accurate for the task in hand. In short, visualisation should be fit for purpose. 1.2.12 As a general principle, any visualisation should reasonably represent the proposal in such a way that people can understand the likely landscape and visual change. The degree of detail shown will typically be relative to the design and / or planning stage that has been reached. Visualisations should assist interested parties in understanding the nature of a proposed development within its context, and its likely effects.