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Harrogate District Local Plan: Publication DraftKey Issues Report 2018

August 2018

1 Introduction 5

Local Plan Publication Draft 2018 Key Issues

2 Whole Plan 7

3 Introduction 12

4 Vision and Objectives 13

5 Harrogate District Growth Strategy 17GS1: Providing New Homes and Jobs 17GS2: Growth Strategy to 2035 23GS3: Development Limits 36GS4: Green Belt 45GS5: Supporting the District's Economy 50GS6: Sustainable Development 52GS7: Health and Wellbeing 53GS8: Nidderdale Area of Outstanding Natural Beauty 54

6 Economy 56EC1: Protection and Enhancement of Existing Employment Areas 56EC2: Expansion of Existing Businesses 59EC3: Employment Development in the Countryside 59EC4: Farm Diversification 60EC5: Town and Local Centre Management 61EC6: Protection of Tourist Facilities 62EC7: Sustainable Rural Tourism 63

7 Housing 65HS1: Housing Mix and Density 65HS2: Affordable Housing 69HS3: Self and Custom Build Housing 72HS4: Older People's Specialist Housing 77HS5: Space Standards 78HS6: Conversion of Rural Buildings for Housing 79HS7: Replacement Dwellings in the Countryside 80HS8: Extensions to Dwellings 80HS9: Rural Worker's Dwellings 80HS10: Providing for the Needs of Gypsies and Travellers 81Gypsy and Traveller Allocations 85

8 Transport and Infrastructure 89TI1: Sustainable Transport 89TI2: Protection of Transport Sites and Routes 92

Harrogate District Local Plan: Key Issues Publication Draft Harrogate Borough Council

Contents

TI3: Parking Provision 92TI4: Delivery of New Infrastructure 93TI5: Telecommunications 93TI6: Provision of Educational Facilities 95Educational Facilities Allocations 96

9 Climate Change 99CC1: Flood Risk and Sustainable Development 99CC2: Rivers 100CC3: Renewable and Low Carbon Energy 100CC4: Sustainable Design 102

10 Heritage and Placemaking 104HP1: Harrogate Town Centre Improvements 104HP2: Heritage Assets 104HP3: Local Distinctiveness 106HP4: Protecting Amenity 108HP5: Public Rights of Way 108HP6: Protection of Existing Sport, Open Space and Recreation Facilities 108HP7: New Sports, Open Space and Recreation Development 108HP8: Protection and Enhancement of Community Facilities 109HP9: Provision of New Community Facilities 110

11 Natural Environment 111NE1: Air Quality 111NE2: Water Quality 111NE3: Protecting the Natural Environment 112NE4: Landscape Character 113NE5: Green Infrastructure 115NE6: Local Green Space 116Local Green Space Allocations 117NE7: Trees and Woodland 118NE8: Protection of Agricultural Land 118NE9: Unstable and Contaminated Land 119

12 Delivery and Monitoring 122DM1: Housing Allocations 125Harrogate Sites 147Knaresborough Sites 171Ripon Sites 176Boroughbridge Sites 182Masham Site 192Pateley Bridge Site 195Birstwith Sites 196Bishop Monkton Sites 198

Harrogate Borough Council Harrogate District Local Plan: Key Issues Publication Draft

Contents

Burton Leonard Site 202Dacre Banks Site 203Darley Sites 204Dishforth Site 208Goldsborough Sites 208Green Hammerton 210Hampsthwaite Site 213Killinghall 217Kirk Hammerton 218Kirkby Malzeard Sites 220Markington Site 223Marton cum Grafton Sites 224North Stainley Sites 226Pannal Sites 229Sharow Site 234Spofforth Sites 234Staveley Site 238Summerbridge Sites 240Tockwith Site 242Commitments - Housing 244DM2: Employment Allocations 244Harrogate Site 246Melmerby Sites 247Pannal Site 249DM3: Mixed Use Allocations 253Harrogate Sites 254Knaresborough Site 257Ripon Site 258DM4: Green Hammerton/Cattal Broad Location for Growth 258

13 Sustainability Appraisal Publication Draft 2018 Key Issues 263

14 Habitat Regulations Assessment Publication Draft 2018 Key Issues 265

15 Equality Analysis Publication Draft 2018 key issues 267

Appendices

Appendix 1 Housing Trajectory 268

Appendix 2 Strategic Infrastructure Delivery 269


Contents

4Harrogate District Local Plan: Key Issues Publication Draft Harrogate Borough Council

Introduction

1 Introduction1.1 The Harrogate District Local Plan Publication Draft was subject to consultation between 26

January and 9 March 2018 and approximately 3300 individual representations were receivedto the consultation from 1562 consultees. This document identifies the main issues raisedfrom the consultation as well as providing a Council response and whether the issue resultsin a proposed modification to the plan. Sections 4 - 15 of this document highlight the keyissues for each chapter of the Draft Local Plan and general comments that were raisedduring this consultation. Sections 16 details the key issues raised in regards to theSustainability Appraisal, section 17 Habitat Regulations and section 18 Equality Analysis.

1.2 This report provides a summary of the responses made to the Publication Draft consultationin 2018. It should be noted that the report does not aim to summarise all the commentsreceived but rather to draw out and identify the key issues and/or matters that may requirefurther clarification or rewording. All the responses received can be viewed in full on theconsultation portal: http://consult.harrogate.gov.uk and will be passed onto the Inspector fortheir consideration as part of the Examination.

1.3 This document should be read alongside the Harrogate District Local Plan Submission Draft2018 : Consultation Statement(1) which provides an overview of all consultations andstakeholder involvement from the early stages of plan making to submission of the plan forExamination and also the Harrogate District Local Plan Submission Draft ProposedModifications Schedule August 2018 which details the modifications to the Local Plan thatthe Council would like the Inspector to consider.

1 https://www.harrogate.gov.uk/info/20101/planning_policy_and_the_local_plan/550/harrogate_district_local_plan_emerging


Introduction 1

http://consult.harrogate.gov.uk/

https://www.harrogate.gov.uk/info/20101/planning_policy_and_the_local_plan/550/harrogate_district_local_plan_emerging


Local Plan Publication Draft 2018 Key Issues

2 Whole Plan

Amendmentto the Plan

HBC ResponseKey Issue

Noamendment.

The council has undertaken a comprehensiveprogram of community engagement and stakeholderinvolvement which has informed the developmentof the plan.

Issues with the ConsultationThe complexity of the consultation and processfor responding feels designed to limit thenumber of responses

Reports have been published outlining how thecouncil have responded to issues raised in theconsultation. These and further details of how theconsultation was undertaken can be found inthe consultation statement.

Large numbers of previous consultationresponses have been ignored

Consultations have been carried out over aholiday period

The nature of the consultation is reflective of thestage now reached in the plan making process,where there is an obligation to publish the Draft Planand technical evidence in full.

Documents produced were complex and noteasily accessed by large sections of the public

Afterparagraph2.10 add new

The council has had on-going dialogue with itsneighbouring authorities and agreed a set of actionsand mitigation measures in response to keystrategic cross boundary issues.

Duty to Co-operateThe following organiations are satisfied that theDuty to Cooperate has been satisfied and noissues outstanding. sub heading

andparagraphto read:A separate report on how the council has

exercised its Duty to Co-Operate requirement hasbeen prepared

Hambleton District Council

'York, NorthYorkshire andEast Riding

City of York Council(2)

West Yorkshire Combined AuthorityStrategicEconomicPlan

The YNYER LEP have written in support of thePlan's housing and economic growth objectives andpolicies, specifically stating that the approach is

Selby District Council

The StrategicEconomicPlan (SEP)

North Yorkshire County Council appropriate and consistent with the YNYER SEPand reflects local economic challenges andobjectives.Environment Agency

was approvedin March 2014and an update

It would be appropriate, however, to make referenceto the SEP.Duty to Cooperate paper takes a simplistic

approach and needs to identify issues andoutcomes of engagement not just consultationand actions that have been taken.

published in2016. Thevision of theLEP is tomake York,Little information on how Council has engaged

on cross boundary issues with City of York andCity of Leeds in particular which is pertinent

NorthYorkshire andEast Ridinggiven Leeds City Council are seeking to reduce

annual housing requirement through currentCore Strategy review.

the place togrow a smallbusiness,combining aHBC has not had a sufficient level of

consultation with Central Government (DCLG),NYCC and its neighbouring planning authorities

qualitybusinesslocationwith aon the opportunities to create more long term

employment and more affordable housing inthis area of North Yorkshire.

great qualityof life.Harrogate isidentified asLittle or no evidence that HBC has adopted the

YNYER – Strategic Economic Plan – March2014 [Enterprise Partnership] ESIF –

one of thelocationswheresubmission, or even part of the strategy. Therehousing



Whole Plan 2



growth will beunlocked andemployment

is a huge void between the two strategies whichsuggests no real collaboration on the mainissues – growth of the local economy, housingand employment. sites fast

tracked, witheasingcongestion inHarrogateidentified asbeing one ofthe keyactions tofacilitate this.'

Noamendment.

Disagree. Local plan engagement has beenundertaken in accordance with the SCI.

Legal compliance (Respondentsinclude Hampsthwaite Action Group (HAG))

Local Plan engagement not undertaken inaccordance with SCI The Council has updated the Sustainability

Appraisal to address issues raised at the PublicationDraft Consultation where appropriate. The updatedSustainability Appraisal includes:

Sustainability Appraisal failed to considercumulative impact of development or fullyassess impact on heritage assets

1. a strengthened assessment of the cumulativeimpacts of the local plan.Hampsthwaite Action Group are concerned the

council did not properly consider housinggrowth reasonable alternatives following receipt 2. justification for the level of housing growth

adopted in the plan and the decision makingprocess adopted.

of the HEDNA report (in accordance with theSEA Directive) and the local community inHampsthwaite did not get an opportunity tocomment on those reasonable alternatives. Forthese reasons, the Publication Draft Local Planis neither legally compliant or sound.

3. a more detailed assessment of growthstrategies and the process involved, includingdiscussion of significance.

4. the Non-Technical Summary has beenamended so that it documents the processand conclusionsmademore comprehensivelyand reads as a stand alone document.

Paragraph 1.10 of the Non-Technical Summarygoes on to state: “The cumulative impacts ofdraft allocations have been identified on asettlement basis for Harrogate, Knaresborough,Ripon and Boroughbridge and cumulatively forthe local plan as a whole.”

The Harrogate District Local Plan SubmissionDraft August 2018 , Sustainability AppraisalVol.1 updated following Publication DraftConsultation will be included in the ExaminationLibrary (3)

Although the council states that its sustainabilityappraisal incorporates the SEADirective it doesnot address certain cumulative effects asrequired by the SEA Directive, particularly thecumulative effects of multiple housing siteallocations on communities such asHampsthwaite. Significantly, the cumulativeimpacts described by the councilwere not undertaken on a settlement basis –the sustainability appraisals were undertakenon a site by site – individual - basis and thenlisted in the document by settlement. Thecouncil’s statement in paragraph 1.10 ismisleading and wrong. HAG is concerned thatthe SEA Directive has not been fully compliedwith because cumulative impacts of multiplesite allocations at the Primary Service Village(PSV) level are not considered.


Harrogate Borough Council Harrogate District Local Plan: Key Issues Publication Draft8

2Whole Plan



Noamendment.

The final growth strategy adopted is a variation ofthose originally tested at earlier stages of the planmaking process. The SA has been updated toinclude a more detailed assessment of the process.

Tests of soundness (Respondentsinclude Hampsthwaite Action Group (HAG))

The SEA Directive reasonable alternativesrequirements were not applied properly leadingto the inclusion of Hampsthwaite in the

The assessment of cumulative impacts in the SAhas been strengthened.A more detailed assessment of growth strategiesand the process involved, including discussion ofsignificance is included in an updated SA report.

Harrogate to Pateley Bridge rural publictransport corridor as a settlement for housinggrowth.

The SEA Directive cumulative impactrequirements were not applied properly and asa result evidence demonstrating the cumulative The Harrogate District Local Plan Submission

Draft 2018 , Sustainability Appraisal Vol.1updated following Publication DraftConsultation will be included in the ExaminationLibrary

The Infrastructure Capacity Study (ICS) reportshave been available alongside the Local Plan ateach stage of consultation. At Publication Local

impacts of multiple housing sites inHampsthwaite was not considered in theevidence base.

The approach to selecting the growth optionsset out in the Local Plan document differs fromthe information provided in the sustainabilityappraisal document – suggesting that the Local

Plan stage the latest ICS and Draft InfrastructureDelivery Plan were published as supportingdocuments.

Plan preferred option for its growth strategywas not informed by the sustainability appraisal(incorporating the SEA Directive requirementson alternatives).

There is an identified residual housing requirementto be delivered during the plan period (as set out inChapter 10 of the Local Plan and the Housing

There was a flawed consultation process onthe housing need objectives, alternatives andthe need for additional sites which, if doneproperly would have informed the council whyHM9 is not required

Background Paper) and, through the Local Plan,there is a need to allocate land to ensure thisrequirement is met. The council considers that thissite can contribute to meeting this need and theapproach taken to the identification of this site isbased on reasonable evidence.HM9 assessed against other Publication Draft

Local Plan policy shows a number ofinconsistences in approach and an assessmentusing the draft policy demonstrates HM9 wouldnot be able to deliver sustainable development.

As set out in the evidence base, many sites havebeen considered through the site selection process.Sites have been allocated that are considered tooffer the greatest sustainability benefits and

The council failed to take into account keyevidence and is unable to justify HM9 as adeliverable or sustainable choice whenHampsthwaite’s infrastructure andenvironmental capacity is considered.

considerations such as the scale of development,access, and impacts on highways landscape,ecology, heritage assets and flooding were takeninto account during the site assessment process.

Potential adverse impacts of development of thesite were considered through the site assessmentprocess. Where potential adverse impacts were

The reasonable alternatives of what housingnumbers would be required to meet differenteconomic objectives were not considered at arobust political level in July 2017.

identified, it is considered that these are notinsurmountable and could potentially be mitigated,as set out in the Site Requirements. Furtherassessment of these issues will be undertaken aspart of the planning application process if requiredat this stage.

There is no evidence to support theHampsthwaite allocations HM7 and HM9(together with the other recent housingdevelopments) could be supported by existinginfrastructure capacity. Neither is there an It is recognised that new development, both

individual sites and from the cumulative impact ofseveral sites, will place extra pressure on existing

Infrastructure Delivery Plan which sets out howinfrastructure can be improved to deliversustainable development in the village. infrastructure and may need new or improved

infrastructure to support it. The council continuesto work with the County Council, utility and otherinfrastructure/service providers to make sure theinfrastructure implications of the allocated sites arefully assessed and where necessary mitigationmeasures are identified and put in place to address


Whole Plan 2



development impacts. Funding contributions fromdevelopers will be sought where needed to increasecapacity to provide local infrastructure.

The SA has been updated and includes astrengthened assessment of cumulative impacts.

The Harrogate District Local Plan Submission DraftAugust 2018 , Sustainability Appraisal Vol.1/Vol.2updated following Publication Draft Consultation willbe included in the Examination Library

Noamendment.

The response from the West Yorkshire CombinedAuthority to the Publication Local Plan confirms thatthe approach taken by the Plan would support theimplementation of the the SEP.

Legal compliance (Save Spring Lane SLADefence Group)

The council has not complied with its dutyunder the Self-Build and CustomHousebuildingAct 2015

Each local authority is required to determine its ownObjectively Assessed Housing Needs (OAHN).Leeds City Council reviewed their housing

The council has not carried out a StrategicEnvironmental Assessment (SEA) of thecumulative impacts of allocating multiple sitesin a single settlement

requirement target in the light of updated evidencerelevant to them: the OAHN for Harrogate is basedon the latest available evidence as set out in theHEDNA.The council has ignored the Leeds City Region

Strategic Economic Plan (SEP), which doesnot identify Harrogate as an area for housinggrowth

Justification for the level of housing growth adoptedin the plan and the decision making processadopted is included in the updated SA.

The Harrogate District Local Plan SubmissionDraft August 2018 , Sustainability AppraisalVol.1 updated following Publication DraftConsultation will be included in the ExaminationLibrary

Leeds City Council has reduced its housingneed by approximately 30% but HarrogateBorough Council has not reduced its target

Reasonable alternatives have not beenpresented for consultation- as required byRegulation 2(b) of the EnvironmentalAssessment of Plans and ProgrammesRegulations 2004

Noamendment.

The Infrastructure Capacity Study (ICS) reportshave been available alongside the Local Plan ateach stage of consultation. At Publication Local

Evidence Base / Infrastructure (Save Spring LaneSLA Defence Group)

The plan does not deal with infrastructure- theinfrastructure plan is not available.Infrastructure policies should be developedalongside the Local Plan

Plan stage the latest ICS and Draft InfrastructureDelivery Plan were published as supportingdocuments.

The Council are currently consulting on a CIL DraftCharging Schedule. Until this is in place the Councilwill continue to secure developer contributions for

Community Infrastructure Levy (CIL) not inplace- this makes it less likely that thenecessary infrastructure will be provided

improvements to infrastructure required as aconsequence of development through Section 106Agreements.

HBC Housing Strategy 2015-20 doesn'taddress affordability. Affordable homes mustremain permanently outside the open market

The provision of affordable housing through theplanning system must be in accordance with theaffordable housing definition in the NPPF and

HBC Economic Growth Strategy 2017-2035:is full of meaningless phrases

legislation. As such some tenures of affordablehousing can, after a certain time, be disposed of onthe open market.Inadequate assessment of infrastructure needs,

particularly traffic, education water supply andsewerage


2Whole Plan



The Council have worked with the relevant serviceor utility providers to develop the ICS, includingNorth Yorkshire County Council (as highway andeducation authority), Yorkshire Water and publictransport operators.

Noamendment.

This is a level of detail inappropriate for inclusionin the Local Plan. However, construction is anecessary activity and impacts such as noise may

The plan does not protect the viability of businessesduring the construction of development when roadsare closed or there are other obstructions whichreduce a business's footfall. be managed through conditions relating to hours of

construction on any planning permission. Someconstruction sites, companies and suppliers mayalso register with the Considerate ConstructorsScheme and abide by a Code of ConsideratePractice.

Noamendment.

The Plan has been prepared to be consistent withthe principles and policies set out in the NPPF.

Not consistent with National Policy

Plan should be withdrawn and adjusted accordinglyto comply with the revised NPPF.

Noamendment.

The council considers that the Local Plan policiesprovide an appropriate framework for developmentsto mitigate and adapt to climate change.

Climate ChangeThe plan has ducked the issue of ClimateChange as being part of sustainabledevelopment, so does not meet the UnitedNations’ nor National Guidance on sustainabledevelopment as "meeting the needs of thepresent without compromising the ability offuture generations to meet their own needs”which includes “living within the planet’senvironmental limits”.

The plan does not address climate changedirectly and does not incorporate any genuinemitigation actions within it either to meet theClimate Change Act 2008 itself or the provenchallenges of climate change. The plan talksof “encouraging” developers to think aboutclimate change, but it must “insist” on bestbuilding practice for all new homes genuinelyto reduce climate change impacts for futuregenerations, and must, also, preventdevelopers utilising viability tests to ignoreclimate change modifications incorporated intoapproved plans.

Table 2.1 Key Issues: Whole Plan


Whole Plan 2

3 Introduction

Amendment tothe Plan


In paragraph2.18 amendwording from'adoption' to'made'.

Agree.Para 2.18: neighbourhood plans are "made" andnot adopted.

Amend wording from 'adoption' to 'made'.

No amendment.The suggested amendment is consideredunnecessary as neighbourhood planning groupswould be engaged as a matter of course during thepreparation of the Local Plan.

Para 2.20: Strategic development sites should beagreed with neighbourhood planning bodies.

Add sentence “The Local Planning Authority willliaise with neighbourhood planning bodies in theselection of strategic development sites for theproper planning of neighbourhood areas."

It should be noted that whilst consensus betweenthe LPA and neighbourhood planning group on theidentification of strategic development sites wouldbe the ideal position, paragraph 16 of the NPPF isclear that those producing neighbourhood plansshould support the strategic development needs setout in Local Plans and that Neighbourhood Plansshould not be used to constrain the delivery of astrategic site allocated for development in the LocalPlan.

No amendment.Disagree. Whilst the NPPF states that local planningauthorities should set out clearly their strategicpolicies for the area, it is not specified that this should

Para 2.17 - 2.20 (Ripon City Council)

Does not adequately address paragraph 184 ofthe NPPF as it does not identify which policies arestrategic for neighbourhood planning.

be within the Local Plan. The council will provideguidance on this as part of its wider package ofsupport to Neighbourhood Planning Groups.

Strategic policies should be stated in paras 2.17-2.20 and clearly identified in the document

No amendment.Disagree. It is for Neighbourhood Planning Groupsto decide which issues are important for theircommunity and area. The council will supportneighbourhood planning groups in the developmentof their plan.

Para 2.17 - 2.20 (Ripon City Council)

Does not adequately address paragraph 185 ofthe NPPF as it does not identify which non-strategic policies could be addressed byneighbourhood plans

Wording should be added to non-strategic policieswhich are being addressed in more detail in theemerging Ripon City Plan to avoid duplication andensure that the City Plan policies are not replacedwhen the Local Plan is adopted.

Table 3.1 Key Issues: Introduction


3 Introduction

4 Vision and Objectives

Amendment to thePlan

HBC ResponseKey Issue/Suggested Modification

Vision

No amendment.The Infrastructure Delivery Schedule(Appendix 3 of the Publication Local Plan)sets out the key infrastructure

Aspirations in the vision are not supported by theInfrastructure Development Plan.

requirements on which the delivery of theplan depends. These have been identifiedfollowing discussion with infrastructureand service providers throughout thepreparation of the plan. The Councilconsiders that there is sufficient certaintythat this infrastructure can be deliveredover the plan period.

No amendment.The Council considers that the planpolicies are fully appropriate to deliverthe plan's vision and objectives.

Concern that some of policies are not fully compliantwith meeting vision and objectives.

No amendment.The Plan has planned positively forhousing growth. It is clear that thehousing requirement (in Policy GS1) is a

Requirement to boost significantly supply of housingnot reflected.

minimum provision and represents asignificant step change on that previouslyplanned for and delivered. The sitesproposed for allocation provide flexibilityensuring the housing requirement will bemet.

No amendment.The Vision as worded reflects theCouncil's corporate vision. It is alsoconsidered that historic environment iswrapped up in the phrase natural andbuilt environment.

Historic England support the vision's justification andthat the district's environmental assets will continueto be defining feature but Vision does not identify allthe elements of the environmental dimension. Asmanyelements of the historic environment are not built nornatural, vision omits a key element of the district'scharacter. (Historic England)

Amend third line of Vision to also refer to the historicenvironment

After paragraph 2.6add new paragraph(new text underlined):

Agree reference should be made to thenew settlement in the vision narrative.

Vision does not highlight importance of developmentof new settlement or reflect requirement to boostsignificantly supply of housing.

'The creation of a newsettlement in the Green

Objective 1(c) already makes referenceto the new settlementAmend vision to be bolder regarding housing supply

and reflect Objective 3. Hammerton/Cattal areahas begun, providingnew homes, jobs and

Importance of new settlement to growth strategyshould be explicitly recognised within the objectivesand submit that new settlement at Flaxby should bereferenced.

infrastructure,including primaryschools and improvedpublic transportfacilities.'

No amendment.Paragraphs 47 and 157 of the NPPFrequire Local Plans to plan for at least 15years post-adoption, therefore, thetimescale for the District Local Plan isappropriate.

The 17 year timescale is quite short for such anambitious set of policies, especially because majoraspects of several current policies (eg transport, airquality, congestion, housing for all needs and climatechange) do not seem to be facing in the necessarydirection of travel.


Vision and Objectives 4



It should also be recognised that theLocal Plan will be reviewed before theend of the Plan period. Indeed under theLocal Plan Regulations (2017) there is arequirement to undertake a review ofLocal Plans at least once every five yearsto determine whether a Plan requires tobe updated.

No amendment.It is considered that taken as a wholethe Plan seeks to address the issuesidentified through, for example, expecting

Vision not ambitious enough in addressing congestionor air quality; improving residential areas by reducingrat runs; increasing density of existing area withaccess to public transport. higher density development in locations

with good accessibility to public transport(Policy HS1).

No amendment.The Vision is aspirational but realistic.The objectives and policies in the planare in place to ensure that the vision isachievable

Amend vision to one which achievable.

This is a Utopian vision which is incapable of beingmet through the proposals, or in some cases lack ofproposals, in the Plan. (Haverah Park withBeckwithshaw Parish Council)

Rewrite the vision to give a more realistic view of thesituation considered to be attainable by 2035.

No amendmentThe phrase 'wider number of villages'encompasses Primary Service Villages.

Vision refers to main settlements and market townsand wider number of villages but is silent on PrimaryService Villages which are singled out in the GrowthStrategy as settlements for new housing siteallocations. (Hampsthwaite Action Group)

Reword the vision to included specific reference toPrimary Service Villages and recognised thatdisproportionate housing growth does not help to retainessential services in rural areas.

Recognise that some villages such as Hampsthwaitehave reached an unsustainable level of housing growthin recent years and delete housing allocations HM7and HM9.

Objectives

No amendmentObjective 1(c) already makes referenceto the new settlement

Objective 1 - Sustainable Development

Should explicitly refer to development of newsettlement as essential in order to meet district'shousing need

Amend wording to refer to new settlement.

No amendment.The Plan has planned positively forhousing growth. The sites allocated inthe Plan provide a range of sites in terms

Objective 3 - Housing

For objective to be achieved, Council must tackleproblem of housing delivery. If not, will underminedelivery of vision.

of their size, type and geography and aredeliverable. The Council looks to workproactively with developers to ensurebarriers to delivery are addressed. Thisis demonstrated by the fact that there are


4Vision and Objectives



currently pending planning applicationson 21 of the allocated sites included inthe Publication Local Plan.

No amendment.The safety and welfare of road users isa key requirement of paragraph 31 of theNPPF and the Department of Transport

Objective 4 - Infrastructure and Connectivity

Failure to identify provision of roadside facilities formotorists, including Motorway Service Areas (MSAs)contrary to NPPF paragraph 31 there are no full MSA's

Circular 02/2013 'The Strategic RoadNetwork and Delivery of SustainableDevelopment'.north of Wetherby Services until Durham MSA, a

distance of over 60 miles. Plan is not justified as itdoes not promote the most appropriate strategy forthe district.

The wording of key mechanism a) should be amendedas follows (new wording underlined):a. Facilitating thedelivery of infrastructure to accommodate and supportnew housing and employment development, andsupport the safety and welfare of road users.

The need for new infrastructure isconsidered in Policy TI4 and LPAs mayrely on the NPPF and other nationalguidance rather than replicating them intheir plans.

Significant stretch of A1(M) not served by MSA,causing serious safety risk to road users.Unreasonable for Council to rely on upgrade toLeeming Bar to meet needs of area, location of whichis unsuitable for requirement of a well-connectedMSA.

Add following as key mechanism:

'Facilitate the delivery of an appropriate MotorwayService Area along the A1(M) to meet the requiredneed and improve road safety along this corridor'

No amendmentThe purpose of an objective is to set the'goal' or aspiration and the mechanismfor addressing this is referenced in thepolicy so it is appropriate to use wordssuch as 'encourage'

Objective 5 - Natural resources and climatechange

Plan neither addresses climate change directly norincorporate any genuine mitigation actions. The plantalks of “encouraging” developers to think aboutclimate change, but it must “insist” on best buildingpractice for all new homes.

Objective 5 - amend wording to require ratherthan encourage in key mechanisms a and b.

Amend Objective 6 toread (new textunderlined): 'Conserve

Agree that objective should also refer tothe importance of the District's heritageassets.

Objective 6 - Heritage and placemaking

Heritage assets make an important contribution tothe District's identity. Essential, therefore, that LocalPlan sets out a sufficiently robust Policy framework

the historicenvironment for thebenefit of present andfor the management of this resource. Similarfuture generationsand create successfulplaces...'

to Objective 7, the plan should set out a clear intentionof conserving the historic environment for the benefitof present and future generations. (Historic England)

Amend wording to read: 'Conserve the historicenvironment for the benefit of present and futuregenerations and create successful places...'


Vision and Objectives 4



No amendmentIt is considered that as worded theobjective appropriately reflects the NPPF.

Objective 7- Natural Environment

Appears to go further than guidance set out in NPPF.

Amend wording to reflect advice in paras 17 and 109of the NPPF.

Table 4.1 Key Issues: Vision and Objectives


4Vision and Objectives

5 Harrogate District Growth StrategyKey Diagram



No AmendmentThe depiction of the new settlement is consistentwith Policy DM4 which identifies a broad locationfor growth. As stated in the policy, the boundary,

Current depiction of new settlement broad locationon key diagram fails to provide any certainty as toexact location of development.

nature and form of a new settlement within thisbroad location will be established in a separate NewSettlement Development Plan Document (DPD).

Show new settlement broad location on keydiagram as bordered boundary or similar.

No amendmentThe key diagram is only intended to bediagrammatic so the present notation is adequate.

Public transport corridor unclear - does not followgeneral routes of the existing infrastructure.

Clarify public transport corridor.

Table 5.1 Key Issues: Key Diagram

GS1: Providing New Homes and Jobs



N/AComments noted.SupportConclusions of HEDNA recognised and policyprovisions supported (NYCC)

Support minimum housing figure identified, willhelp ensure appropriate amount of new housingdevelopment takes place in sustainable ruralvillages such as Bishop Monkton

Housing Market Area

N oamendment

Notwithstanding the District is covered by morethan one housing market area (as recognised inLocal Plan paragraph 3.3) there is no requirement

HEDNA recognises that more than one housingmarketarea covering district but Plan takes no account ofdifferent geographical areas of district and housing figure

for the Council to identify a housing figure foris not broken down to housing market level or tosub-areas or settlements. The distribution ofsettlement level. Without separate figure for Riponhousing within the Local Plan takes into accounta wider range of factors than justdemographic/economic growth.

difficult to plan effectively for the future of the City eitherat strategic or neighbourhood level, including in relationto employment land and infrastructure provision. Noevidence of any dialogue in relation to co-ordinatinghousing needs in the different housing market areas(including Ripon City Council).

The Council has had on-going dialogue with theNeighbourhood Plan team in respect of housingprovision in Ripon.

Strategic housing market assessment should includeseparate assessments for the two discrete housingmarket areas based on the specific economic andmarket signals in each, including travel to work patterns,and there should be a housing figure for each.

No account given in allocation of the housingrequirement that district is covered by more than onehousing market area. Likely northern housing marketwould be subject to less intensive pressures from inwardmigration than the south of the district. Had further workbeen done on housing requirement based on a two


Harrogate District Growth Strategy 5



market approach, it is likely that the north of the districtwould have been shown to require less housing thanthe current strategy. (Ripon Residents Planning Group)

Carry out an assessment of the housing requirement inrelation to the two housing markets identified within thedistrict and make alterations to the plan accordingly(removing allocated sites from the plan in the northernmarket area); use the figure derived from demographictrends in the HEDNA (and again removing housingallocations); produce further justification for using theeconomic forecast figures and a single, district widehousing market.

HEDNA/OAN

Noamendment.

The assessment of housing need has evolved aspolicy and case law has evolved over the periodof the Local Plan preparation. In addition, the

No satisfactory explanation given for the increase inhousing need which has occurred between differentstages of plan making or for the decrease in affordablehousing need. assessment of housing need has taken into

account new data, including various editions of thehousehold forecasts that have been published,and changing market forecasts.

Reassess the housing need (including affordablehousing need) to provide a more consistent forecastand fully explain any changes.

The HEDNA (paragraph 7.12) acknowledges thatthe analysis has shown a declining affordablehousing need compared to previous assessmentsWide variation in housing forecasts in recent years is

cause for concern. in 2015 and 2016. As noted, the reality is thatfigures can vary and are specific to the point atwhich analysis is undertaken. Given that the netneed is a function of two large numbers (grossneed and gross supply) small changes can havequite a notable impact on the bottom line needsestimate.

When looking in detail at the specific figures forindividual components of need, it can be seen thatthe key difference is a reducing level of newlyforming households in need (this accounts forvirtually all of the difference in the assessments).The lower estimated number of newly forminghouseholds is largely driven be reducing projectedhousehold growth in the CLG projections ratherthan any changes to the overall affordability ofhousing or the supply of relets.

Noamendment.

The HEDNA sets out a demographic need for 410dwellings per annum but this is not the objectivelyassessed need.

HEDNA in key findings estimates need for 410 dwellingsper annum or 8,610 over plan period. As such, level ofhousing Plan is providing for is not justified.

Noamendment.

Comments noted but, the OAN is based on robustand justified evidence, as set out in the HEDNA.

Assessments undertaken by independent consultantsis a useful benchmark to gauge a more realistic OAN.

Noamendment.

The Council's OAN consultants have reviewedthe representations submitted regarding the OANand assumptions used. The Council considers theevidence remains robust and the OAN isappropriate.

Welcome increase in housing numbers and that bothhousing and employment requirements are expressedas minima.

Remain concerned that assumptions used to generatefigures, particularly housing, have suppressed the OAN.This will exacerbate affordability issue and does notrepresent positive planning.


5Harrogate District Growth Strategy



Further consideration should be given to assumptionsmade in calculating OAN. Consider that housingrequirement should be a minimum of between 750 and800 dwellings per annum.

Number of assumptions in the HEDNA have acted tosuppress the OAN figure of 669 dpa. Undertaken critiqueof HEDNA, which has evidenced alternative OAN of atleast 770 dpa.

Noamendment.

There has been substantial debate about theappropriate economic activity rate. The HEDNAhas set out the parameters of this debate andtaken the central variant.

OBR rates provide more robust basis on which toproject economic activity. OAHN should be at least 758dwellings per annum.

Amend OAHN figure to at least 758 dwellings perannum. There are a number of areas where the Experian

rate has been accepted in favour of OBR rates,including by the Inspector at the examination ofthe North West Leicestershire Local Plan, who atparagraph 108 of his report (October 2017) statedthat 'the approach of the HEDNA to economicactivity rates is logical and robust but remains tobe considered alongside factors that affectmodelling input data.' The approach in NorthWestLeicestershire was identical to that in Harrogate.

Noamendment.

The HEDNA is an objective assessment,representing a technical evidence document, whichinforms the housing and employment landrequirement; it does not set the requirement andis by no means a policy document.

HEDNA did not address the policy issue of whether itis appropriate to provide housing to facilitate jobsforecast and proposed housing requirement isessentially one designed to facilitate employment growthgreater than that required for purely demographicreasons. Such an approach not adequately explainedor justified. Although significantly higher than the demographic

starting point, planning for the higher level ofhousing is based on clear and justified evidenceHousing requirement should be reassessed in light of

Government’s suggested methodology of job growth in the strategic growth sectorsidentified in the district's adopted Economic GrowthStrategy.

The proposed level of housing growth is not justified tosupport the economy of the District, particularly giventhe associated significant environmental and socialimplications.

The responses from theWest Yorkshire CombinedAuthority and the North Yorkshire, York and EastRiding LEP to the Publication Local Plan alsoconfirm that the approach taken would support theimplementation of their respective StrategicEconomic Plans.

The standard methodology is, at this stage, tiedto the revised NPPF which remains in draft.Furthermore, the revised NPPF (paragraph 209)is clear that under the transitional arrangementsthe examination of plans submitted on or beforesix months after the date of the new NPPF'spublication will take no account of the newNPPF. On the basis of the current timescale forthe Local Plan, it is appropriate for the Council touse the current NPPF and continue with the OANidentified in the HEDNA.

Noamendment.

The impact of Brexit on household and populationprojections is considered in Section 2 of theHEDNA. However, as there are a number of

HEDNA has not sufficiently considered the impacts ofBrexit on the UK economy and needs to be adjusted totake more realistic view of recent forecasts.

unknowns in relation to the final deal which will be





agreed and its impact on migration, this does notprovide a clear basis for the HEDNA to adjust theOAN based on a 'Brexit' scenario.

As historically housing targets have not been met wouldhave expected plan to include strategy as to how it isintended to achieve this Plan's housing target or to haveincluded an achievable target.

The Delivery and Monitoring Chapter of the LocalPlan sets out the actions the Council will take if itbecomes apparent through monitoring that thehousing trajectory is not being met.

HEDNA has ignored impact of Brexit, recent informationsuggests 13% reduction in economic activity in north ofEngland due to Brexit. Economic uplift applied isexaggerated and not justified, resulting in unattainableannual housing target.

Noamendment

The Council are planning for a level of housingwhich meets the job target not encouragingemployment growth through additionalhousebuilding, although this may be an outcomeof the policy.

Economic uplift exaggerated and not justified resultingin unattainable annual and five year housing land supplytarget, which Plan seeks to achieve by allocations inareas which will not enable sustainable development(Hampsthwaite Action Group).

Review OAN and produce more realistic OAN figure.

Standardised Methodology

Noamendment.

The standard methodology should not render thelatest objectively assessed housing needassessment i.e. the HEDNA out of date.

Council chosen to proceed on basis of HEDNA ratherthan standardised methodology, as limited differencebetween the two base figures. Using latest householdprojections and house price/earnings ratios, use ofstandardised methodology would give substantiallydifferent outcome in the order of 530dpa. Failure to meetOAN would render plan unsound.

In any case the standard methodology is, at thisstage, tied to the revised NPPF which remains indraft. Furthermore, the revised NPPF (paragraph209) is clear that under the transitional

HBC should use the standard methodology figure of395.

arrangements the examination of plans submittedon or before six months after the date of the newNPPF's publication will take no account of the newNPPF. On the basis of the current timescale forthe Local Plan, it is appropriate for the Council touse the current NPPF and continue with the OANidentified in the HEDNA.

Targets/flexibility

Noamendment.

Policy GS1 states that the housing andemployment land figures are aminimum provisionover the plan period, demonstrating the Council'sapproach to meeting the needs of the district infull, as well as providing flexibility.

Sufficient flexibility should be retained by ensuring targetfigures are kept to minimum should there be need toincrease figure if circumstances dictate.

Agree housing target should be expressed as aminimum requirement rather than a ceiling. Alsoimportant provision provides flexibility to respond to National policy does not require a buffer to be

added to the OAN. However, the Local Plan, interms of the number/type of sites proposed for

changing circumstances or policy aspirations, such aseconomic growth (Defence Infrastructure Organisation(DIO)). allocation, provides a degree of flexibility so that

in the event sites do not come forward whenanticipated or deliver the yield expected, thehousing requirement will be met.

Expected delivery does not meet extra 20% buffer inaddition to OAN as required by para 47 of the NPPF.

Increase expected delivery of homes to 16,858dwellings.

Should provide mechanism to enable release of furthersites should land supply fall below 5 years.

Noamendment.

Noted. However, to avoid unnecessary duplicationthe Council's preferred approach is for this detailtogether with information on the preferred

Policy is ineffective because it fails to set out howminimum housing requirement will be met or referencecomponent parts of the proposed supply and information





on this in Appendix 1 is unclear. Fails to providesufficient flexibility and choice or acknowledge not allidentified sites will come forward.

allocations to be set out in a single chapter.Paragraph 3.5 clearly refers to this informationbeing contained in Chapter 10: Delivery andMonitoring.

Amend policy to set out assumptions being relied on todeliver minimum housing requirement.

Noamendment.

The NPPF requires the Council to prepare a LocalPlan based on a strategy which seeks to meetobjectively assessed development requirements.

Targets for housing and employment are excessiveand would lead to substantial loss of attractivecountryside.

The number of dwellings and amount ofemployment land to be provided for, and as setReduce Housing Target to 970 new homes and

employment land allocations to 27.5 hectares. Deletereferences to inward investment.

out in Policy GS1, are informed by an objectiveassessment of housing and employment needsover the plan period.

Affordable Housing

Noamendment

The HEDNA acknowledges affordability pressuresacross the district which would justify an uplift formarket signals. However, the HEDNA concludes

As delivery of affordable housing and tackling theaffordability issue in Harrogate is a fundamentalobjective of the Plan, it is considered that 669 dpa is theabsolute minimum level of housing required to start toaddress these issues.

that as the economic-led housing need issubstantially higher, and will provide additionalaffordable housing through increased developercontributions, an uplift is not warranted.

As stated in the PPG (paragraph 19) anyadjustment in response to worsening marketsignals should result in an adjustment to the'household projection (the starting point)'.Therefore, if this were to occur then the economicuplift would be lessened, however, the OAN wouldbe unaffected.

Noamendment.

There is no necessity to allocate sites as indicatedby the respondent, as limited affordable housingfor local community needs would, under the NPPF,not be considered to be inappropriate developmentin the Green Belt.

Proposed approach to affordable housing delivery doesnot afford any certainty in provision nor address needin those locations which are not the focus for furtheropen market housing development (i.e. green beltsettlements/parishes). The option to allocate land forsuch purposes should be accommodated, including thatat Spofforth Lane, Follifoot (site FF1).

Older Persons Housing

Noamendment.

Policy HS1 requires new development to providea wide mix of homes to meet the range of housingneeds and demands of the District's residents: this

Housing requirement does not take account of full needsarising from specialist housing, particularly need forolder people’s accommodation.

will cater for all type of housing needs, includinghousing suitable for older people. Policy HS4 dealswith the provision of housing specifically designedfor older people.

Review housing requirement and address shortcomingsregarding specialist housing, particularly housing forolder people.

Economy

Noamendment.

Through the retention of key employment sites andthe provision of new sites, the Plan seeks toprovide a portfolio of sites to support both thoseexisting businesses seeking to grow and thoseseeking to invest in the district.

Not clear how economic sectors other than thoseidentified as driver's for growth will be treated. (RiponCity Council).

Add text to clarify the approach for other economicsectors.





Noamendment.

Noted. The Local Plan allocates over 18 hectaresof new employment land on sites in Harrogate andalso seeks to protect key employment sites frombeing lost to non-employment uses (through PolicyEC1).

Employment growth in Harrogate must match housinggrowth to avoid the town becoming a dormitory town.

Welcome general increase in employment landprovision but concern over lack of new land allocationsand threats to existing and proposed employment siteswithin Harrogate.

Noamendment.

Noted, however as set out in the HEDNA theforecast economic growth has been converted tofloorspace per B Use Class and then a landrequirement.

Assessment of employment land requirements takesno account of fact that high earning jobs Council is keento create actually require less space per employee thantraditional manufacturing, distribution and retail (whichare all low paid).

Noamendment.

The HEDNA was published in July 2017 and wasprepared on the basis of the latest availableinformation at the time of writing.

Forecasts for future economic growth have beendowngraded, therefore, figure of 1.9% used in HEDNAshould be revised down.

General

Noamendment.

An Open Space, Outdoor Sports and BuiltFacilities Study has been commissioned, with areport expected by summer 2019.

Need to prepare an up-to-date indoor sports facility studyand review approach towards securing sports facilityprovision through the growth proposed as set out inGS1. (Sport England)

Noamendment.

As an independent, objective assessment, directconsultation on the HEDNA would not beappropriate.

No opportunity was given to the public or ParishCouncils to input into the preparation or comment onthe HEDNA. (Hampsthwaite Action Group)

However, at the Additional Sites consultation stage(under Regulation 18), consultees were specificallyinvited (under Question 1) to make comments onthe updated evidence base: this included theHEDNA (July 2017), which was made availableas part of the consultation.

Regulation 19 stage (Publication Local Plan)allowed for further comment on the outputs of theHEDNA.

Noamendment.

The NPPF requires the Council to prepare a LocalPlan based on a strategy which seeks to meetobjectively assessed development requirements,

SA did not consider the environmental or social impactsof alternative growth options. Alternatives such as pasttrends, less development and different levels of growthshould have been considered in the context of therelationship of the District with adjacent authorities.

unless there is a lack of physical capacity or anyadverse impacts of doing so would significantlyand demonstrably outweigh the benefits. TheCouncil's evidence demonstrates that there areno fundamental constraints to delivery in terms ofland availability, viability, environmental capacityand infrastructure capacity. As such, there isconsidered to be no justification for the Local Planto seek to plan for less than the OAN. The SAconsidered the impacts of alternative growthoptions for delivering the assessed developmentrequirements.

Noamendment.

In deciding to make allocations within the AONB,the Council has given consideration to meetingthe local and affordable housing needs of

The plan does not place enough emphasis on protectingthe AONB (as per para 115 of the NPPF) and is notjustified in building so many houses in theAONB. Developments over 10 houses should not beallowed within any of the Nidderdale AONB villages.

communities within the AONB. The potential fornew development to have an impact on thelandscape character and visual amenity of theAONB and whether any impact could be mitigatedDo not allow any developments over 10 houses within

any of the Nidderdale AONB villages. has been carefully considered in identifying sites





for allocation. The Council consider this to be theappropriate approach rather limiting the size ofsites as suggested by the respondent.

Noamendment.

Wetherby is identified in the adopted Leeds CoreStrategy as a Major Settlement and the emergingLeeds Site Allocations Plan proposes housing andemployment allocations reflective of this.

Growth strategy ignores influence and contribution ofWetherby as main service settlement and focus forgrowth and ramifications this may have for HarrogateDistrict.

Whilst it is recognised that Wetherby will have aninfluence on the south eastern part of the district,any allocations within Harrogate district are likely

Duty to Cooperate Paper does not address this to anymeaningful degree or potential unmet needs of aneighbouring authority being addressed or expresslyconsidered. to primarily be of benefit to meeting the housing

and economic needs ofWetherby rather than thoseof Harrogate.South eastern part of district influenced by York/Leeds

and role of land peripheral to Wetherby and influence itcould have on mitigating 'pull' further beyond localauthority boundary ignored.

It should also be recognised that discussions, aspart of the duty to co-operate, with Leeds CityCouncil have not identified the need for any partof their housing requirement or any otherdevelopment needs to bemet in Harrogate District.

Change Key Diagram to identify Wetherby as area forpotential growth and allocate appropriate degree ofemployment land.

Noamendment.

In calculating the residual housing requirement tobe provided for through the making of allocations,the number of dwellings to be delivered from siteswith an extant planning permission is accountedfor.

Concern regarding the impact of landbanking and theimpacts of a post-brexit scenario (falling EU migration)and further concern regarding the inadequacy of localinfrastructure.

Request audit and appraisal of existing unfulfilledplanning permissions. Review housing targetaccordingly.

Table 5.2 Key Issues: Policy GS1 Providing New Homes and Jobs

GS2: Growth Strategy to 2035



No amendment.Noted.Designation of following are supported:Primary Service Village - Pannal

Primary Service Village - Hampsthwaite

Secondary Service Village - Bishop Monkton,Marton cum Grafton

No amendment.Noted.Growth strategy supported. Provision ofmaintaining or enhancing services and facilitiesin rural villages is particularly welcome.

Growth Strategy is logical, provides clear structuralhierarchy of where development will beencouraged. Direction of small scale windfall androunding off is strongly supported.





Broadly support Policy provisions A-D. Welcomethat "New Settlement" proposal is now excludedfrom formal hierarchy: distinction between existinghierarchy and that which may emerge at end ofplan period is appropriate approach.

Broadly support proposed growth strategy,acknowledge threemain settlements offer greatestrange of jobs, shops and services.

Support aims and objectives of Policy and locatinggrowth in or around main settlements assequential first priority.

Policy wording

No amendment.The amendment suggested is consideredunnecessary as the impact of development onlandscape character is covered by Policy NE4(Landscape Character).

Criterion A - essential any development is appropriatefor its context and will not harm the elements whichcontribute to district's distinctive character, a key elementof which is the landscape setting of district's towns andvillages. (Historic England)

Amend Criterion A to read: 'The settlement's role,character and landscape setting'

No amendment.Support noted. The impact of development oncommunity facilities or social infrastructurewould be considered under Policy TI4 (Deliveryof New Infrastructure).

Support designation of Pannal as a Primary ServiceVillage and the allocation of growth reflective of the roleand character of the village.

Part G should be expanded to require development toenhance the sustainability of community infrastructure,to specifically include school provision within the Policy.

Settlement Hierarchy

No amendment.The Council's approach to the classificationof settlements in the hierarchy seeks to reflectthe service role of a settlement. The

The settlement hierarchy needs to include an elementof flexibility so that there is the option and ability forvillages and settlements to traverse the hierarchy if they

classification of settlements does not placeimprove the services and facilities available. Therereliance on the presence of a particular facility,should be also be some consideration of widerwhich would allow for changes to service anddemographic information and the vitality of a place when

considering the 'role' of villages as service centres orhubs.

facility availability in a settlement over the planperiod to be accommodated. However, whetherthere should be any change to thecategorisation of a settlement in the hierarchywould be most appropriately considered aspart of any Local Plan review.

Request changes to the criteria at Policy GS2 toemphasise the 'opportunity' rather than the 'need' tomaintain or enhance services and facilities in ruralvillages and to deliver new homes as there is no test ofneed within the NPPF.

No amendment.The Council's approach to the classificationof settlements in the hierarchy is based on theavailability of community facilities, key public

Burton Leonard should be identified as a PrimaryService Village.

services and retail, service and leisurebusinesses in a settlement, as set out in theSettlement Hierarchy Background Paper(2016).





The Council's facilities research concluded thatBurton Leonard did not have the range offacilities and services to be classed as aPrimary Service Village.

No amendment.Under the Council's approach to theclassification of settlements Bickerton doesnot not have the range of facilities and servicesto be classed as a smaller village.

Expected Bickerton would have been identified as asmaller village. Has 80+ dwellings, sustainable due toproximity to Wetherby, links to key employment areasand benefits from from York/Wetherby bus service.Number of identified smaller villages which are lesssustainable.

Include Bickerton in settlement hierarchy as smallervillage

No amendmentThe classification of Boroughbridge as a LocalService Centre, reflects its role as one of thedistrict's smaller market towns. It is consideredunnecessary to amend the classification.

May be case for status ofBoroughbridge to be elevatedwithin settlement hierarchy given ability to accommodategrowth.

No amendmentThe Council's approach to the classificationof settlements in the hierarchy is based on theavailability of community facilities, key public

Categorisation of Staveley does not take into accountthe small population and limited extent of local facilities.Staveley no longer has a cricket club as recorded in thebackground paper. services and retail, service and leisure

businesses in a settlement, rather than thepopulation size of that settlement.Staveley should be categorised as a smaller village.

The Council's facilities research concludedthat Staveley had the range of facilities andservices to be classed as a Secondary ServiceVillage. As there is other recreational provisionin the village, the loss of the cricket club wouldnot lead to a changed conclusion.

No amendment.The development of the new settlement overthe plan period and beyond is recognised inPolicy GS2. However, it is considered

Importance of provision of new settlement should bereflected in development hierarchy as a strategicdevelopment providing a significant number of newhomes over the plan period. appropriate to differentiate the new settlement

from existing settlements and, therefore, at thisstage exclude it from the settlement hierarchy.Re-insert new settlement into the development hierarchy.

No amendment.Wetherby is identified in the adopted LeedsCore Strategy as a Major Settlement and theemerging Leeds Site Allocations Plan proposeshousing and employment allocations reflectiveof this.

Local Plan should acknowledge opportunity for growtharoundWetherby, as Local Plans should consider crossboundary issues, and should apply same growth strategyto Wetherby as proposed for main settlements withinthe district. Otherwise land around western extent ofWetherby would be prevented from being consideredfor growth despite its sustainable location, solely becauseit lies within a different local authority area.

Discussions, as part of the duty to co-operate,with Leeds City Council have not identified theneed for any part of their housing requirementor any other development needs to be met inHarrogate District.

Policy should acknowledge opportunity for growth atWetherby.

No amendment.Under the Council's approach to theclassification of settlements, a smaller villagewould posses a recreational facility (the

Cowthorpe does not meet the criteria to be categorisedas a smaller villager. There is no community facility asthe play park is small with only 3 pieces of play

approach adopted does not require this to beequipment and no ball games are allowed. The churchhas no facilities and attempts at community use havefailed. (Cowthorpe Community Forum)

of a specific size or type of facility) and a villagehall or place of worship. In the case of





Cowthorpe, as there is a recreational facility,albeit small, and a church it has the level offacilities to be classed as a smaller village.

Remove Cowthorpe from Smaller Village category.

Cowthorpe should not be designated a Smaller Villageas : does not have functional community facility, no busservice or convenient access to public transport, noevidence of necessary investment in infrastructure, noevidence of need for further market housing in village.(Tockwith with Wilstrop Parish Council)

Delete Smaller Village designation from Cowthorpe.

No amendmentUnder the Council's approach to theclassification of settlements, Ferrensby doesnot not have the range of facilities and servicesto be classed as a smaller village.

Ferrensby should be identified as a Smaller Village.Accessible by public transport, opportunities for limitedrounding off and infill, development would support ruralfacilities.

Include Ferrensby in settlement hierarchy as smallervillage.

No amendmentThe Council's facilities research concludedthat Hampsthwaite has the range of facilitiesand services to be classed as a Primary

Hampsthwaite should not be identified as being locatedon a key public transport or defined as a primary servicevillage because:

Service Village. The village is located on oneof the six strategic bus routes identified in thelimited level of services and facilitiesLocal Plan - the Harrogate to Pateley Bridgeroute where the service frequency is an hourlypublic transport is limiteddaytime service Monday - Saturday. There aremajor existing employment sites on the westernall major employment sites are on the east of

Harrogate side of Harrogate (at Cardale Park) and theLocal Plan proposes a further 8 hectares ofemployment land as part of a mixed useallocation (H51).Removal of the reference to Hampsthwaite being located

on the key public transport corridor and thereclassification of Hampsthwaite from Primary ServiceVillage to Secondary Service Village

No amendment.As set out in the Settlement HierarchyBackground Paper (2016), in addition to thelevel of services and facilities available,

Cluster of Fearby and Healey should be designated aSecondary Service Village.

settlements included within the hierarchy needDesignate Fearby and Healy a Secondary ServiceVillage. to have a pattern of development that allows

a development limit to be defined. Therefore,an additional requirement for inclusion in thehierarchy is that a settlement must have a welldefined built up area. In the case of Fearbyand Healey it was concluded that a well definedbuilt up area could not be defined and as aresult they were excluded from the hierarchy.

Site allocations

No amendment.Follifoot lies wholly within the Green Belt andas such it would not be appropriate to makespecific allocations for new development.

Whilst broadly support proposed growth strategy,Follifoot is a sustainable village and should berecognised as such with allocation of housing sites.

No amendment.It is recognised that the new settlement isunlikely to start to deliver housing until mid planperiod. As such a range of other sites around

Plan would not be effective if delivery from newsettlement was relied on within plan period, additionalsites should be allocated to ensure identified housingneed can be met. existing settlements are allocated in the Local

Plan to ensure sufficient housing supply in the





Generally support growth strategy and identification ofKillinghall as Primary Service Village but have significantconcerns with the identification of a broad area of growth

early part of the plan period. Indeed a numberof the Local Plan allocations benefit fromplanning permission or are the subject ofcurrent planning applications.for a new settlement. If the new settlement is proven to

be deliverable and a viable option to pursue, it is highlyunlikely to delivery many, if any units, by the end of thePlan period. As such, query whether need to identifyadditional small scale housing sites across the districtto delivery housing before any new settlement isestablished.

Insufficient land has been identified to meet housingneeds. In preference to new settlement, new housingallocations should be identified in primary settlementsincluding Hampsthwaite.

Increase overall housing requirement. Delete proposednew settlement and identify additional allocations inlarger primary settlements.

No amendment.It is considered that the sites identified inTockwith provide for a level of newdevelopment that is commensurate to the roleand character of the village.

Whilst support identification of Tockwith as PrimaryService Village, there are opportunities for furtherallocations in village.

No amendment.It is not considered necessary to addadditional text as it is self evident that newdevelopment within these settlements is animportant part of the overall strategy.

Strongly support direction of growth to Primary ServiceVillages but important role of residential development inthese locations as central component to overall growthstrategy should be more robustly recognised insupporting text.

No amendment.The Local Plan makes allocations with apotential yield of 750 dwellings: this isconsidered commensurate with the role andcharacter of Boroughbridge.

Recognition ofBoroughbridge as a local service centreis not reflected in the scale of housing proposed by theplan.

No amendment.Whilst all sites within these settlements havebeen carefully assessed it has not beenpossible to identify sites for development in all.

Plan is not enabling or encouraging of sustainabledevelopment in Secondary Service Villages.

Despite policy supporting allocations in secondaryservice villages, failed to identify sites that would be inaccordance with policy.

However, 21 of the housing sites allocated arewithin Secondary Service Villages and, as awhole, the policies of the Local Plan wouldsupport appropriate development in SecondaryService Villages on other sites.

No amendment.The approach provides for a level of newdevelopment that is considered commensurateto the role and character of these villages.

Whilst support direction of small scale windfall androunding to smaller villages, policy could go further andallocate sites to ensure and safeguard certainty overdelivery of sites.

Amend supporting text to more overtly recognisecontribution made by smaller villages to overall housingdelivery.

Small scale growth should be provided for in SmallerVillages, such as Little Ribston, through the allocationof specific sites. Approach takes no account of whethersettlement is located in defined public transport corridor,which is key factor in Policy. Allowing some growth wouldprovide local housing choice and support viability ofservices. Flexibility provided by Policy GS3 regardingwindfall development does not give certainty of delivery.





Make housing allocations in those Smaller Villages welllocated in relation to larger settlements and which havepublic transport access.

Allocations should be made in Smaller Villages as wouldprovide more certainty on delivery. Consider Minskipand Whixley to be sustainable locations with goodtransport links and facilities available locally whereallocations should be made.

Allow for specific allocations in Smaller Villages.

Should bemore robust and positive approach to housingdelivery and lack of any housing allocation in NorthRigton should be addressed

Should be more robust and positive approach tohousing delivery and lack of any housing allocation inFarnham should be addressed

Given compelling need for new housing Local Planshould allocate further sites, including suitable site inKirk Deighton

No amendment.The level of development proposed reflectsthe good public transport connections ofPannal and considered to be commensurateto its role as a Primary Service Village.

Policy ignores unique locational characteristics ofPannal (focus around transport hub and connectivitybetween Leeds and Harrogate).

Amend policy to reflect unique characteristics of Pannal'slocation to existing public transport and new roadinfrastructure.

No amendment.As at the end of March 2018, there were 20dwellings with planning permission wheredevelopment had yet to start and a further twounder construction (within the Parish).

Constitutes an over development of Darley as it takesno account of the significant developments grantedapproval in the village already.

Draft Local Plan needs to be brought in line with NationalPolicy regarding development within the AONB.Formulating a strategy that shares development equitably

In deciding to make allocations within theAONB, the Council has given consideration tomeeting the local and affordable housing needsacross settlements; focusing on the needs of local peopleof communities within the AONB. The potentialie: affordable housing and favoring small sympatheticallyfor new development to have an impact on thedesigned schemes. Believe this approach would deliver

a sound Local Plan for future development whilstmaintaining the special value of the AONB.

landscape character and visual amenity of theAONB and whether any impact could bemitigated has been carefully considered inidentifying sites for allocation.

No amendment.It is not considered necessary to add additionaltext as this is self evident from paragraph 3.19.

Support identification of Masham as Local ServiceCentre, but Plan needs to more widely recognise thereliance which Masham and its rural hinterland have oneach other.

New Settlement

No amendment.The Local Plan does not solely rely on a newsettlement: there are nearly 80 other sitesidentified in the main settlements or other

Support growth hierarchy and emphasis on main townsto provide new development. Do not object to approachto new settlement but should be recognised as longer

settlements in the settlement hierarchy, whichterm vision and seen as additional to requirements ofwill deliver housing across the plan period.this plan period. Delivery from new settlement appearsHowever, there are insufficient suitable andoptimistic, starting significantly later than 2024 by which

time replacement plan should be an advanced stage ofpreparation.





Whilst broadly agree with settlement hierarchy, disagreewith justification for new settlement. Distracts from pointthere are suitable alternative greenfield extensionsaround settlements in hierarchy that could be utilised.

deliverable sites in these settlements to meetthe district's full objectively assessed housingneed.

The Council reviewed the options for thelocation of a new settlement, as set out in theNewSettlement Background Paper (November

Whilst recognise why settlements have been identifiedin hierarchy consider level of development or type/sizeof sites allocated to number of them tobe disproportionate.

2017) but for the reasons set out in theBackground Paper remain satisfied that theGreen Hammerton/Cattal area is the rightlocation for a new settlement.Consider Flaxby to better location for new settlement.

Consideration should also be given to second majorhousing development in area of J49 A1(M) to avoid needto ruin district's villages.

The approach of having a second newsettlement could result in too much focus beingtaken away from other locations, whereessential infrastructure improvements areneeded to ensure their long term sustainability.Rather than allocated sites which are inappropriate and

harmful to character of Harrogate, Local Plan shouldinclude additional new settlements. Site OC11 is bestsite for sustainable transport of all new settlementalternatives considered.

Identify land west of Ripon Road A61 (site OC11) asadditional new settlement location

Identification of broad location raises conflict withobjectives of growth strategy which seek to control scaleof new development to respect the role and characterof existing settlements.

Delete broad location for growth and replace with specificsite allocation at Flaxby.

Employment allocations

No amendment.The site was not included in the PublicationLocal Plan as an employment allocationfollowing updated evidence from the HEDNA

Support direction of growth to Tockwith as housing andemployment development crucial to sustain services andfacilities. To prevent occupiers looking elsewhere for

(July 2017). This recommended that as the sitepremises, need for continued investment and expansionwas unlikely to attract commercial interest, duein business park. Lack of current available floorspaceto accessibility, it should not be identified aswill compound outwardmigration of businesses and work

force. To meet aspirations of Policy GS2, employmentallocation TW2 should be re-instated.

Re-instate employment allocation to north of MarstonBusiness Park (TW2)

an allocation for employment uses.Notwithstanding this, the policies of the LocalPlan would not preclude development thatsupported the continued employment use ofthe site.

No amendment.The Local Plan proposes new employmentdevelopment as part of the mixed usedevelopment on the Ripon Barracks site and

Ripon has a different travel to work area and is less wellconnected than Harrogate and Knaresborough but thereis little to support the development of employment in

also seeks to protect key employment sites inthe City from being lost to non-employmentuses (through Policy EC1).

Ripon. Close proximity of A1(M) will mean significanthousing in Ripon is likely to lead to unsustainable carcommuting.

No amendment.A strategic employment site is allocated atA1(M) J47, which now has the benefit ofplanning permission.

Further concentrating employment at Cardale Park inHarrogate will lead to increased congestion - employmentuses should be located near the A1.

Traffic modelling work indicates that theproposed allocation at Cardale Park can beaccommodated with mitigation.

Employment should be located near A1.





No amendment.The allocated sites provide a range of sites interms of size, type and location suitable forexisting and new businesses within the

The ‘higher value’ growth sectors in the Council’sEconomic Growth Strategy are not aligned fully to itsemployment land allocations. Lack of a higher education

identified growth sectors. However,community and proximity of university cities with scienceemployment provision is not confined to theparks and incubator units will hamper significantallocated sites. The Plan's economic policiesas a whole seek to support the developmentof new employment floorspace.

expansion of this scientific research and developmentsector; lack of road capacity in the District precludesdevelopment of this sector other than along the A1corridor.

No amendment.The NPPF requires the Council to prepare aLocal Plan based on a strategy that seeks tomeet objectively assessed development

The statement that ‘the success of the Harrogate districtas a business location is, in part, due to its attractivebuilt and natural environments and its highly skilled

requirements and the allocations proposed areworkforce’ requires comment. The proposed landrequired to meet these assessed requirements.allocations are of such magnitude and location that they

will adversely affect the attractive built and naturalenvironment.

The landscape and environmental impacts ofdeveloping the allocated sites and mitigationmeasures, if required, formed part of the siteassessment process .

Site selection

No amendment.The NPPF is clear that Green Belt boundariesshould only be altered in exceptionalcircumstances. The Green Belt Background

Support approach of identifyingmajor housing allocationson urban extensions on edge of Harrogate but consideroverall approach to site selection is unsound and not

Paper (2016) sets out the reasons why thefully justified as being most appropriate strategy.Council has concluded that it does not need toSpecifically concerned with how review of Green Beltundertake a Green Belt review in order to meethas been dealt with when considered against otherthe emerging plan requirements in a way thatalternative options such as a new settlement. On basisrepresents sustainable development. Theinsufficient suitable and available sites within maingovernment has re-iterated its commitment tosettlements without either releasing Green Belt orthe protection of the Green Belt. Most recentlycreating new settlement, creates two alternativein the draft revised NPPF they make clear thatstrategies that should be fully tested against each other.Green Belt boundaries should only beSuitability of sites identified as draft allocations,amended where exceptional circumstancescan be demonstrated having explored all otherreasonable options.

significantly influenced by not amending Green Belt,given less weight to principles of delivering sustainabledevelopment in favour of protection of Green Belt at allcosts.

Evidence base should fully explore and review releaseof Green Belt to provide sustainable patterns ofdevelopment.

As there are other options for meetingdevelopment needs in the district the Councilis of the view that the exceptionalcircumstances to trigger a Green Belt reviewcannot be demonstrated.

No amendment.It is considered that the proposed housingsupply is robust and provides sufficientflexibility. The allocated sites provide a range

Growth strategy places over reliance on larger sitesbeing delivered by volume housebuilders. Fails to provideflexibility and choice or consider importance of identifyingrange of smaller sites to accommodate small/mediumsized housebuilders.

Amend policy to provide emphasis on need for smallerallocations.

of sites in terms of their size (29 of the siteshave an indicative capacity of 50 or lessdwellings), type and geography and aredeliverable. This is demonstrated by the factthat there are currently pending planningapplications on 21 of the allocated sitesincluded in the Publication Local Plan.

To reduce housing shortfall, priority should be given tosites free from constraints, benefit from end developerand which can be delivered early in plan period.

Amend policy to emphasise need to deliver housing inshorter term and sites able to deliver in early plan periodwill be considered positively.

Additional flexibility is provided through theDevelopment Limit policy for small scaledevelopment.





No amendment.All sites have been assessed through theSustainability Appraisal process. The 2016Draft Local Plan sought to include the most

Council has failed to reassess new settlement optionsand other sites on like-for-like basis; many of sitesallocated at Additional Sites consultation stage are

sustainable site allocations to the thecontrary to strategic approach to growth and previousobjectively assessed need. Following updatesassertion that insufficient suitable and available sites toof the OAN, sites previously assessed as partaccommodate development in these locations; failed toof the Draft Local Plan consultation, but notidentified as draft allocations were re-visitedand the most sustainable identified.

demonstrate that intended allocation at GreenHammerton/Cattal is a viable and deliverableoption; growth strategy not reviewed to establish whethera further new settlement would represent moresustainable option than allocating additional sites on The Council has updated the Sustainability

Appraisal to address issues raised at thePublication Draft Consultation where

edges of settlements, land at Deighton Grange (siteOC11) represents most sustainable option alongsideGreen Hammerton.

Allocate additional new settlement at Deighton Grange.

appropriate. The updated SustainabilityAppraisal to include a more detailedassessment of growth strategies and theprocess involved, including discussion ofsignificance.

The Harrogate District Local PlanSubmission Draft August 2018 ,Sustainability Appraisal Vol.1 and Vol.2updated following Publication DraftConsultation will be included in theExamination Library

No amendment.All available sites within settlements havebeen carefully assessed but it has not beenpossible to identify suitable sites in all

Spatial strategy does not fully take into considerationlocalised demand for housing and distribution againstavailable alternatives. Number of settlements will not

Secondary Service Villages. However, it issee sustainable growth because housing has not beenallocated in these locations, leaving settlements unableto support their existing services.

Amend policy to include wording:

clear from both the Policy and reasonedjustification that development of non-allocatedsites would be supported and the amendmentsuggested by the respondent is consideredunnecessary.

'New development will also be needed in the SecondaryService Villages and Smaller Villages and will be locatedin these rural villages to support their continuedsustainability. This will be considered alongside PolicyGS3 but it should not prohibit support of developmentsites that fall outside the development limit which candemonstrate a logical extension to a village and supportthe local community.'

No amendment.The landscape and environmental impacts ofdeveloping the allocated sites and mitigationmeasures, if required, formed part of the siteassessment process .

Allocation of sites within the Secondary Service villagesdoes not appear to have taken into account the sensitivenature of the character of certain villages e.g. AONB.Plan should have allocated development within villagesthat were not subject to any kind of environmental orlandscape designation in the first instance and only ifland were not available in the least visually sensitive orphysically constrained villages should the Council thenlook to the more sensitive villages.

No amendment.The Council's facilities research concludedthat Hampsthwaite has the range of facilitiesand services to be classed as a Primary

Evidence to support assumptions made about allocatinggrowth to Hampsthwaite is lacking: no evidence that newhousing will maintain or enhance facilities or their

Service Village and new residents wouldundoubtedly make use of those facilities andservices.

sustainability; query whether Hampsthwaite iscomparable with other Primary Service Villages; nocumulative study of environmental impact of housingallocations in village means unlikely capacity of





infrastructure in settlement is known or time frame forinvestment or improvement. (Hampsthwaite ActionGroup)

The Council has been working withinfrastructure providers and others to assessthe quality and capacity of existinginfrastructure and the Infrastructure DeliveryPlan provides detail on the infrastructureneeded to support the development includedin the Plan.

Under Policy TI4, the developmentmanagement process for planning applicationswill involve the further consideration ofappropriate mitigation for developmentproposals.

The Council has updated the SustainabilityAppraisal to address issues raised at thePublication Draft Consultation whereappropriate. The updated SustainabilityAppraisal includes a more detailedassessment of cumulative effects.

The Harrogate District Local PlanSubmission Draft August 2018 ,Sustainability Appraisal Vol.1 and Vol.2updated following Publication DraftConsultation will be included in theExamination Library

No amendment.Whilst the Sustainability Appraisal highlightsthat some sites currently have poor access topublic transport services it should be

The committed or proposed housing for south westHarrogate is contrary to the Sustainability Appraisal andinconsistent with Policy GS2, which both refer to locating

recognised that the Infrastructure Delivery Plangrowth in public transport corridors. This area ofHarrogate does not meet this criteria and is alreadysuffering from traffic congestion.

identifies existing bus services in WestHarrogate will be extended to serve newdevelopment.

No amendment.Killinghall possesses a range of services andfacilities and the level of growth allocated tothe village is considered appropriate given itssustainability.

Developments in Killinghall are not sustainable overlonger period of time, village has recently had a decreasein public services and will become an urban extensionof Harrogate. (Killinghall Parish Council)

Brownfield sites

No amendment.It is the case that brownfield land is relativelyscarce within the District. As such, it is notpossible for the majority of new development

Need for Local Plan to take more positive approach tobrownfield sites and their redevelopment.

Retain saved Policy GB7 or similar to address brownfieldsite redevelopment.

to be accommodated on brownfield sites.Where brownfield land is available, assessedas being suitable and consistent with thegrowth strategy, it has been allocated fordevelopment i.e. Ripon Barrack sites.Plan identifies greenfield sites without identifying

brownfield sites first.

Prioritise brownfield sites.

Delivery

No amendment.The Council has been working withinfrastructure providers and others to assessthe quality and capacity of existing

Evidence base does not demonstrate that allocationscan be delivered. Looked at capacity of infrastructurenetwork but assessments only go has far as identifying

infrastructure and the Infrastructure Deliveryproblems. Does not actually demonstrate capacity forPlan (IDP) provides detail on the infrastructurenew development within existing infrastructure or that

realistic and cost-effective solutions where capacityconstraints identified.

needed to support the development includedin the Plan. This has informed the Infrastructure





Schedule included as Appendix 3 of thePublication Local Plan. The IDP is regardedas a live document and the Infrastructure

The plan is ill-conceived as the existing infrastructure tosupport the scale of development proposed does notexist and existing infrastructure is overloaded.

Schedule will be reviewed and modified asrequired during the plan period as furtherinformation becomes available.

Under Policy TI4, the developmentmanagement process for planning applicationswill involve the further consideration ofappropriate mitigation for developmentproposals.

No amendment.The housing requirement of the Local plan isa minimum requirement, reflecting the nationalrequirement to significantly boost housing

Policy does not assign numbers or suggested dwellingpercentage increases which would allow the Council tomore accurately monitor delivery rates against targets,

supply. The allocation of specific dwellingwhich would in turn provide greater comfort to residentswithin the settlements and enable developers to progressplans with greater certainty.

Policy unsound in its current form as the proposedspread of housing across the Secondary Service Villagesis not justified or consistent with the Council’s evidence

numbers to individual settlements would,therefore, represent an inappropriate level ofdetail and reduce flexibility in housingprovision.

base or NPPF, which suggests that landscapes ofparticular value, including AONBs, should be protectedfrom development. The Council’s approach to allocatingland for housing within the Secondary villages does notappear to have taken into account the sensitive natureof the character of certain villages. Darley is a particularpoint in case, as the settlement is located within theNidderdale Area of Outstanding Natural Beauty (AONB).

The Plan should first of all allocate land for developmentwithin settlements that are least sensitive todevelopment, and only if land is unavailable should thevillages that require conservation or preservation beconsidered.

Supporting text

Amendparagraph 3.16to read (new

For the purposes of clarification agree thatreference should also bemade to Laver Banks.

Support growth strategy. Paragraph 3.16 should alsoacknowledge the contribution the Laver Banks site (R27)will make as part of the redevelopment of Riponbarracks.

Amend wording of paragraph 3.16 to also refer to LaverBanks site (R27).

textunderlined): '...there-developmentof the formerClaro andDeverallBarracks andthe adjoiningLaver Bankssite for newhomes, ....'

No amendment.It is considered unnecessary to repeatelements of the evidence base in the Plan'sreasoned justification.

HEDNA identified that greatest demand for employmentuses lies within Harrogate and the surrounding area.This should be referred to in paragraphs 3.15-3.16.





Amend paragraphs 3.15-3.16 to reflect HEDNA andacknowledge themajority of employment shortfall shouldbe made up in large sites in and around Harrogate andKnaresborough and that there will be some smaller scaleemployment opportunities provided in Ripon, which willbe limited to market demand.

No amendment.Whilst Ripon is not served by a train service itstill benefits from a bus service (to Harrogateand Leeds) with a very high frequency ofservice (every 10 - 20 minutes during daytime).

Para. 3.15 Ripon is not as well connected to publictransport as Harrogate and Knaresborough.

Para 3.16 Reference to City Plan team not makingallocations is disingenuous and implies City Plan teamhave declined to make allocations. (Ripon Civic Society) The wording does no more than reflect the

position that the Ripon City Plan does notinclude any specific allocations.Para 3.15 amend text to acknowledge difference

between Ripon and Harrogate and Kanresborough

Para 3.16 Add reference to lack of housing target forRipon as way of explanation or amend second and thirdsentence to read: “A Neighbourhood Plan… teamwhichis proposing housing growth through prioritising thesubstantial brownfield potential of the military estate andwindfall site opportunities close to the city centre. It isalso identifying mixed use regeneration areas …”

General

No amendment.The starting point for the OAN is thedemographic need (410 dwellings per annum)based on the latetst available evidence at the

Housing growth of 669 homes per annum has beenbased solely on estimated jobs growth up to 2035.Although jobs growth can influence housing need itshould not be the sole driver. time but there is also a need to look at the

housing need associated with forecasteconomic growth.Further consideration should be given to the population

changes in addition to the estimated job growth.

No amendment.The Council is working withlandowners/developers to ensure sites arebrought forward in a timely manner. In 2017/18

The growth strategy needs to be more realistic - over5000 homes have consent and are not yet built. Theplan is not remotely achievable by 2035.

there has been a significant increase inhousing completions. Currently 21 of theallocations are the subject of a pendingplanning application.

No amendment.The standard methodology should not renderthe latest objectively assessed housing needassessment i.e. the HEDNA, out of date. In

Number of houses indicated as being needed does notreflect national guidance, which indicates the need for395 dwellings per annum. Spatial strategy of directing

any case the standard methodology is, at thisstage, tied to the revised NPPF which remainsin draft.

development to western edge of Harrogate is flawed dueto lack of infrastructure to support scale of development.Cumulative impact of development has not been carriedout. Not considered opportunity provided by brownfieldsites e.g. Flaxby. Consultation process has beeninadequate.

The Council has been working withinfrastructure providers and others to assessthe quality and capacity of existinginfrastructure and the Infrastructure DeliveryPlan (IDP) provides detail on the infrastructureneeded to support the development includedin the Plan. This has informed the InfrastructureSchedule included as Appendix 3 of thePublication Local Plan.





Where brownfield land is available, assessedas being suitable and consistent with thegrowth strategy, it has been allocated fordevelopment.

The Sustainability Appraisal has consideredcumulative effects and has been updated toinclude a more detailed assessment. All sitessubmitted following a 'call for sites' have beenassessed as part of the SA, including Flaxby.The updated report is:

The Harrogate District Local PlanSubmission Draft August 2018 ,Sustainability Appraisal Vol.1/Vol.2 updatedfollowing Publication DraftConsultation which will be included in theExamination Library

Consultation on the Publication Local Plan wasreflective of the stage of plan making reached.

The final strategy adopted is often a variationof those tested at earlier stages in the planmaking process. The SA has been updated in

The selection of the growth strategy, in particular thechoice to focus growth in public transport corridors, doesnot meet the requirements of the SEADirective regarding

this respect to provide further details of theprocess adopted and the assessment anddevelopment of the growth option.

an assessment of realistic alternatives: The initialassessment looked at strategic public transport corridorsand did not include the corridor fromHarrogate to PateleyBridge

The Harrogate District Local PlanSubmission Draft August 2018 ,Sustainability Appraisal Vol.1/Vol.2 updatedfollowing Publication Draft Consultationwillbe included in the Examination Library

(Hampsthwaite Action Group)

Remove the Harrogate to Pateley Bridge public transportcorridor from the Key Diagram, policy GS2 and para3.13. Remove sites DM1/HM7 and DM1/HM9 from theplan

No amendment.The key public transport corridors have beenidentified on the basis of the frequency ofservice provided.

The transport corridor through Hampsthwaite shouldnot be considered on an equal basis to the othercorridors identified because:

The road is narrow and twisting

The village of Hampsthwaite is a bottleneck alongthe route

(Hampsthwaite Action Group)

No amendment.Whilst Ripon is not served by a train serviceit still benefits from a bus service (to Harrogateand Leeds) with a very high frequency ofservice (every 10 - 20 minutes during daytime).

Plan should recognise that Ripon is less well connectedto public transport links. In absence of firm proposals forpublic transport improvements, new development likelyto lead to car borne commuting and increased trafficpassing through City Centre, which suffers from airquality problems. (Ripon City Council) The Infrastructure Delivery Plan also identifies

measures to improve accessibility within theCity by means other than the private car: theseAmend policy to recognise Ripon is significantly less

well-connected than the other main settlements andaddress the associated wider sustainability andinfrastructure issues.

include improvements to Ripon bus station, theextension of the Ripon City bus service andnew cycle links from development areas to thecity centre.





No amendment.Noted, however, permitted development rights(subject to prior approval) already exist toenable changes from retail to residential use.

Re-use vacant town centre retail space for housing.This would reduce urban sprawl and help bring peopleback to our town centres.

Table 5.3 Key Issues: Policy GS2 Growth Strategy to 2035

GS3: Development Limits



N/ANoted.Support (including CPRE)

Support continued use of development limits. Criteria seemsufficiently robust to ensure where development outside ofdevelopment limits is permitted, character of settlement andrelationship to surrounding landscape not irreparably harmed.(Historic England)

Support, generally positive towards encouraging newdevelopment to reflect growth strategy and settlementhierarchy.

Policy

No amendment.Whilst the approach set out in the Policyprovides for an element of flexibility torespond to changing circumstances, it

Support overall approach but object to number of the criteria:

Criterion A - should be more flexible by leaving out referenceto 'built form', sites directly adjacent settlements notnecessarily most sustainable option whereas sites separatedbut well related may be prefereable

would be inappropriate to allowunrestricted development outside of thedevelopment limits and the criteria asdrafted in the Local Plan are consideredto be both necessary and appropriatelyworded.

Criterion B - this is restrictive and may prevent preferableand more sustainable sites coming forward that alternativesites within settlements

Criterion F - in some circumstance ribbon development maybe optimum and most sustainable method to expandsettlements. Cannot apply one size fits all approach todevelopment

Criterion A - delete words 'built form'

Criterion B - delete

Criterion F - delete

No amendment.The policies of the Plan should be readtogether and Policy EC7 (SustainableRural Tourism) addresses therespondent's issue.

Criterion A should not define too narrowly the type, locationand size of acceptable tourism development. This approachis inconsistent with NPPF paragraph 28.

Reword Criterion A to: ‘It can be demonstrated there arelocational reasons why the proposal is appropriate outsideof the settlement boundary.'

No amendment.The wording is considered appropriateas allocated sites should be prioritised fordevelopment in advance of unallocatedsites outside of development limits comingforward.

Criterion B is unnecessary having regard to the thirdparagraph which refers to circumstances where there areallocations within settlements. However, test in thirdparagraph too onerous and should refer to allocations thatdo not come forward within reasonable period of time.





The fourth paragraph does relate tosettlements wholly within the Green Belt.As the approach to development within

Not clear whether fourth paragraph is concerned with insetsettlements in Green Belt or washed over by Green Belt butas covered by Policy GS4 and national policy, this paragraphis redundant. such villages differs to non Green Belt

settlements the inclusion of the paragraphis, for the avoidance of doubt, consideredappropriate.

Delete fourth paragraph of Policy which refers to Green Belt.

No amendment.Settlement development limits are acommonly used tool in Local Plans andhave been successfully used as aplanning policy tool in Harrogate Districtfor a considerable time.

Use of development limits is inappropriate and unnecessary.Provision B is onerous and may constrain windfallopportunities coming forward.

Delete Provision B from policy.

AmendCriterionD to read (newtext underlined,

Agree that the suggested amendmentwould provide clarification andconsistency with national policy.

Criterion D - wording could potentially allow a developmenteven though it would result in considerable harm to heritageasset, which is not consistent with national policy.

deleted textstruck through):(Historic England)'It would nothaveCriterion D - delete 'significant'an significantadverse impacton the character..... '

No amendment.It is inevitable that large scaledevelopment will have impacts: as set outin the New Settlement Report (November2017) all the assessed locations for a newsettlement had similar impacts.

Identification of broad location for growth runs counter toobjectives of this policy and specifically policy criteria A, C,D and E.

No amendment.Any development proposal would besubject to consultation as part of theplanning application process.

Development outside of development limits should not beallowed without public consultation and where aNeighbourhood Plan exists and does not show developmentoutside the limit, development should not be allowed unlessthe Neighbourhood Plan has been updated and approved. It is considered that the use of a minimum

distance would be an inflexible approach,for example it would not take account ofthe size of the development proposed orthe topography of the intervening land.

Policy should include a minimum distance betweensettlements where no development should be located so asto avoid coalescence.

No amendment.Whilst the Policy provides for an elementof flexibility, the policy criteria provide arobust approach to assessing proposalsadjacent to development limits.

Policy is too generous/allows too much flexibility. (RiponCivic Society)

Delete second paragraph and criteria A-E.

No amendment.As defined the development limits offeropportunities for small scale developmentwhich will provide for a level of new

Sites have been excluded in the past for falling on the wrongside of development limits, despite being more sustainablethan sites within the settlement development limit. Insteadeach site should be considered on its own merits to ensuresustainable development is promoted.

development that is consideredcommensurate with the role and characterof smaller villages.

In light of compelling need to deliver new homes morepositive approach to housing delivery should be taken. Ratherthan enabling sites outside development limits to comeforward subject to meeting criteria should include sites withindevelopment limits and allocate them for housing.

Whilst the approach set out in the Policyprovides for an element of flexibility torespond to changing circumstances, itwould be inappropriate to allowunrestricted development outside of the





Support the inclusion of development limits on SecondaryService Villages, such as Darley, as a way of controllingdevelopment although in its current form the wording of the

development limits and the criteria asdrafted in the Local Plan are consideredto be both necessary and appropriatelyworded.policy is open to interpretation and somewhat subjective. If

the Council are willing to consider development outside ofthe Development Limits it brings into question the purposeof the Development Limits and a better approach would beto draw more appropriate limits in the first instance and seekto accommodate growth within these. (Darley and MenwithParish Council)

The inclusion of indicative percentage increases for each ofthe tiers based on the existing number of dwellings in asettlement would provide a useful indication as to whethera proposed development would be disproportionate or not.

No amendment.As development limits have been definedusing the principles in paragraph 3.24 ofthe Publication Local Plan, the issue ofalternative development limits does notarise.

The SA has not considered alternative development limitsor the cumulative impact of development on individualsettlements. Significant omission when the proposed increasein the size of a settlement such as Hampsthwaite is so great.The proposed development limit includes all sites proposedfor development.

In defining development limits, theapproach has been taken to include theproposed housing and employmentallocations within the development limit.

The Hampsthwaite development limit should not be extendedbeyond those sites with planning permission. Site HM9should be excluded.

No amendment.Settlement development limits are acommonly used tool in Local Plans andhave been used as a planning policy toolin Harrogate for a considerable time.

It is not clear what benefit there is in having developmentlimits when development in certain circumstances can takeplace outside those limits. (Kirby Hill and District ParishCouncil)

No amendment.Noted, although disagree that specificreference is needed. When aneighbourhood plan is made it will formpart of the development Plan and will betaken into account accordingly.

Where a made neighbourhood plan is in existence, to affordlocal distinctiveness, the development limitboundary should be taken to be as that shown in the relevantneighbourhood plan’s policies map. (Ripon City Council)

There is anamendment beingproposed to the

Add to the Policy: Introduction asfollows to addextra clarificationre NeighbourhoodPlans:

'Notwithstanding the strategic nature of this policy in thatthere shall be a development limit in defined settlements,where a made neighbourhood plan is in existence, to affordlocal distinctiveness, the development limit boundary itselfshall be taken to be as that shown in the relevantneighbourhood plan’s policies map.'

"Neighbourhoodplans areprepared inaccordance witha formal processand have astatutory status.ANeighbourhoodPlan that,followingindependentexamination,secures thesupport of localpeople througha referendum is'made' part ofthe developmentplan. It will then





be used byHarrogateBoroughCouncilto determineplanningapplications inthe relevantarea, alongsiderelevant policiesin the LocalPlan"

No amendment.The Local Plan does not restrict theredevelopment of brownfield sites wherethis would be consistent with Planpolicies.

Policy should be more explicit on supporting developmentof brownfield sites outside of Green Belt and avoid restrictingbrownfield growth in sustainable locations.

Amend Policy to be more explicit on support for developmentof brownfield land.

No amendment.It is unclear in what way the respondentbelieves the approach taken is notconsistent. The approach to definingdevelopment limits has been consistentlyapplied, including in North Stainley.

North Stainely Estate is particularly concerned that thedevelopment limit for North Stainley have not been developedin a manner which seeks to enable sustainable growth orconsistent with the approach taken else where in theborough.

Provision for growth in the village hasbeen made in the Local Plan with theallocation of two housing sites (with

Request changes to the criteria at Policy GS3 to refer to 'asignificant and unacceptable adverse impact on the characterand appearance of the surrounding countryside'

capacity for 225 dwellings) and a site toenable the development of a new school,which in turn would provide aredevelopment opportunity.

Development Limits - support

N/ANoted.Consider Harrogate development limit and inclusion of siteH69 within it is sound.

Support Bishop Monkton development limit and inclusionof site BM3 within it.

Support Killinghall development limit and inclusion of landadjoining Grainbeck Manor.

Support Marton cum Grafton development limit

Development limit for Hampsthwaite will support a level ofdevelopment which will have a significant impact on thevillage, its environment and local community.

Development Limits - changes

No amendment.The approach to defining developmentlimits has been to exclude buildingsseparated from the main built up area of

Arkendale development limit drawn too tight.

The draft settlement boundary should be amended to includeland comprising Hazel Head Farm and development at MarHead Balk.

a settlement. The area referred to liesbeyond the edge of the main built up areaof the village. As such, it is considered tohave been appropriately excluded.

No amendment.The Farnham development limit has beendefined using the principles in paragraph3.24 of the Publication Local Plan and

Farnham development limit drawn too tightly and shouldbe extended to include land at Rock Cottage Farm. Wouldcomprise logical infill and rounding off of opportunity.

include that on the 'outside' of the





development limit land will generally beused for agriculture, outdoor sport,woodland or other open uses. Following

Amend development limit to include land at Rock Cottage.

this principle, it is considered that the areareferred to has been appropriatelyexcluded.

No amendment.The approach to defining developmentlimits has been to exclude existingproperties in spacious grounds where they

Red House is part of existing built form ofBishopMonkton,closely connected with exiting developments and localservices. Pre-application enquiry confirmed garden of RedHouse was suitable for residential development and is nowsubject to planning application.

lie beyond the edge of the main built uparea of the settlement. As such, it isconsidered that this property has beenappropriately excluded.Two housing allocations to immediate south, which would

extend village to west provide further justification for inclusionof The Red House and garden in development limit. The planning application referred to was

refused in February 2018, although arevised application was submitted in May2018.

Amend development limit to include The Red House andgarden.

No amendment.Development limits have beendefined using the principles in paragraph3.24 of the Publication Local Plan and

Need to amendKnaresborough development limit to provideadditional housing opportunities.

include that on the 'outside' of theAmend development limit to include land adjacent toNetherlands, Abbey Road. development limit, land will generally be

used for agriculture, outdoor sport,woodland or other open uses.Notwithstanding that planning permissionhas been granted for development of theadjacent site (originally on appeal in 2016)and that a planning application for twodwellings on the site has been received(in May 2018 but not yet determined),following the above principle, it isconsidered that the area referred to, whichis heavily treed, has been appropriatelyexcluded.

No amendment.In accordance with the principle that onthe 'outside' of the development limit, landwill generally be used for open uses it is

No justification for exclusion of site B22from Boroughbridge development limit. Logical andappropriate to include whole of Boroughbridge High Schooland site B22 within development limit. considered that the school playing fields

have been appropriately excluded (theHigh School buildings are within theAmend development limit to include site B22 and High

School. development limit). As Site B22 isallocated for expanded educationalfacilities at the High School, most likelyfurther playing field provision it isconsidered appropriate that it lies outwiththe development limit.

No amendment.Allocated sites have been included withinthe development limit of a settlement.Both site B12 and B21 are considered to

Boroughbridge development limit is arbitrary and is notjustified. Aldborough Gate forms natural boundary to thetown and site B21 is key open area separating Aldboroughfrom Boroughbridge. be appropriately allocated and, therefore,

there is no justification for excluding themfrom the development limit.Amend development limit to exclude sites B21 and B12.

No amendment.In preparing this Plan, the developmentlimits defined in the 2001 Local Plan werereviewed. Part of the approach to defining

Huby development limit too tightly drawn, no infillopportunities available. Could be addressed byamendment to development limit to include three areas ofland. the development limits in the new Local

Plan has been to exclude existing





properties in spacious grounds where theylie beyond the edge of the main built uparea of a settlement. It is considered that

Site 1 - natural extension to Holly Park, well enclosedby existing woodland and tree belts

on this basis, Holly Beck House (Site 3)has been appropriately excluded from theHubby development limit.

Site 2 - enclosed and hidden from view by woodlandon its south east and west boundaries and by existingdwellings on Holly Park.

In accordance with the principle that onthe 'outside' of the development limit, landwill generally be used for agriculture,

Site 3 - includes land within curtilage of Holly BeckHouse and triangular area of land to west. Holly BeckHouse previously included in the development limitsof the 2001 Local Plan. outdoor sport, woodland or other open

uses it is considered that sites 1 and 2have been appropriately excluded.

Amend development limit to include the three areas of land.

Amend theNorth Stainleydevelopment

It is agreed that The Staveley Arms Pubshould be included in the settlementdevelopment limit. However, the approach

North Stainley development limit should include main builtup area of settlement.

limit to includeThe StaveleyArms Pub.

to defining development limits has beento exclude buildings separated from themain built up area of a settlement,

Amend development limit to include the main built up areasof the settlement and to the existing and established builtform of North Stainley Hall and grounds, Lodge House,Lightwater Farmhouse and The Staveley Arms Pub and CarPark.

including existing properties in spaciousgrounds. As such, it is considered thatNorth Stainley Hall and Lightwater Farmhave been appropriately excluded.

No amendment.As a masterplan for the development ofthe Ripon Barrack sites is at an earlystage of preparation and subject to

Area to the south-west of site R27, running down to thebanks of the River Laver, is not proposed to be developed.However, as it lies outside the Ripon development limits,

change, it would be premature, at thisany application for the wider site which included the areastage, to amend the Ripon developmentrunning to Laver Banks would be non-compliant with Draftlimit to reflect the emerging masterplan.Policy GS3. Extension to the Ripon Development BoundaryIt should also be noted that as Policy GS3to include this small area would allow an application coveringprovides flexibility to enable sitesthe full masterplan to be policy compliant and for the scheme

to deliver the appropriate amount of public open space.(Defence Infrastructure Organisation)

adjoining development limits to comeforward there is no imperative for this areato be included in the development limit.

Amend development limit to include land to south west ofSite R27.

Amend theRipondevelopment

It is agreed that the Ripon developmentlimit should be amended to include thebuilt development at Pottery Fields.

Land at Pottery Fields, Ripon (western part) should beincluded within the development limit for Ripon because:

limit to includeit is adjacent the development limitPottery Field andassociatedoutbuildings.

limit has been extended elsewhere to include muchlarger sites

Amend development limit to include land at Pottery Fields(western part).

No amendment.The barns to the north east of Back Lanebenefit from planning permission forconversion to two dwellings (granted in

Object to inclusion of barns north east and north west of theend of Back Lane, Weeton as it:

May 2017): sites with planning permissionwill result in development in the green belthave been included within developmentlimits. With the inclusion of these buildingsis not in keeping with the core shape and form of the

settlement within the development limit, the barns tothe north west of Back Lane are





considered to relate to the built up areaof the settlement and are, therefore,appropriately included.

have an adverse impact on future character andappearance of surrounding countryside

contradicts GS3 para 3.24 - farm buildings will beoutside development limits and para 3.25 as the barnsare not physically, functionally or visually related toexisting built up area.

Amend development limit so that barns at Back Lane areexcluded.

No amendment.As set out in paragraph 3.26 of thePublication Local Plan, all settlementdevelopment limits have been amended

The application of development limits to Darley appears tohave been a crude exercise, artificially altered to incorporatethe Council’s proposed allocations, thereby failing to take

to include sites proposed for allocation. Asinto account the findings of the Council’s own evidence base;site DR14 is considered to bethe relationship of land to the existing built form; and existingappropriately allocated there is nojustification for excluding it from thedevelopment limit.

development patterns that are largely focused along MainStreet. Point made with particular emphasis on site DR14,which is considered is an unsuitable location fordevelopment. (Darley and Menwith Parish Council)

Amend development limit to incorporate a more appropriateboundary, excluding DR14.

No amendment.The approach to defining developmentlimits has been to exclude farm buildingsbeyond the main built up area of the

Ramsgill development limit should be extended on the westside of the village to include several traditional stonebuildings, which are part of the village. (Upper NidderdaleParish Council) settlement. As such, it is considered that

the development limit has beenappropriately defined.Amend development limit to include buildings on west side

of village.

No amendment.The approach to defining developmentlimits has been to exclude farm buildingsbeyond the main built up area of the

Middlesmoor development limit should be extended on thewest side of the village to include stone buildings, which arepart of the village. (Upper Nidderdale Parish Council)

settlement. As such, it is considered thatthe development limit has beenappropriately defined.

Amend development limit to include buildings on west sideof village.

Middlemoor development limit should include farm steadingof Ivy House Farm.

Part of village, other significant buildings in villageincluded within development limit including thoseopposite farm steading

inclusion would help meet housing need through futureopportunity to convert farm buildings

Amend development limit to include farm steading at IvyHouse Farm.

No amendment.In accordance with the principle that onthe 'outside' of the development limit, landwill generally be used for open uses it is

Dacre Banks development limit should be extended toinclude land to north of committed housing site (DB6).

considered that the field beyond the area





that benefits from planning permissionhas been appropriately excluded from thedevelopment limit.

Development Limits - changes related to omission sites

In relation to representations seeking the allocation of specific sites a number of respondents also made representationsthat the settlement development limit should be amended to include the site (see below). As the Council does not considerthere is a need to allocate these sites, there is no necessity to amend the settlement development limits as suggested.

No amendment.See response to Development Limits -changes related to omission sites

Land at Holgate BankGrange,Arkendale should be includedwithin development limit. Site is accessible parcel whichrounds the settlement, bounded by existing and futureconsented development.

Important flexibility to allow for development on edge ofsettlement limits is retained.

Amend development limit to include land at Holgate BankGrange.

Spofforth development limit drawn too tightly and does nottake positive approach to delivery of housing or make mostefficient use of available sites around village.

Amend development limit to include land Hall Cottages andadjacent land.

Sicklinghall development limit is drawn too tightly and doesnot allow for small scale rounding off or windfalls in line withsettlement's position in settlement hierarchy.

Amend development limit to include site at Back Farm andland at Dairy Farm.

Farnham development limit drawn too tightly and does nottake positive approach to delivery of housing or make mostefficient use of available sites around village.

Amend development limit to allow for windfall developments,including land to rear of The Old Crown.

North Rigton development limit drawn too tightly and doesnot leave opportunity for village to expand in line withdesignation as Secondary Service Village.

Client's property partly within development limit but domesticoutbuildings/garden excluded. Case law suggests gardensoutside development limits are considered brownfield,suggesting limited infilling or redevelopment could beappropriate.

Amend development limit to allow for development potential,including on land at Bracken Lodge.

Need to increase development limits to facilitate new housingand help meet identified housing need.





Land at Chapel Lane, Marton-le-Moor is immediatelyadjacent to and surrounded on 2.5 sides by existing builtform of Marton-le-Moor. Previous planning applications haveconfirmed site was suitable for some form of residentialdevelopment.

Amend development limit to include all or part of land northof Chapel Lane.

Tockwith development limit should be altered to includeland at Tockwith West (site TW11).

Amend development limit to include site TW11.

Tockwith development limit should be amended. Logicaland appropriate to extend it further west and then south toincorporate land at Tockwith Airfield.

Amend development limit to include Tockwith Airfield.

Whilst support approach to development limits andTockwith development limit, which will provide logical anddefensible settlement edge the Local Plan does not fullyreflect the approach set out in the Policy supporting text inrespect of identifying suitable land for allocation within thedevelopment limit, such as site TW13.

Harrogate development limit drawn too tightly. Should beamended to include land at Fulwith Grange.

Amend development limit to follow boundary of FulwithGrange and Fulwith Mill Lane.

Suitability of site for residential development previouslyconsidered acceptable by officers (as part of planningapplication 17/00213/OUTMAJ). As such should be includedin Harrogate development limit to allow site to come forward.

Amend development limit to include land at Rossett GreenLane.

Harrogate development limit should be extended furthersouth.

Extend development limit to include land at Penny Pot Lane.

Area bound by Kent Road/Cornwall Road/Penny Pot Lane(H13) should be included within the Harrogate developmentlimit. Character is no different to the area within thedevelopment limit. Would provide infill and rounding offopportunities.

Amend development limit to include land bound by KentRoad/Cornwall Road/Penny Pot Lane.

Boroughbridge development limit should be extendedfurther west, A168 would provide logical and defendablelimit.





Extend development limit to include land at Roecliffe Lane.

Killinghall development limit includes part of DalesideNurseries (housing commitment KL9) and should beextended to include remainder of Daleside Nurseries.

Amend development limit to include all of Daleside Nurseries.

Green Hammerton development limit should be extendedto the north west to include the whole of site GH14.

Amend development limit to include all of site GH14.

Important flexibility to allow development on edge ofsettlement limit is retained but Baldersby development limitshould be extended to include land at The Hill.

Amend development limit to include land at The Hill.

Important flexibility to allow development on edge ofsettlement limit is retained butCowthorpe development limitshould be extended to include land at Warfield Lane.

Amend development limit to include land at Warfield Lane.

The proposed Draft Development Limit forKirkbyMalzeardlimit does not include all existing housing, allows insufficientlyfor suitable in-fill housing and is already out-of-date, asconsent has been granted on a number of plots, both insideand outside the proposed limit, since it was prepared.

Development limit should be updated with adequate provisionfor some suitable in-fill housing being incorporated.

Amend Marton-cum-Grafton development limit to includesite known as MG5.

Masham development limit should be amended to includeland to the east of the northern part of allocated site M13.

Table 5.4 Key Issues: Policy GS3 Development Limits

GS4: Green Belt



Policy

Noamendment.

The NPPF (paragraph 81)indicates that once Green Beltshave been defined, LPAs should

Criteria listed set out what Council consider to be opportunities forbeneficial use of the Green Belt. However, Green Belt is a land-use ratherthan landscape policy: retention and enhancement of landscape, visualamenity and biodiversity are not listed as the purposes of Green Belt inthe NPPF.

plan positively to enhance thebeneficial use of the Green Belt.As such, the Policy identifieswhat, in the context of HarrogateDistrict, the Council consider tobe the beneficial uses to beaddressed.





Green Belt Review/Boundary

Noamendment.

The NPPF is clear that GreenBelt boundaries should only bealtered in exceptional

Green Belt designation covering Sicklinghall does not serve any of thepurposes of including land within Green Belt.

circumstances. The Green BeltSicklinghall, including land at Back Lane, should be inset within the GreenBelt to reflect designation as Secondary Service Village. Background Paper (2016) sets

out the reasons why the Councilhas concluded that it does not

Green Belt boundary at southern edge of Spofforth does not reflectdevelopment on the ground.

need to undertake a Green Beltreview in order to meet theemerging plan requirements in

Properties along Park Road and land adjacent to Hall Cottages. Spofforthshould be removed from the Green Belt.

a way that representssustainable development. Thegovernment has re-iterated itscommitment to the protection of

Green Belt designation covering built part of North Rigton does not serveany of the purposes of including land within Green Belt.

the Green Belt. Most recently inthe draft revised NPPF theymake clear that Green Belt

North Rigton, including land at Bracken Lodge, should be inset within theGreen Belt to reflect designation as Secondary Service Village.

boundaries should only beamended where exceptionalcircumstances can bedemonstrated having exploredall other reasonable options.Modest review of Green Belt boundaries should be undertaken to remove

anomalous designations and developed areas where Green Belt protectionis unnecessary e.g. substantive built up area such as along Bogs Lane As there are other options for

meeting development needs inthe district the Council is of the

and parts of settlements. Land at Bogs Lane could be removed withoutaffecting purpose of Green Belt in this location which is to maintainstrategic gap between Harrogate and Knaresborough.

Land east of Bogs Lane, Harrogate should be removed from Green Belt.

view that the exceptionalcircumstances to trigger a GreenBelt review cannot bedemonstrated.

Last review of Green Belt over 26 years ago. Given current requirementsfor growth, objectives of achieving sustainable development and significantchanges in circumstances since last review, comprehensive assessmentof Green Belt boundaries required.

Review Green Belt.

Potential for Huby as Secondary Service Village to realise modest levelsof sustainable growth is restricted by washing over by Green Belt.

Inset Huby within the Green Belt.

Review of Green Belt boundaries should have been undertaken as partof the local plan process. Specific reference to Henshaws College landnorth of Bogs Lane, Harrogate.

Review Green Belt boundaries.

A failure to undertake a selective review of Green Belt boundaries insustainable locations has resulted in allocations being pushed to lesssustainable locations. Also failed to assess whether any sites within GreenBelt and immediately adjacent principal growth areas still meet purposesof Green Belt.

Undertake selective Green Belt boundary review of land around southside of Pannal.





Fails to address the duty to co-operate in regards to Leeds City Councildesignation of land as Green Belt off Kings Meadow View. The approachshould be reciprocated by Harrogate with a Green Belt review of thearea.

Disagree with justification in para. 3.30 that it is not necessary to amendthe extent of the Green Belt as it fails to recognize all of para 82 of theNPPF. An extension of the Green Belt would meet bullet points 3 and 4of para 82 and para 83 of the NPPF.

Extend the Green Belt east of Harrogate Road from Spofforth through toand completely surrounding Kirk Deighton at least to the west of the A168and south to Wetherby. Green Belt should include the Harland Way fromWetherby to Spofforth and the SSSI at Kirk Deighton. This will strengthenHeritage and Placemaking objective 6 and Natural Environment objective7.

Amend para. 3.3 to state green belt amendment was necessary to sustainintegrity of Kirk Deighton and ensure consistency with other Local Plans.

It is presumed that major development to the east of Harrogate has beenprecluded because of its Green Belt status. Whilst Green Belt protectionof land is important, it must be questioned whether current Green Beltdesignations around Harrogate are still appropriate and fit for purpose,given the scale of the proposed development and the disproportionateimpacts to the west side of Harrogate.

Noamendment.

The Gypsy and TravellerBackground Paper August2018 defines why the

There are no 'very special' or 'exceptional circumstances' for the Greenbelt boundary to be altered to accommodate the Gypsy and Travellersites.

recommended approach hasbeen taken and why there arehealth, educational need,personal circumastances and the inability

to identify alternative sites are not 'exceptional circumstances' exceptional circumstances. Para17 of the Planning Policy forTraveller Sites states that localconcerns as to whether the sites residents can be defined as

Gypsies and Travellers planning authorities can makeexceptional limited alteration tothe defined green belt boundaryland in public ownership has not been consideredto accommodate a site insetwithin the Green Belt to meet aHBC not resisted inappropriate development in the past specific, identified need for aTraveller site. Due to the

spread of Gypsy and Traveller sites across the District isunproportionate

circumstances of the threecurrent sites in Knaresborough,the lack of a deliverable site(s)

concerns about precedence and the small number of pitchesrequired, the three existing

local plan not proposing compensatory action against the loss ofthe Green Belt

Gypsy and Traveller sites canbe taken out of the Green Beltand allocated.

(Knaresborough and Calcutt Green Belt Protection Group) The allocation does not set aprecedent for furtherencroachment into the GreenBelt as a number of provisionswill be put in place to ensure theimpact on the Green belt will bekept to a minimum as follows:

tight drawing of allocationboundary for each siteand any further expansionwould not be permitted





and unauthoriseddevelopment enforcedagainst

the sites will bespecifically allocated forGypsy and Traveller useand if they cease to existas such cannot be usedfor any other use

permanent planningpermission will still needto be gained and anyplanning approval willinclude conditions fordevelopment of the site

(Also see response to PolicyHS10)





NoAmendment

Policy GS4 relates to the GreenBelt rather than Gypsy andTravellers and the suggestedwording would not be in line withthe thrust of the policy.

Policy should be reworded as follows:

"To avoid the repetition of past failings and to ensure that HarrogateBorough Council (HBC) planners do not in the future find themselves ina position by which expedient action is required, HBC will work harder toensure that the requirements of the NPPF and PPTS are more effectivelyand fully met, within the plan's time span we undertake to:

Address the current issue by:

1. Conducting a complete search of alternative sites (to K40, K41 andK42), including public (HBC) owned land - with sufficient sites tobe identified and allocated by 30.2.2019

2. retaining in full size and scope, as it exists at 1.3.2018,Knaresborough Green Belt

3. Allowing the current traveller sites (at K40, K41 and K42) time limitedtemporary permission until 30.3.2020

4. By 30.3.2020 HBC planners will have identified and providedsufficient and adequate sites to meet the full 5 year plan Gypsy andTraveller sites requirement including providing alternative sites forsites K40, K41 and K42 on land which is not Green Belt.

5. Refusing any and all temporary or permanent planning permissionsfor Gypsy and Traveller sites in the area to the south ofKnaresbroough which includes the 2.77 sq m. areas in and aroundCalcutt.

6. Reviewing in line with national guidance and legislation, whetherthe current residents of the sites qualify as travellers, and thuswhether the sites also do so

Going Forwards:

To avoid continued repetition of past failings, HBC planners will by30.3.2019 have:

a. conducted a complete search of land across the whole district, byreviewing and adding to the sites assessment in HBC planners'Gypsy and Traveller Background paper (Nov 2017) and the previousGTSA, a search of all the land publicly owned by HBC and ant othersites which have, or do, subsequently become available and aresustainable

b. identified and set aside sufficient, adequate site for the full five yearsof the Plan period. This will take account of the fair distribution ofGypsy and Traveller sites across the whole district with theexception of land to the south of Knaresborough which, since italready has a dispropotionately large number of Gypsy and Travellersites, will be excluded.

c. ensured that all 9existing and proposed) GT sites are commensuratewith the nearest settle community - both individually andcumulatively, in the short, medium and long terms - fully in line withNPPF and other legislation. Having made public HBC'snumerical/objective base for the calculation of what qualifies as'commensurate with the nearest settled population'

d. engaged the nearest settled community in early, open, meaningfuland fair discussion in line with NPPF requirements of both current





and proposed Gypsy and Traveller sites, and avoid limitingengagement only to Local Plan consultations. The methods ofengagement will take into account the fact that not everyone hasor wants access online or regularly reads newspapers.

e. published progress reports on the achievement of all the criteriaincluded in this statement on the Council website at quarterlyintervals and by 30.6.18, 30.9.18, 31.12.18, 31.3.19, 30.6.19,30.9.19, 31.12.19 and 30.3.2020, in addition to supplying the sameinformation to interested parties, including the Knaresborough andCalcutt Green Belt Protection Action Group

Ensure that planning enforcement is conducted effectively by:

a. making publicly available HBCs planning enforcement policy towhich members of the public can refer and which allows any futurefailings in enforcement to be promptly identified and the Councilsplanners held to account

b. enforcing planning law in line with the policy fairly, equitably andconsistently across the whole population - no matter whom thepeople are who are suspected to have infringed it; settled orunsettled, regardless of race, wealth, political affiliation, where theylive, the risk of being threatened, or any other criteria orcircumstances

c. ensuring that unlawful settlement of land is not, at a later time,rewarded by being granted planning permission. Thusdemonstrating a mindfulness of the obvious unintentionalconsequences of planning policy.

d. avoiding unauthorised settlements, in green belt or otherwise andresponding quickly and effectively to resolve any issues as per thefomal enforcement policy

Table 5.5 Key Issues: Policy GS4 Green Belt

GS5: Supporting the District's Economy



Noamendment.

Comments noted. However, this could applyto any local authority area within the countryand, as such, the suggested amendment isnot considered to add anything locally specificto the Plan.

Economic benefits that can be delivered through the housebuilding industry should be recognised within the Policy.

Amend policy to reflect economic benefits that can bedelivered through the house building industry.

Noamendment.

Whilst employment land provision will bemade as part of the new settlement, it is notenvisaged that this would be a strategic site.

New settlement will make important contribution to economywhich should be reflected in policy, with specific referenceto supporting growth within the new settlement.

Amend policy to reflect importance of new settlement toeconomy.

As such, it is considered that reference inPolicy DM4 (Green Hammerton/Cattal BroadLocation for Growth) to employment landprovision adequately covers the point madeby the respondent.





Noamendment.

Whilst this is the case, it needs to be seen inthe context of the wider evidence: Table 55of the HEDNA indicates that of the

HEDNA (para. 14.13) found that there is an undersupply ofdevelopable employment sites within Harrogate and thesurrounding area, which is where the greatest demand exists.This should be acknowledged. (Defence InfrastructureOrganisation (DIO))

Amend paragraph 3.48 to acknowledge there is an undersupply of developable employment sites within Harrogateand the surrounding area, which is where the greatestdemand exists.

employment sites assessed in the Ripon andBoroughbridge sub- area, there was only 1.11hectares of available land assessed as beingsuitable for further employment development.

Noamendment.

The Council's Economic DevelopmentStrategy sets out the actions the Council willtake to deliver economic growth in the Districtand support existing and new businesses.

Policy does not give any indication as to how HBC willpromote the area and attract new businesses i.e. bidding forfunding support, joint strategy on promotion of infrastructurealong the A1(M) corridor, education and training.

Noamendment.

It is considered that taken as a whole theLocal Plan adequately addresses the pointsmade by the respondent.

This Policy and justification needs to be more inclusive withregard to:

1. the recognition of and support for established sectors,notably in the rural and northern parts of the district

2. the role of Ripon as a main settlement in the deliveryof the target growth sectors

3. the role of Ripon as a main settlement and the focalmarket town for the northern and western part of thedistrict

4. the role of Ripon in the visitor economy.

3.37 - The hyperbole “… is a great place to do business,illustrated by its … “ has no place in a Local Plan.

(Ripon Civic Society)

Amend wording to address inclusivity of district's economyand Ripon's role.

Amend 3.37 to read 'Harrogate district enjoys a diversebusiness... '

Noamendment.

Specific reference to the points made therespondent are not considered necessary.The evidence base (HEDNA), and the

Policy does not recognise that economic and tourism issuesare different in Ripon and its hinterland and therefore doesnot provide Ripon specific guidance for its needs, including

Employment Land Study before it, wasavailable to inform the development of the CityPlan.

employment uses which are key to the local economy,infrastructure and facilities for the tourism economy, includinghotels. Without such strategic guidance it is more difficultto plan at neighbourhood level in the Ripon City Plan. (RiponCity Council)

Policy should recognise that economic and tourism issuesare different in Ripon and provide specific guidance in thepolicy for its needs.

Noamendment.

It is considered that as a strategic policy thecriterion is appropriately worded and needsto be read in conjunction with Policy EC7(Sustainable Rural Tourism) and Policy HS9(Rural Worker's Dwelling).

Encouraged by and supportive of the recognition of thecontribution which tourism makes to the district's economy.However, to maintain and enhance the visitor economy, needto ensure appropriate and modern provision for staff working





in this sector, as well as ensuring that the accommodationand attractions which the visitors use are maintained to ahigh standard and evolve to meet market demands.

Amend Criterion F as follows: ‘Maintaining and enhancingthe District's visitor economy by supporting the appropriatedevelopment of existing services, the appropriate provisionof new services and development of modern and appropriateaccommodation for both visitors and the staff serving thesector.’

Noamendment.

It is unclear what the respondent's suggestedamendment would add as it is explicit fromthe current wording of the criterion that the

Welcome clear support for diversification of farmingbusinesses but believe need to provide greater support forthe ongoing development of agricultural businesses in order

development of the rural and agriculturalthat the countryside is maintained in a way which is attractiveeconomy would be supported. The Policy alsoto visitors with investment in the land, landscape and built

assets which will help to attract and retain youngergenerations within an economically viable sector.

needs to be read in conjunction with theEconomy policies of the Local Plan, inparticular Policy EC3 (EmploymentDevelopment in the Countryside) and PolicyAmend Criterion G to read: "supporting the ongoing

development of the rural and agricultural economy and itsdiversification".

EC4 (Farm Diversification), which arereferenced in the 'Related planning policies'box.

Noamendment.

The Council's Economic Growth Strategyhighlights that workplace earnings in theDistrict are low and one of the aims of the

Plan should make provision for employment at all levels,including the young and those that have not higher levels ofeducation. Specifically, the area should not create exclusion

Strategy is to seek to re-balance this throughand diminish social cohesion by focusing its strategy on highincreasing the number of higher value jobsvalue employment to the detriment of employment for all.available. The Local Plan is one mechanismBuilding housing does not result directly in employmentto deliver this through the allocation of siteslocally without a plan, particularly if the housing precludes

local people from purchasing houses where the house priceto income ratio is too high.

attractive to businesses with high value jobs.However, this does not mean thatdevelopment of other sectors or existingbusinesses will not be supported.In paragraph 3.36 delete "include a higher proportion of high

value jobs"

Noamendment.

It is considered that the sites allocated wouldnot preclude such developments.

Employment land allocations should make some provisionto allow small and micro businesses develop, such asworkspace hubs.

Table 5.6 Key Issues: Policy GS5 Supporting the District's Economy

GS6: Sustainable Development



N/ANoted.Support. Reflects model policy and has been amended inaccordance with previous comments.

Noamendment.

This is already recognised underPolicy GS2.

Whilst support Policy, supporting text should recognise thathousing has fundamental role to play in sustainability of villagesand as a key component to overall growth strategy.

Amend supporting text to Policy GS6 to recognise contribution ofsmaller villages to supporting growth.





Noamendment.The Local Plan should be read as awhole and the order of the policiesshould not be taken to imply anyprecedence or priority.

Support general principle of policy but as replicates NPPF wordingit is essentially superflous.

If policy retained, should bemoved to start of document so decisionmakers aware of Council's agenda and adopt proactive approachto considering planning applications.

Delete policy or if retained move to start of document.

Policy is superfluous.

Delete policy.

Noamendment.

The Council's Economic Strategy2017-2035, sets out the priorities andtargeted interventions the Council will,together with partners, deliver acrossthe District.

In promoting growth of local economy there is a need for the localauthority to be the driving force behind increasing growth anddevelopment in the district and policy should identifypractical actions the Council will take.

Noamendment.

The policies and proposals of theLocal Plan have been subject to SAthroughout, this has considered theenvironmental and social impacts ofdevelopment.

Sustainable development has economic, social and environmentaldimensions and they are meant to carry equal weight. The DraftLocal Plan ignores completely the acknowledgement ofenvironmental and social benefit that has been given to SpecialLandscape Areas eg Crimple Valley.

Table 5.7 Key Issues: Policy GS6 Sustainable Development

GS7: Health and Wellbeing



Noamendment.

Criteria B and C - access to good housing andemployment opportunities can have an impact onwell-being and, therefore, in the context of the policy

Support overall aim but object to number of criteria:

Criteria B and C - do not directly relate to evidenceand aims behind policy and repeat several policiesin Plan. If retained should reference these relevantpolicies within text. No explanation of what isconsidered accessible location in criteria C

it is appropriate for reference to be made. Accessiblerefers to locations that can be accessed by meansother than the private car.

Criterion E - Building Regulations only set a minimumrequired standard in respect of energy efficiency. TheCouncil's Sustainable Design policy encourages lower

Criterion E - matter for Building Regulations

energy use through both passive design measuresand energy efficiency. In this context the criterion isappropriate.

Criterion F - to ensure developers are aware ofstandards, reference should be made to ResidentialDesign Guide or subsequent guidance

Criterion F - The Design Guide is not consideredrelevant in the context of this Policy.

Criterion I - should refer to dedicated policy NE5

Criteria B and C - delete or if retained add referenceto relevant policies Criterion I - as Policy NE5 is already cross referenced

(in the related policies box) no further reference isconsidered to be necessary.Criterion E - delete

Criterion F - add reference to relevant designguidance

Criterion I - add reference to Policy NE5





Noamendment.

Noted. Policy HS1 does not set a rigid housing mixto be applied but rather expresses a desire to worktowards the suggested mix set out in the HEDNAinformed by local assessments of housing need andsite characteristics.

Housing mix should be dealt with on a site by sitebasis to ensure that flexibility is maintained in orderto deliver the right mix of unit size and tenure to suitthe prevailing local circumstances at the time.

Noamendment.

The Local Plan seeks to deliver the infrastructurenecessary to support the level of growth proposedover the plan period (Policy TI4). Where development

Words that sound good but the reality is that the planproposes over development and due to the lack ofappropriate infrastructure to support the developmentit will have a negative effect on the health andwellbeing of residents.

generates a need for new physical or socialinfrastructure, the developer will be expected toprovide, or contribute towards, these facilities.

Noamendment.

Noted. The impact of development on communityfacilities or social infrastructure would be consideredunder Policy TI4 (Delivery of New Infrastructure).

Policy should ensure that development does notnegatively impact on the capacity or function ofcommunity facilities or social infrastructure.

Amend Part H of the policy to ensure thatdevelopment does not negatively impact on thecapacity or function of community facilities or socialinfrastructure.

Table 5.8 Key Issues: Policy GS7 Health and Wellbeing

GS8: Nidderdale Area of Outstanding Natural Beauty



N/ANoted.Support policy (NYCC).

Welcome introduction of this policy which we consider to be positiveand inline with NPPF para 115. Also welcome reference to the settingof the Yorkshire Dales National Park in supporting text. (NaturalEngland)

Noamendment.

It is considered that the Policywording which refers to 'specialqualities' would adequately cover thispoint.

Support reference to fact that development outside a designatedlandscape but within its setting can have a detrimental impact issupported. Welcome inclusions of protection of Dark Skies. (CPRENY)

Policy could be strengthened with reference to preserving tranquility.

Noamendment.

Note support for Policy. The YorkshireDales National Park Authority havenot sought any changes to the Plan orthis Policy in respect of the Parksetting.

Support policy but protection of setting of Yorkshire Dales NationalPark also needs to be reflected within the Policy. (Historic England)

Amend Policy wording to refer to protection of setting of YorkshireDales National Park.

Noamendment.

The scale of allocations in the AONBaccount for 4.5% of all dwellingsexpected to be delivered fromallocated sites across the Districtduring the plan period.

Plan does not afford highest level of protection to AONB, as set outin paragraph 3.76, by allocation of sites. Disagree that Plan hasidentified only modest levels of growth in settlements within theAONB, this does not take account of the level of development alreadypermitted.

The SA has been updated to includea strengthened assessment ofcumulative impacts.

Delete housing allocations in Darley and review allocations in otherAONB settlements to take account of permitted developments.

Combined housing commitments and allocations in AONB villagesis excessive and likely to result in significant and detrimental impactto the villages and the wider AONB. Sustainability Appraisal should





The Harrogate District Local PlanSubmission Draft August 2018 ,Sustainability Appraisal Vol.1/Vol.2

have considered the cumulative impact on clustered ruraldevelopment in villages and in wider areas of significance such asthe Nidderdale AONB.

updated following Publication DraftConsultation will be included in theExamination Library

Table 5.9 Key Issues: Policy GS8 Nidderdale Area of Outstanding Natural Beauty



6 Economy

Amendment to the PlanHBC ResponseKey Issue

No amendment.Noted, however, this is not a matter within theremit of the Local Plan. The Council's EconomicGrowth Strategy sets out the targetedinterventions the Council, along with partners,will deliver across the District.

Employment land supply is not enoughHarrogate needs to offer a package ofbusiness support measures.

No amendment.Noted, however, the Key Facts are onlyintended to provide high level backgroundinformation.

Disagree with key facts: key employmentsectors are in stages of late maturity/ earlydecline.

Reference in key facts to number of start-upsis misleading - should give a net figure. Alsodoes not reference fact that district's mostqualified residents work outside the districtand Harrogate acts as dormitory town.

No amendment.The impact of Brexit has been considered (inthe HEDNA) but as there are a number ofunknowns in relation to the final Brexit deal this

No consideration of recent threats:Brexit: adversely affect financial servicesand residents who work in Leeds orYork does not provide a clear basis for adjustment's

to the assessed housing and economicdevelopment needs of the Local Plan to bemade.

Fracking: reduce tourists and affectproperty prices.

As the Minerals andWaste Joint Plan containsa number of policies related to hydrocarbondevelopment it is not considered appropriateor necessary for the Local Plan to duplicatethese.

No amendment.As a whole the Plan does recognise this forexample in paragraphs 3.38 and 5.13.

No consideration of how lowworkplace wagesleads to price-sensitive customers who shopoutside of Harrogate and who cannot affordproperties.

In the Economy KeyFacts section add newbullet point: 'House

Whilst this could apply to any local authorityarea within the country it is agreed that someinformation could be included in the Key Factssection.

No recognition of substantial economicbenefits that can be delivered through thehouse building industry. References to thebenefits of housing development should beincluded.

building in NorthYorkshire wasresponsible for 10,664jobs, of which 903 werein Harrogate district (HBFRegional Report(Yorkshire andHumberside) EconomicFootprint of Uk HouseBuilding, 2015)

No amendment.It is considered that read as a whole the Planadequately deals with this economicdevelopment in rural areas.

Consider more emphasis should be placedon the importance of economic developmentin rural areas of the district.

Table 6.1 Key Issues: Employment General

EC1: Protection and Enhancement of Existing Employment Areas



N/ANotedSupport (includes YNYER LEP)


6Economy



No amendment.It is unclear in what way the respondentconsiders this to be the case. However,representations from the YNYER LEP

Approach taken by Plan to local economy does not fullyreflect the YNYER Strategic Economic Plan.

to the Publication Local Plan confirm thatthe Plan would support theimplementation of their StrategicEconomic Plan.

No amendment.Noted, although disagree that specificreference is needed. When aneighbourhood plan is made it will formpart of the Development Plan and will betaken into account accordingly.

Where a Neighbourhood Plan is made such unidentified sitesas are shown in the relevant neighbourhood plan's policiesmap should continue in employment uses.

The following wording should be added to thepolicy: "Notwithstanding the identification of key employmentsites, where a made neighbourhood plan is in existence, toafford local distinctiveness, such unidentified sites as areshown in the relevant neighbourhood plan’s policies mapshould continue in employment uses"

No amendment.The HEDNA concludes that there is afuture need for 54.8 hectares ofemployment land up to 2035. To provide

Issue with Employment Land Requirement

The HEDNA concludes that 54.8 hectares of employmentland are required over the District. With 16ha of vacant landon existing employment sites the requirement should become

the most robust overall figure this isbased on a combination of labourdemand projections and historic deliverytrends (depending on the B use class).

38.8 ha. The gross requirement is based firstly on labourdemand projections of 17.6ha which was increased to 28.2hato provide flexibility. A separate forecast was made byextrapolating development rates from 2006 to 2016 and thatconcluded with a need for 49.8 ha based on looking atdifferent use classification requirements. The importance ofthis is that future employment is likely to require more landper employee (in manufacturing, distribution and retail).However the HEDNA then uplifts the allocation for flexibilityagain, thus double counting.

Policy

No amendment.It is considered unnecessary to repeatelements of the evidence base in thePlan's reasoned justification. However,

Policy EC1 should acknowledge the conclusions of theHEDNA which identifies the lack of sites in and aroundHarrogate and Knaresborough. It should also acknowledge

the majority of the employmentallocations made in the Plan are in theHarrogate/Knaresborough area.

that there are limitations for allocating large scale employmentin the western part of Ripon In light of this there should be agreater focus on deliverable and sustainable sites within theKnaresborough and Harrogate.

Policy EC1 and the reasoned justification should acknowledgethat there is an under supply of developable employmentsites within the existing employment areas of Harrogate andKnaresboroughwhere there is considerable demand for spacefor larger and national occupiers.

No amendment.It is clear from the reasoned justificationto Policy EC1 that proposals would notbe expected to satisfy all of criteria E toJ.

Draft Policy is unclear about how the matters forconsideration (matters E to J inclusive) are to be taken intoaccount in determining planning applications. Specifically,the implication from the written justification is that proposalsmust satisfy all of the criteria E to J before permission maybe granted. However, justifying proposals in the context ofany one of the matters should be sufficient justification toapprove alternative proposals.


Economy 6



Draft Policy EC1 should be amended to make it clear that achange of use from an existing employment use will beapproved in circumstances when any of the criteria E to Jinclusive are satisfied.

No amendment.A note to the Policy makes clear thatthe provisions of the Policy will applyonce the site is developed.

Policy requires various information to be provided whereproposals for alternative uses come forward on existingemployment sites.

The policy and justification should be explicit in noting thatthese considerations will not apply to land allocated fordevelopment such as Knaresborough Cattle Market (K17).

Key Employment Sites

No amendment.It is recognised that the site is not inemployment use but it does haveplanning permission for a mixed use

Manse Farm is not currently in employment use or an existingemployment site. The wording of the policy in relation toManse Farm is overly restrictive and does not entail an

development, including an area forappropriate level of flexibility as required by the NPPF.employment use (Use Classes B1 andDeleting the site from Policy EC1 will ensure that sufficientB8). A note to the Policy makes clearthat provisions of the Policy will applyonce the site is developed.

flexibility (as promoted by the NPPF) is applied to those siteswhich may currently benefit from planning permission foremployment use but where that use has not beenimplemented, thereby enabling the site to respond better tothe market and ensuring that policy does not prohibit otherappropriate uses being brought forward on the site ifnecessary.

Manse Farm should not be retained under Policy EC1 as akey employment site but instead be considered as a mixeduse allocation.

Amend theboundary of theBoroughbridge

Agree that the econ premises and theWolseley premises should be includedas part of the Boroughbridge Road andthe Dallamires Lane key employmentsites

The designated key employment sites at BoroughbridgeRoad, Ripon should include the Econ premises and theDallamires Lane, Ripon site should include the Wolseleypremises in order to provide additional protected employmentareas for Ripon given the shortage of quality sites andpremises.

Road, Ripon keyemployment siteto include theEcon premises.

Extend the Boroughbridge Road and Dallamires Laneemployment areas. Amend the

boundary of theDallamires Lane,Ripon keyemployment siteto include theWolseleypremises.

No amendmentWhilst the Business Park providesimportant employment land within Riponand therefore would be offered protection

Add the College Business Park, Ripon to the list of keyemployment sites

under Policy EC1, the site is small scaleand therefore would not be classed asa 'key' employment site.

Amend PolicyEC1m to read(new text

Agree, reference should be made toboth Melmerby Industrial Estate andBarker Business Park.

Employment Allocations

List of sites to be allocated is incomplete and not consistentwith the site allocations. The two business parks at Melmerby(Barker Business Park, Melmerby Industrial Estate) need tobe listed separately.

underlined):'Melmerby


6Economy



IndustrialEstate/BarkerBusiness Park'

The two business parks at Melmerby (Barker Business Park,Melmerby Industrial Estate) need to be listed separately.

No amendment.The HEDNA has assessed this site asbeing a commercially attractive locationand as such the Council consider it

Land off Wetherby Road (H28) would be suitable for mix ofemployment and other uses to complement uses and activitieson the Showground. Provides prominent development siteon a principal route into Harrogate, in effect it is a 'shopwindow' for the Showground and Harrogate.

appropriate that it is identified for B uses.Other uses would be considered on theirmerits against the criteria set out in thepolicy.Remove restriction on uses applicable to Site H28.

No amendment.The site benefits from the protectionafforded to it as a proposed employmentallocation in the Local Plan.

Concern over loss of potential employment sites whereopportunities are in short supply and special circumstancesapply, such the Playing Fields, Harrogate College (H16).Given recent planning application, clear threat to site comingforward for employment land and should be afforded samelevel of protection under policy as for developed sites.

In respect of site H16, delete reference to site beingprotected once developed.

Delete K17 fromthe list of keyemploymentsites under EC1

While the site is still suitable for a mix ofuses, the HEDNA states that the site iscommercially unattractive and should beconsidered for alternative uses. In light

Mixed Use Allocations

Former Cattle Market, Knaresborough (site K17) shouldbe deleted as no employment use is anticipated within aredevelopment scheme for the site and policy protection forany employment component of a mixed use scheme is whollydisproportionate and unjustified.

of this evidence it would be appropriateto remove it from the list of keyemployment sites protected under PolicyEC1.

Cattle Market, Knaresborough should be deleted from the listin Policy EC1.

No amendment.The Policy criteria provide for theviability of the continuing use of a sitefor employment use to be considered.

Local Plan should not seek to constrain the uses withinemployment areas or the consideration of sites and premisesfor alternative uses where they are no longer suitable foremployment.

Table 6.2 Key Issues: Policy EC1 Protection and Enhancement of Existing Employment Areas

EC2: Expansion of Existing Businesses



N/ANotedSupport (including Historic England and YNYER LEP)

No amendment.Noted. It is considered that the policyprovides an appropriate level of flexibilityas sought be the respondent.

Support positively worded policy andmaximum flexibilityshould be integrated in the wording to ensure that thecriteria based approach does not stifle future economicdevelopment.

Table 6.3 Key Issues: Policy EC2 Expansion of Existing Businesses

EC3: Employment Development in the Countryside



N/ANotedSupport (including Historic England)


Economy 6



No amendment.As it would be inappropriate to allowunrestricted development in thecountryside it is considered essentialthat proposals satisfy all the Policycriteria.

It is important that the policy tests required are proportionateto the scale of the proposed use.

The first part of the policy should be rephrased to "Newdevelopment in the open countryside will be permitted whereone or more of the following criteria are satisfied"

AmendPolicy EC3Aii to read (newtext underlined,

To ensure consistency with thewording of other policies it is agreedthat reference to 'adjacent thesettlement' should be deleted.

Policy does not provide appropriate flexibility or reflectcircumstances where development in proximity but not adjacentto a settlement may be appropriate and give rise to sustainabilitybenefits as well. The 'well related' part of the policy is a deleted text struckduplication of the 'adjacent' test and therefore redundant. Well through): 'smallrelated could be considered in terms of accessibility, locationrelative to main transport routes etc. the base requirement tobe 'adjacent' is excessive.

scale new buildingadjacent to a ruralsettlement, whichis well related tothe settlement,... 'Re-word Policy EC3 A ii to read as follows: ‘ii. new build

development which is well related to the settlement, benefitsthe local economy, and reduces the need for increased carcommuting to urban centres’

No amendment.The criterion seeks to ensure thatconversion takes place withminimum intervention and retention

Para 4.20 - the test for the building to be structurally sound failsto recognise some of the practical issues regarding traditionalfarm buildings. the policy should be modified to permit buildings

of original fabric and that whenwhich are of substantial construction and capable of conversionwith some reconstruction work to be permitted in order that theycan be brought into a sustainable new use.

converted buildings are nottantamount to a new build. It isconsidered that the Policy strikes abalance between encouraging thePropose alterations to policy EC3 d) to read: "the building is of

permanent and substantial construction and capable ofconversion without the need for substantial extension oralteration".

re-use of rural buildings andensuring the architectural andhistoric character of traditionalbuildings are not undermined.

No amendment.The Local Plan makes adequateprovision to meet employment landrequirements over the plan period.

Important Local Plan recognises value of prosperous and viablerural community and supports thriving rural economy andcountryside. Local developers keen to invest and may be rurallocations e.g. alongside principal transport corridors presentappropriate development opportunities.

The location of sites as suggestedby the respondents would not beconsistent with the Local Plangrowth strategy.Plan does not encourage growth and employment opportunities

along A1(M) or in open countryside where it would relate wellto existing infrastructure links.

Amend policy wording: 'New employment development will alsobe permitted in the countryside where it is strategically locatedwithin the A1(M) corridor and relates closely to existingsettlements within approximately 2km. Development of this typewould need to mitigate as far as possible any impact on thelandscape, character, appearance or general amenity of thearea.'

Table 6.4 Key Issues: Policy EC3 Employment Development in the Countryside

EC4: Farm Diversification


6Economy



Amend Criterion Bto read (new textunderlined, deleted

Agree that the suggestedamendment would provideclarification and consistencywith national policy.

Criterion B wording could potentially allow a development eventhough it would result in considerable harm to heritage asset, whichis not consistent with national policy (Historic England).

text struck through):'There is nosignificant adverseimpact .... '

In Criterion B delete 'significant'

No amendment.As it would be inappropriateto allow unrestricteddevelopment in the

Policy tests and information required should be proportionate toscale of proposed use.

countryside it is consideredessential that proposalssatisfy all the Policy criteria.

First part of policy should be rephrased to: "Proposals relating tofarm diversification and other land based enterprises will besupported where one or more of the following criteria are satisfied."

No amendment.It is considered that thepolicy is appropriatelyworded.

Whilst support for diversification of farming businesses is welcomeddo not consider Policy positively supports development of theunderlying agricultural enterprises. Policy should be amended togive support to ongoing development of traditional agriculturalenterprises and their diversification is supported by properlyrecognising, in policy terms, the remote nature of a significant numberof these businesses and the appeal which those locations have tovisitors.

Amend wording of the first paragraph of the policy and Criterion Dto:

"Proposals relating to the development of agricultural enterprises,farm diversification and other land based enterprises will be permittedwhere all of the following criteria are met: …..

d) The proposal forms part of a comprehensive strategy and isoperated either as part of a sustainable farm or appropriate landbased enterprise and will contribute to the viability of that existingbusiness or, for new enterprises, is supported by a Business Planwhich demonstrates to the District Council that the development isin support of a viable enterprise.’

Table 6.5 Key Issues: Policy EC4 Farm Diversification

EC5: Town and Local Centre Management



N/ANotedSupport (Historic England)

Noamendment.

The 'Primary Shopping Centre' in Masham is notnewly defined and was previously referred to as'Shopping Centre' in the Harrogate District LocalPlan. Policy requirements for the area have notchanged, just the title of the area.

Object to the newly defined 'Primary Shopping Centre'in Masham. Buildings should not be identified as PrimaryShops without consultation with the landowners as itbestows new legal requirements on them.

NoAmendment

The sequential approach and the impact test areset out in paragraph 4.30 of the justification. It isnot necessary to repeat national policy and havethe wording within Policy EC5.

The wording of Draft Policy EC5 should be amended tomake specific reference to the sequential approach tosite selection and the impact test set out within the NPPF.

Noamendment.

Retail development outside of a PrimaryShopping Area (unless to meet local needs)would require an impact assessment. Paragraph

Policy does not set out the circumstances when therefusal of planning permission would be justified followingan impact assessment for retail development locatedoutside the town centre.


Economy 6



4.30 clearly sets out such developments will onlybe allowed if the proposal will not lead to asignificant adverse impact.

Noamendment.

The Council considers it appropriate to requireimpact assessments for smaller retaildevelopments where particular concerns ariseas a result of the size and nature of any proposalsas, over time, local circumstances may change.

The final paragraph of Sub-Section D where the Councilreserve the right to require an impact assessment forretail proposals below the thresholds should be deletedas there is no justification for this.

Noamendment.

Noted, although disagree that specific referenceis needed. When a neighbourhood plan is madeit will form part of the development Plan and willbe taken into account accordingly.

Where a made neighbourhood plan is in existence, toafford local distinctiveness such town centre boundary,shopping area or shopping frontage as may be definedon the relevant neighbourhood plan’s policies map shallbe taken to apply. Add after C and E

"Notwithstanding the definition of a Town CentreBoundary, Primary Shopping Area, Primary ShoppingFrontage and Secondary Shopping Frontage in a townor local centre, where a made neighbourhood plan is inexistence, to afford local distinctiveness such town centreboundary, shopping area or shopping frontage as maybe defined on the relevant neighbourhood plan’s policiesmap shall be taken to apply."

Table 6.6 Key Issues: Policy EC5 Town and Local Centre Management

EC6: Protection of Tourist Facilities



N/ANotedSupport the Policy

Noamendment.

The Visitor Accommodation Studyjustifies the threshold as set out in thePolicy. However, disagree that specific

Notwithstanding the strategic nature of this policy and in thatthere shall be a threshold of number of lettable bedrooms, wherea made neighbourhood plan is in existence, to afford local

reference as suggested by thedistinctiveness the threshold itself shall be that included in therelevant neighbourhood plan. Evidence for this representationcan be found in the Submission Draft Ripon City Plan.

respondent is needed. When aneighbourhood plan is made it will formpart of the Development Plan and will betaken into account accordingly.Add after Hotel Provision. (Ripon City Council)

"Notwithstanding the strategic nature of this policy and in thatthere shall be a threshold of number of lettable bedrooms, wherea made neighbourhood plan is in existence, to afford localdistinctiveness the threshold itself shall be that included in therelevant neighbourhood plan."

Harrogate town’s role in the provision of hotel accommodationshould not inhibit the protection of hotels in other towns which,although smaller, play a significant role in the local visitoreconomy. (Ripon Civic Society)

Amend paragraph 4.42 to admit lower lettable bedroom thresholdsin neighbourhood areas.


6Economy



Noamendment.

This is a broad paragraph which explainsthe importance of the tourism industryfor the Harrogate District to justify the

Listing of the district’s tourist assets is unnecessarily restricted,omitting as it does Ripon Cathedral and museums whilstmentioning “the historic city of York and vibrant, cosmopolitanLeeds”. This is a Local Plan, not a tourist brochure for otherareas. (Ripon Civic Society)

need for a 'Protection of Tourist Facilities'policy. It is not designed to be a list ofspecific tourism assets but just providessome examples. The reference to theAmend paragraph 4.36 to admit a broader range of tourism

attractions within the district and diminish references todestinations beyond the district.

wider area is to recognise that thetourism industry of the District benefitsfrom it location close to "the historic cityof York ....".

Table 6.7 Key Issues: Policy EC6 Protection of Tourist Facilities

EC7: Sustainable Rural Tourism


N/ANotedSupport the Policy

Amend Criterion B to read(new text underlined, deletedtext struck through): ' ......

Agree thatamendments wouldprovide clarity and also

The NPPF, in its definition of the environmental dimension ofsustainable development, makes a distinction between built,natural and historic environment. For consistency (and to make

high quality of the district'sbuilt, and natural and historicenvironment.

consistency of wordingwith similar criteria inother policies.

it clear to users of the Plan that the “high- quality environment”being sought actually refers to the historic environment as well),this Criterion should be framed in a similar language. (HistoricEngland)

Policy EC7, Criterion B amend to read:

"high quality of the district's built, natural and historic environment"

No amendment.Such proposals wouldbe considered on theirmerits against thepolicies applicable atthat time.

Amend justification to ensure that conversion of static holidayhomes to permanent residential developments will not bepermissible in the future. (CPRE North Yorkshire)

Amend wording of CriterionA to (new text underlined,deleted text struck through):

Agree that amendmentas suggested by therespondent would beappropriate.

Criterion A is overly restrictive and is inconsistent with paragraph28 of the NPPF.

Delete Criterion A or amend wording to: 'It can be demonstratedthat proposals for new attractions or accommodation require alocation outside the settlement boundary.'

"it can be demonstrated thatproposals for new attractionsor accommodation cannot belocated within or adjacent tothemain towns, local service

Concerned that Criterion A could put in place a sequential testwhich it will be impossible for conversion schemes to satisfy. Solong as an applicant can demonstrate that the re-use of a

centres and primary servicevillages and subsequentlythat locations within or

traditional farm building for visitor accommodation is sustainable, adjacent to secondaryit should not be necessary to demonstrate that the proposal could service villages have beennot be located within or adjacent to main towns, local service fully considered require a

rural location and cannot beaccommodated elsewhere"

centres and primary service villages. Also important to recognisethat staff accommodation might be provided off site for hotel andother sector staff.

Delete paragraph 4.49Amend Policy to include two new criteria:

"b) In considering new accommodation for staff, the provision ofaccommodation off site will be considered where this is adjacentto a main town, local service center, primary or secondary servicevillage and is justified as part of the applicant's strategy.


Economy 6


c) Where the re-use of traditional farm buildings is proposed forrural tourism, this will be permitted where it satisfies the followingcriteria".

Table 6.8 Key Issues: Policy EC7 Sustainable Rural Toursim


6Economy

7 Housing



No amendment.Comments noted, however, it is considered that asthe Local Plan makes provision for the delivery ofaffordable housing through Policy HS2, the explicitpolicy sought by the respondent is not necessary tomake the Plan sound.

Section should include a community ledhousing policy to deliver genuinely affordablehousing and increase community cohesion.

Table 7.1 Key Issues: Housing General

HS1: Housing Mix and Density



Consistency with National Policy

Noamendment.

There is a limited availability of local data,therefore, the HEDNA was prepared usingnational data. As stated in the HEDNA, these

Policy is not in line with Written Ministerial Statement inrespect of higher optional housing standards.

conclusions are based on considering the fullProvide local assessment evidencing specific case forinclusion of higher optional standards for accessible andadaptable homes, applying criteria set out in PPG.

range of evidence in the round. The HEDNAconclusions reflect the relative level of disabilityissues in the District as well as projected changesto the age profile of the population movingforward.

The HEDNA assessment has beensupplemented by evidence in the HousingBackground Paper (November 2017) using thesources of information identified in the data sheeton available disability data published by theGovernment, which planning authorities can drawfrom to inform housing needs assessments, anddata from POPPI (Projecting Older PeoplePopulation Information).

The Council considers the inclusion of the higheroptional technical standards to be appropriatelyevidenced based on the data which is available.

Noamendment.

Policy HS1 refers to M4(2) (accessible andadaptable dwellings) not M4(3) (wheelchair userdwellings) as suggested by the respondent.

Requirement for 25% of market homes to comply withPart M4(3) is inconsistent with national policy as thisshould only be applied to those dwellings where localauthority is responsible for allocation/nomination of personto that dwelling.

Delete reference to application of Part M4(3) to markethomes.

Issues with Evidence Base/Consistency

Noamendment

There is a limited availability of local data,therefore, the HEDNA was prepared usingnational data. As stated in the HEDNA, these

Council should identify and provide evidence specific toHarrogate to support policy in relation to future need; size;location, type and quality of dwellings needed;

conclusions are based on considering the fullaccessibility and adaptability of existing stock; how needsrange of evidence in the round. The HEDNAvary across different housing tenures; and overallconclusions reflect the relative level of disabilityviability. Whole Plan Viability Assessment tests 10% of

housing being accessible and adaptable whereas draftpolicy proposes 25%.

issues in the District as well as projected changesto the age profile of the population movingforward.


Housing 7



Delete optional housing standards or if to be retainedprovide appropriate evidence base and appropriateviability clause.

The evidence provided by the HEDNA has beensupplemented by evidence in the HousingBackground Paper (November 2017).

An update to the WPVS (May 2018) has testedthe changed policy requirement (as contained inthe Publication Local Plan) in respect of the

No evidence/viability testing to support requirement for25% adaptable homes or indication as to where theyshould be located. Further evidence to justify approachis required.

accessible and adaptable standard andconcludes that the policy requirements of theLocal Plan (cumulatively) are unlikely to preventdevelopment from coming forward.Requirement for 25% accessible and adaptable homes

is removed or if retained appropriate evidence is providedto justify requirement and demonstrate its viability. It is recognised that it may not be practical or

feasible to incorporate accessible and adaptablehomes on every site and the Policy has beenworded accordingly.No justification for 10 dwelling threshold for provision of

accessible/adaptable homes.The Housing White Paper 'Fixing our BrokenHousing Market', was clear that in bringingforward an adequate supply of accessible

Further information on viability testing of HEDNAmix andaccessible/adaptable homes recommendations required,as WPVS testing pre-dates HEDNA. housing to meet local need, planning authoritiesLocal housing needs can be met without introduction ofoptional housing standards and should be deleted or ifretained supported by appropriate evidence base

should set policies using the optional technicalhousing standards. This has been broughtforward into the draft update to the PlanningPractice Guidance (March 2018).

The Council considers, therefore, the inclusionof the optional technical housing standards to beappropriately evidenced and justified.

Noamendment.

Policy HS1 requires new development to providea wide mix of homes to meet the range ofhousing needs and demands of the District's

HEDNA has not fully assessed the full needs arising forspecialist housing over the plan period, particularly theneed for older peoples’ accommodation.

residents: this will cater for all types of housingneeds, including housing suitable for olderHEDNA needs to be reviewed/ amended to address

omissions regarding specialist housing, or reference tothe HEDNA should be removed from the policy.

people. Section 9 of the HEDNA considers theneed for older persons housing, particularlyspecialist homes and registered bedspacesneeded over the plan period. Policy HS4 supportsolder persons specialist housing.

Flexibility

N/ANoted.Support intention to allow variations from indicativedensities to take account of site specific circumstances(Historic England).

Noamendment

The Policy already provides flexibility in respectof local site characteristics influencing both thehousing mix and density of a development andfurther flexibility is not considered to be required.

Welcome flexibility in relation to local site constraints butfurther flexibility could be incorporated to take account ofevidence in relation to local site characteristics andviability.

Further flexibility is included in relation to mix of housingand density of development.

Noamendment

The HEDNA sets out a suggested mix foraffordable, intermediate and market housingbased on evidence as gathered for the District

Investment decisions based on reference to HEDNA toguide housing mix may be undermined by suddenchanges in advice; provision of 1 bed housing is not

as a whole. The HEDNA explicitly states (atflexible to future changes in demographic trends andparagraph 10.49) that the suggested mix isreflective of long term needs and should not beapplied prescriptively to each site.

needs; minimum density requirement not sufficiently clearand should be acceptable to net off strategic landscapingand SUDs.


7Housing



The Policy, as worded, does not set a rigidhousing mix but expresses a desire to worktowards the mix set out in the HEDNA and is

Amend Policy supporting text to allow focus on 4 bed aswell as 2/3 bed properties, that needs assessment maychange and the minimum density requirements may benet of strategic landscaping areas and SUDs. clear that the final mix will be subject to

negotiation. The local analysis provides furtherguidance on mix, which reflects the consultationundertaken with developers and others relevantDoes not recognise that housing mix need will vary over

time and geography and does not reflect the Council'seconomic growth agenda.

to specific areas. However, the district wideneeds is the starting point and should takeprecedence over the local mix, although clearly

No reference to how frequently HEDNA will be updated,has bearing on changing housing mix requirements.

the local mix should be a factor in determiningthe flexible range on a site by site basis. Theoverall mix will be dependent on the number ofunits and affordable units that are being plannedfor.

As method of calculating housing need over plan periodmay change, policy should reference 'evidence' ratherthan 'HEDNA'.

The draft Policy recognises the HEDNArepresents a moment in time by referring to thelatest HEDNA and the use of the most up to date

Reference 'evidence' rather than HEDNA.

Welcome flexibility provided in respect of density butwould emphasise Council should take pragmatic approachwhen considering density and that applicants should notneed to provide onerous evidence.

evidence of need/demand (paragraph 5.8), whichmay come from other sources. It is notconsidered necessary to state the frequency ofHEDNA updating: the required mix will bereviewed throughout the plan period reflectingthe evidence at that time. It is also likely, throughthe draft revisions to the NPPF, that policies willbe required to be reviewed to assess whetherthey need updating at least once every five years.

Paragraph 5.10 of the reasoned justification isclear that the density requirement would applyto the net developable area of a site. It isexpected that demonstration of compliance withthe density element of the policy would form partof any design statement or similar document,which may be submitted in support of a planningapplication.

Local Assessments of Housing Need

Noamendment

Local assessments of housing need couldinclude assessments of local housing needundertaken as evidence for preparation of aNeighbourhood Plan.

Wording is unclear as to who will undertake localassessments or whether responsibility of applicant toprovide evidence to support development mix: would beonerous requirement if developer has to provideassessments.

Paragraph 5.8 of the reasoned justification isclear that where the mix of housing does notrespond to identified needs, it will be the

Amend supporting text to policy to provide clear guidanceon what is expected from local assessments of housingneed and how frequently HEDNA will be updated. applicant's responsibility to demonstrate why the

mix proposed is appropriate with reference to thelevel of identified need, existing housing stock,financial viability and deliverability.Disproportionate to require every scheme which deviates

from HEDNA on housing mix to provide additionalevidence without any clarity on what they should contain,who should provide them, recognition of changing needsover time or economic growth agenda.

Not clear in justifying text to Policy what is expected -potential to cause delays in determination of planningapplications.

Implementation/enforcement


Housing 7



Noamendment

The HEDNA sets out a suggested mix foraffordable, intermediate and market housingand explicitly states (at paragraph 10.49) that it

No safeguards to ensure that the housing mix that getsbuilt will match the needs identified in the HEDNA.

should not be applied prescriptively to eachsite. Policy HS1 does not, therefore, set a rigidhousing mix but expresses a desire to worktowards the mix set out in the HEDNA.This provides the flexibility required by the NPPFto ensure that the development of sites remainsviable and also to reflect that the type/size ofhousing required may change over the planperiod.

Relationship with Neighbourhood Plans

Noamendment.

Noted, although disagree that specific referenceis needed. When a neighbourhood plan is madeit will form part of the development Plan and willbe taken into account accordingly.

There a made neighbourhood plan is in existence, toafford local distinctiveness the minimum net density itselfshall be that included in the relevant neighbourhood plan.(Ripon City Council)

Add to Policy: "Notwithstanding the strategic nature ofthis policy and in that new housing development will beexpected to achieve a minimum net density includingdevelopment within a defined town and city centre, wherea made neighbourhood plan is in existence, to afford localdistinctiveness the minimum net density itself shall bethat included in the relevant neighbourhood plan".

AONB

Noamendment.

Although the Policy expects developments wouldachieve a minimum density of 30 dwellings perhectare, where this would have a detrimental

The densities in the policy do not have due regard to thesignificance of the AONB and therefore to suggest densitymore suited to the middle of main settlements isinappropriate and not in conformity with the NPPF andsensitive locations.

impact on the character or amenity of the area,then the Policy allows for development at a lowerdensity to be permitted.

Adaptable Homes

Noamendment

The reasoned justification (paragraph 5.7)explains that the Council want the district'shousing stock to be more flexible, enabling

Requirement for adaptable homes must have regard tolocation and context of the development. No guaranteethat houses provided would be occupied by householdswho would directly benefit from it being adaptable. households and other sections of the community

likely to have a need for housing designed tomeet their changing needs to have those needsmet.

Delete requirement for 10% of homes to be adaptableand accessible.

Older Persons Housing

Noamendment.

Policy HS1 is not prescriptive on the mix ofhousing types to be provided on individual sites.This provides the flexibility required by the NPPF

To enable older people to stay in their own home, housingmix needs to provide for bungalows and have moreemphasis on smaller units.

to ensure that the development of sites remainsviable. However, the policy does require newdevelopment to provide a wide mix of homes tomeet the range of housing needs and demandsof the District's residents and for a proportion ofthese to be designed to be adaptable: this willcater for all types of housing needs, includinghousing suitable for older people.

Table 7.2 Key Issues: Policy HS1 Housing Mix and Density


7Housing

HS2: Affordable Housing



N/ANoted.Support the Policyviability wording is welcomed as itprovides flexibility

support flexibility to bring sites forwardwhere viability issues or need foraffordable housing cannot bedemonstrated.

Evidence Base

No amendment.The HEDNA (paragraph 7.12) acknowledgesthat the analysis has shown a decliningaffordable housing need compared to previous

Comparing documents in the evidence basethe number of affordable houses needed acrossthe district decreased by 18% between the

assessments in 2015 and 2016. As noted, theassessments carried out in 2016 and 2017.reality is that figures can vary and are specificSpecifically, the document issued in June 2016to the point at which analysis is undertaken.stated that the council needed to build 5,383Given that the net need is a function of two largeaffordable houses up to 2035. Less than a yearnumbers (gross need and gross supply) smallchanges can have quite a notable impact on thebottom line needs estimate.

later this changed to 4,397. No satisfactoryexplanation is given for the decrease. This lackof consistency throws doubt on the objectivenature of the assessment.

When looking in detail at the specific figures forindividual components of need, the keydifference is a reducing level of newly forming

Reassess the affordable housing need toprovide a % of the total housing need based onthe housing waiting list. households in need (this accounts for virtually

all of the difference in the assessments). Thelower estimated number of newly formingReassess the affordable housing need to

provide nearer to 40% of the total housing need.A more consistent forecast in relation to earlierassessments with full explanation of whychanges are being made is required.

households is largely driven by reducingprojected household growth in the CLGprojections rather than any changes to theoverall affordability of housing or the supply ofre-lets.

No amendment.The HEDNA provides the necessary evidenceon need, supplemented by information in theHousing Background Paper (November 2017).

Whilst supportive of the provision of homes forolder and disabled persons, it needs to be clearwithin the evidence why the provision of allaffordable homes at these higher standards isjustified. PPG is also clear that Local Plan An update to the WPVS (May 2018) has

reconsidered viability based on the policyrequirements of the Publication Plan. This

policies for wheelchair accessible homes shouldbe applied only to those dwellings where thelocal authority is responsible for allocating or concludes that the policy requirements of the

Local Plan (cumulatively) are unlikely to preventdevelopment from coming forward.

nominating a person to live in that dwelling (ID:56-009). Therefore, there will need to be a clearpolicy for how the Council will work withdevelopers and housing associations to deliverthese homes.

The Council should ensure they have theappropriate evidence to support the introductionof the 10% policy or that the elements that arenot justified are deleted from the policy

Viability

No amendment.Noted.The evidence provided within the ViabilityAssessment highlight the issues of the viabilityof the affordable housing requirement, andparticularly so in Ripon.


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No amendment.The affordable housing targets for greenfieldand brownfield sites are justified by evidence ofneed (as set out in the HEDNA) and viability

It is noted that a viability clause is includedwithin this requirement. Whilst this is supportedit should not be used as a mechanism to justify

assessment (as set out in the WPVS) and arean unsustainable affordable housing target. Theconsidered to be realistic and achievable.Council should consider its evidence further andHowever, viability is a material consideration inamend the affordable housing targetsdetermining a planning application where theprovision of affordable housing is expected andthe wording of Policy HS2 reflects this.

accordingly. This may require variablecontributions based upon geography and / orother criteria.

The percentages of affordable homes requiredseems incredibly low given: the scarcity of landwhich can be developed without threatening the

The HEDNA provides the necessary evidenceon need and the WPVS update providesevidence on the impact of viability in respect ofaccessible and adaptable homes.rural nature of our district; the importance of

preserving land for food production and wildlife;that affordable homes are likely to occupy asmaller area thanmore expensive larger homes.

An update to the WPVS (May 2018) hasreconsidered viability based on the policyrequirements of the Publication Plan in respect

Targets of 30-40% are accompanied by toomany negotiable conditions and escapeclauses. The target should not be optional

of accessible and adaptable dwellings. Thisconcludes that the policy requirements of theLocal Plan (cumulatively) are unlikely to preventdevelopment from coming forward.Where schemes are viable, developers should

not be able to renegotiate the delivery onaffordable housing on reserved mattersapplications. If not viable for private developerthen HBC could take control and build socialhousing or gift land to community groups orcreate serviced plots on the land.

Para 5.19 - contains the get-out for allhousebuilders and will ensure that affordablehousing needs are not met. The Homes &Communities Agency Housing Statistics Reportfor April – October 2017 published on 28November 2017 shows that the proportion ofhouse builds started (excluding London) in thatperiod that were affordable was 52% of the totalcompared with an average of 60%-70% inrecent years.

Remove paragraph 5.19

The justification for the 40% requirement isweak and requires further justificationparticularly as the Whole Plan Viability studywas published before the HEDNA. The findingsof the HEDNA have therefore not beenconsidered in the WPV in relation to theamended affordable housing requirement.

The WPV and the Housing Background Papershould be updated in light of the amendedHEDNA evidence.

Affordable housing percentage requirementsset out in Policy do not seem to reflect theevidence base from the viability testing of thePlan. Specific evidence to support inclusion ofhigher optional housing standards also required.

The affordable housing requirement should beamended to better reflect the evidence


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Other Issues

No amendment.It is acknowledged in the HEDNA that theaffordable housing need comprises around 30%of the OAN (669 dwellings per annum), which

Number of elements of policy wording areunclear:

is lower than the 40% sought in Policy HS2, andHEDNA indicates that 30% rate relatesto affordable rent but unclear howexpected remaining tenures would addfurther 10% to requirement when appearsneed has fallen substantially

that affordable needs have been declining overtime. However, the HEDNA also notes(paragraph 7.13) that the reduction in the needfor affordable homes over time is largely aproduct of a lower estimated number of newlyforming households, which is largely driven bynothing in evidence base to justify

reduction in affordable housingcontributions on brownfield sites. Not all

reducing projected household growth in the CLGprojections rather than any changes to theoverall affordability of housing or the supply ofre-lets.

brownfield sites have viability issues andcan be circumstances where greenfieldsites face viability issues

It should also be borne in mind that the OAN isfor all sites, including smaller sites, whereasaffordable housing provision will only begenerated from larger sites and it is not,therefore a direct comparison.

threshold approach based on location andjustifiable evidence would be moreconstructive than requiring provision ofdevelopment appraisals for mostschemes, which is onerous requirement.

The WPVS (September 2016) showed that thedevelopment represented by the brownfieldtypologies was not generally viable at 40%Update affordable housing requirement in line

with viability evidence. affordable housing and that a reduced affordablehousing contribution (30%) should beconsidered.

Policy HS2 sets a target of 40% affordablehousing on greenfield allocations. Para 5.16acknowledges that the need is 30%. In these

The Policy provides flexibility, enabling the mixof affordable housing tenures to be provided toreflect local evidence of housing need at thetime of determining the application.

circumstances it is difficult to justify the currenthigh levels of affordable housing being soughtand provided.

Viability is a material consideration indetermining a planning application where theprovision of affordable housing is expected,therefore, the wording of Policy HS2 reflectsthis.

Change affordable requirement to 30% to reflectHEDNA

In general policy wording should be lessflexible.

Fail to see why there should be a difference inaffordable housing requirements for brownfieldand greenfield sites.

Final tenure mix should be set by policy andchanges should not be allowed.

Failure to meet requirements should not beallowed and paragraph 7 should be deleted.

Paragraph 7 (failure to meet requirements)should be deleted.

Paragraph 4 (final tenure mix) should bedeleted.

Affordable housing requirement should be 40%on greenfield and brownfield sites.


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No amendment.All housing developments that meet thethresholds set out in Policy HS2 will be expectedto make affordable housing provision, thedefinition of which includes social rented as wellas other affordable tenures.

Affordable housing within the district is notgenuinely affordable to those on a low income.

Plan does not included any robust measures toensure required level of truly affordable housingis delivered and in a way that makes itsustainably affordable.

No amendment.Comments noted. However, the use ofcommuted sums received is a decision for theCouncil outwith the Local Plan process.

Policy should allow for commuted sums to beaccessible to community led housing groups toprovide affordable housing.

No amendment.Noted. The supporting text does not specify thesize of a pepper potted group.

With regards 'pepper potting', up to 12affordable houses can be grouped togetherwithout compromising the policy's desire toimpose mixed communities and avoid socialexclusion.

No amendment.The Written Ministerial Statement (November2014), which introduced thresholds above whichlocal authorities could require affordable

The policy proposes a change to the thresholdfor affordable housing from 11 units to 1,000square metres. In many cases this will be

housing, refers to sites of more than 10units or more than 1,000 square metres: thewording of Policy HS2 is consistent with this.

markedly less than 11 units and so we do notbelieve this is justified or in line with nationalpolicy.

Change threshold for affordable housing to 11units.

Table 7.3 Key Issues: Policy HS2 Affordable Housing

HS3: Self and Custom Build Housing


HBC ResponseKeyIssue/SuggestedModification

Legal Compliance

Noamendment.

The Self and Custom Build Housing Act 2015 requires authorities to give suitable developmentpermission in respect of enough serviced plots of land to meet the demand for self and customhouse-building in the authority’s area arising in each base period.

The policy doesnot comply withthe self build actsupported by theNPPF which The Council has established a self and custom build register to provide an indicator of demand

for self build plots within the district. The data from this register will be used along withother sources of information where necessary to consider the need for this type of plot.

states thatindividuals on theself-build registermust be offered a The Councils considers that the policy approach set out within Policy HS3 Self and Custom

House Building will ensure that demand on the register can be met. Policy HS3 makes aspecific requirement for plots to be made available on strategic housing sites. It is our

plot within 3 yearsof putting theirname on the expectation that, whilst this will provide a proportion of the plots required to meet the demandregister. These identified by the self-build register, a proportion of self builds will also come forward on smallplots of 500+ sites and single plots on infill sites and sites on the edges of settlements. There is a longcannot provide history of windfalls sites consistently becoming available across the Harrogate district and itenough plots for is considered that they will continue to provide a reliable source of supply during the planself-builders, nor period. The Councils 2017 Annual Monitoring Report indicates that 70 suitable development

permissions were granted on single dwelling plots during the first baseperiod: https://www.harrogate.gov.uk/downloads/file/3549/2017_annual_monitoring_report.

will they providethem in therequired timeframe. Additional information is being collected by the Council to aid monitoring in the interim period

prior to the new 1APP planning application form being launched nationally.Supply the plotsunder theCouncil's legalduty


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The requirement to provide plots on strategic sites is supported by Policy GS3 DevelopmentLimits, which sets out a series of criteria whereby development outside of defined DevelopmentLimits will be supported. The Policy also highlights that communities preparing NeighbourhoodPlans will be encouraged to consider the identification of sites specifically for self and custombuild.

Only two sites areover 500dwellings,therefore, policydoes not appear tomeet demand for The suggested amendments to policy wording to support smaller self build plots is not

required, as the first line of the policy already covers this as follows: Proposals for self andcustom build housing, to be occupied as homes by those individuals, will be supported bythe council where they are in conformity with all other relevant local and national policies.

self-build plotswithin the timeframe. Limitedopportunity for selfbuild in other partsof district.

Amend policywording to:

'Support shall alsobe given by theCouncil for smallerserviced plots thatconform with allother relevantlocal and nationalpolicies torecognise thedemand byself-builders forplots with outlineplanningpermission inother locationsthat are not part ofa strategic site of500 dwellings ormore.'

Evidence Base

Noamendment.

The level of demand for custom and self build plots is established by reference to the numberof people on the authority's Self Build Register.

Policyrequirements aresignificant but notunderpinned by The Policy is clear that the provision of plots on strategic sites will be subject to identified

demand at the time of determining any planning application and that regard will be had toviability considerations.

any real evidenceof demand: selfbuild registerindicates limiteddemand.

Policy HS3 has been subject to viability testing via theWhole Plan Viability Assessment workwhich forms part of the evidence base to the Local Plan.

Provision of plotsshould be basedon detailedevidence of needwhich has notbeen producedand subject toviability.

Noamendment

The Council is not reliant solely on windfall sites - it is anticipated that this will form one sourceof the supply of self build plots. It should be noted that a paper on windfall sites has beenprepared as part of the evidence base for the Local Plan. This clearly justifies the expectationthat windfalls will continue to come forward within the District over the plan period and thatas such windfalls form part of the Councils housing supply.

Council cannotrely on windfallsites as they haveno evidence toprove this.


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Implementation on Strategic Sites

Noamendment

The Council intend to address the practical issues around site management through theprovision of planning guidance or SPD, drawing upon examples of good practice from otherareas of the country where self build is successfully being delivered on strategic sites.

A developer willnot want to haveself build plots leftbehind like thegap of a missingtooth. Thereforethe Council willneed to impose afar shorter startingrequirement on aself builder toensure newresidents onsurrounding plotsare not subject toa build periodwhich is over andabove that whichmay reasonablebe expected bythe purchaser of anew house on adevelopingbuilding site.Equally, the samecontrols on dailybuild and deliverytimes for the mainsite will need to beapplied; it wouldbe unreasonablefor existingresidents adjacentthe developing siteas well as newresidents on thesite to experiencematerial supplyand building worksat hours differentto the main site.

Noamendment

See response above relating to practical issues surrounding delivery. It should also benoted that policy HS3 has been subject to viability testing.

Sites of 500+dwellings will bebuilt incomprehensive The amended wording suggested is not considered necessary as the policy already states

the following: In determining the nature and scale of any provision, the council will haveregard to viability considerations and site specific circumstances.

manner byhousebuilders andrequiring self buildplots to bedeliveredalongside mayresult in logisticaland strategicdifficulties, placingunnecessaryburdens ondevelopers andimpacting onhousing delivery.


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Amend policywording to providemore flexibleapproach,encouraging plotson appropriatesites based ondemand present atthat time and innegotiation withapplication.

Design/Implementation

Noamendment.

The reasoned justification (paragraph 5.31) adequately sets out that self build and customplots will be subject to the requirements of other policies, including Policy HS2 (AffordableHousing).

The Council willhave to apply thesame requirementto self build plotsas they do to thesurroundinghouses. So, as foraffordable housingprovision, we willexpect the selfbuild plots to betenure blind and fitin withsurroundingmaterials anddesign. Randomhouse designscannot be allowedto appearscattered througha development.

The Policy needsto make it clearself build houseswill have to meetthe same strictplanningrequirements asthose applied tothe maindevelopment.

Noamendment

The change was made in response to representations raising concerns over the practicalimplications of requiring single/small numbers of plots on small sites. It was acknowledgedthat the practical implications of requiring self build plots on smaller sites, likely to have only

Dramatic changefrom the previousdraft plan. What

one highways access, may impact on site management and delivery. In contrast strategicsites of over 500 dwellings will be delivered by multiple outlets from more than one highwayaccess.

has instigated thechange fromrequiringdevelopers tosupply at least 5%dwelling plots forsale toself-builders onplots of 20+


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dwellings, to plotsof 500+ dwellings?

Noamendment

Noted, although disagree that specific reference is needed. When a neighbourhood plan ismade it will form part of the Development Plan and will be taken into account accordingly.

Where a madeNeighbourhoodPlan is inexistence, toafford localdistinctiveness thesize of site indwellings and theproportion ofdwelling plots tobe made availableshall be thatincluded in therelevantNeighbourhoodPlan. (Ripon CityCouncil)

Add to paragraph“CommunitiespreparingNeighbourhoodPlans ”

"Where a madeNeighbourhoodPlan is inexistence, toafford localdistinctiveness thesize of site indwellings and theproportion ofdwelling plots tobe made availableshall be thatincluded in therelevantNeighbourhoodPlan".

Noamendment

The Council is required to give suitable development permission in respect of enough servicedplots of land to meet the demand for self and custom house-building in the authority’s areaarising in each base period. Draft Policy HS3 puts in place the planning policy framework

Evidence shouldbe provided toensure that this

to aid the Council in meeting its duty, ensuring that demand for plots as evidenced by theprovides anregister can bemet. Additional planning guidance or SPDwill be developed to support policyHS3 and the Council will continue to use the data collected via the self-build register toconsider other ways of supporting and encouraging self and custom building.

additional sourceof housing deliveryto boost supplyand that theCouncil positivelyengages withlandowners andcustom builddevelopers tomaximiseopportunitieswhich come


7Housing



forward on an adhoc and windfallbasis.

Noamendment

Policy requirements within the local plan for residential dwellings built as self or custom buildhomes are the same as those for market and affordable homes. No additional policyrequirements have been included. It is appropriate that proposals for self and Custom buildhousing should be in conformity with all relevant local and national planning policies.

Policy appearsoverly onerousand negative in itsphrasing, inparticular in itsrequirement thatsuchdevelopmentsshould be inconformity with allrelevant local andnational policies.

Policy should beflexible, as anexception togeneral local andnational planningpolicies.

Table 7.4 Key Issues: Policy HS3 Self and Custom Build Housing

HS4: Older People's Specialist Housing



Noamendment.

The Policy would support a range of specialisthousing to meet the needs of older people, which mayinclude Extra Care accommodation. It does not require

In general terms support policy. Unless properlyplanned for likely to be serious shortfall in specialistaccommodation for the older population. Best

the provision of specialist and extra careapproach to meeting diverse needs of older peopleaccommodation as part of general needs housingis to encourage delivery of both specialist forms ofdevelopments, although the reasoned justificationaccommodation and Extra Care accommodation.does indicate that on strategic sites provision may beappropriate as part of providing a wider mix of housingtypes/tenures.

Unlikely to expect provision of specialistaccommodation to be met piecemeal in generalneeds housing developments.

Noamendment.

The reference made by the respondent to the revisedNPPF relates to the expectation that where majordevelopment is proposed at least 10% of the homes

Policy HS4 is not consistent with National Policy asemerging within the Draft NPPF which is a materialconsideration. The Draft NPPF states that major

provided should be made available for affordabledevelopments should make appropriate provision forhome ownership: it does not indicate thataffordable housing unless it would significantlydevelopments providing specialist accommodationprejudice the ability to meet the identified affordable

housing needs of specific groups such as specialisthousing for older people

should be exempt from making a contribution to theprovision of any affordable housing. However, therevised NPPF remains in draft and under theproposed transitional arrangements the examinationof plans submitted on or before six months after thedate of the new NPPF's publication will take noaccount of the new NPPF.

Noamendment.

It is unclear on what basis the respondent considersthe provision of affordable homes to be unjustified.The degree of self-containment of these types of

Requirement to provide affordable housing whendevelopments fall within Use Class C3 is not justifiedand will undermine the delivery of homes for olderpeople. More flexible approach is required to ensurethe delivery of homes for older people.

accommodation varies as does the level of personalcare, which may not be much above the level offeredin general housing in the C3 Use Class. It would not


Housing 7



be equitable to reduce the affordable housingrequirement for those schemes that contribute towardsthe general market housing stock.

Draft Policy HS4 should be amended as follows:

"Developments designed to meet theaccommodation needs of older people will beapproved where it is in a location accessible by public Details of the proposed scheme would need to be

considered alongside any viability arguments on acase by case basis in order to establish the use classand whether the policy should apply.

transport or within walking distance of communityfacilities such as shops or medical services andwhere this is not the case, where appropriate andproportionate provision is made on site."

Noamendment.

Policy HS2 (Affordable Housing) is clear the provisionof affordable housing would be subject to viabilityconsiderations.

Any affordable housing requirement should be inthe context of viability considerations.

Policy should be modified - the affordable housingrequirement should be amended to better reflect theevidence

Noamendment.

The inclusion of a specific policy demonstrates thatthe Council are acting positively to address theprovision of housing for older people.

Requirement of applications to demonstrate needis not justified. The provision of housing for olderpeople should be a key objective of the Local Plan.The plan fails to recognise this need andconsequently it is not positively prepared.

Noamendment.

Policy HS1 requires new development to provide awide mix of homes to meet the range of housingneeds and demands of the District's residents and for

A set proportion (based on sound data) of all theproposed homes in this plan should be designed forolder people to live by themselves. It is vital that older

a proportion of these to be designed to be adaptable:this will cater for all types of housing needs, includinghousing suitable for older people.

people have a desirable place to move to so theycan release large family homes, ideally these wouldbe built together to form small communities.

Table 7.5 Key Issues: Policy HS4 Older People's Specialist Housing

HS5: Space Standards



N/ANoted.Support(including NYCC)

Policy not required

Noamendment.

It is unclear how the respondentconsiders that needs can be metwithout the introduction of housing

Considered that local needs can be met without the introduction ofoptional housing standards.

Standards could be covered by requirements outside of planning e.g.Building Regulations.

standards. The Planning PracticeGuidance is clear that where a LPAwishes to require an internal space

Remove policy from the plan standard, they can do so only bereference in their Local Plan to theNationally Described SpaceStandard (NDSS).

Evidence Base

Noamendment.

The evidence was set out in theHousing Background Paper.

Government have confirmed that the enhanced standards are optionaland would only be needed and viable in certain circumstances. Policyis not in line with Written Ministerial Statement in terms of robust,justifiable evidence to support introduction of standards.

Question validity of the evidence provided which is only based onlimited desktop research. Evidence should be collected over a longerperiod of time, covering a larger number of dwellings.


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None of the evidence base material supporting the current consultationappear to explain and justify why the policy is proposed or the need toapply the space standard within the Plan area.

Should the Council pursue the policy further, a flexible approach isrequired to ensure that other policy considerations are taken on board,and across a multitude of sites and locations a balance of planningpolicy considerations can be applied.

Viability

Noamendment.

The viability modelling undertakenin the WPVS (September 2016)was based on the space standards

The standards can only be introduced through a new Local Plan ifevidence of need has been demonstrated and the impact on viabilityhas been considered.

(Section 8 of the WPVS). TheViability implications of the proposed policy should also be consideredin further detail and within the context of paragraph 173 of the NPPFwhich identified that “the sites and the scale of development identifiedin the plan should not be subject to such a scale of obligations andpolicy burdens that their ability to be developed viably is threatened”

WPVS update (May 2018) hasre-run the appraisals based on thepolicy requirements of thePublication Local Plan andconcluded that the policies of theLocal Plan (cumulatively) areunlikely to prevent developmentfrom coming forward.

Paragraph 5.31 refers to Whole Plan Viability Study (WPVS) lookingat impact of standards and concluding that they are viable. Unable toidentify this in WPVS and therefore consider policy not justified asviability implications are not known. The Costs Impacts associated with

the Housing Standards Review (EC Harris, September 2014) found

Application of this policy will impose higher build costs on new houseswhich will impact on viability and affect supply

that there would be an estimated80% cost recovery, via increasedsales values.

Viability evidence should also be provided taking account of affordablehousing, starter homes housing mix policies, as part of the assessment.

Noamendment.

Comments noted. However, theuse of modular housing does notnecessarily mean creating smallspaces or that the space standardscould not be met.

This policy would stop the creation of using modular housing conceptsfor single household dwellings delivered via a not for profit communityscheme

Noamendment.

It is appropriate to delayimplementation following adoptionof the Local Plan to enabledevelopers to account for this intheir land acquisitions.

NDSS should be implemented immediately to remove doubt. Theguidelines are themselves small and should be considered an extremebaseline rather than a standard size.

Table 7.6 Key Issues: Policy HS5 Space Standards

HS6: Conversion of Rural Buildings for Housing



N/ANoted.Support policy, should help ensure conversion of rural buildingstakes place in manner that will safeguard historic environment andlandscape character. (Historic England)

Noamendment.

Criterion A seeks to ensure thatconversion takes place with minimumintervention and retention of original

The policy as currently worded does not recognise the condition oftraditional farm buildings at the point they becomeredundant. Traditional farm buildings are often not capable of being

fabric and that when convertedput to a modern agricultural use and investment in them is thereforebuildings are not tantamount to a newlimited as a consequence of the lack of financial return which theybuild. As worded it is considered thatprovide. In order that these buildings can be put into a sustainablethe policy strikes a balance betweennew use and the history of these buildings maintained, we believeencouraging the re-use of ruralthat the need for them to be structurally capable of conversion without


Housing 7



reconstruction is prohibitively tight and we believe that the policyshould be amended to reflect the reality of the situation on theground.

buildings and ensuring thearchitectural and historic character oftraditional buildings are notundermined.

Criterion a) should be amended by removing the struck throughwords below:

a) "The building is of permanent and substantialconstruction, structurally sound and capable of conversion withoutthe need for substantial extension or alteration or reconstruction".

Noamendment.

It is not considered that thesuggested amendments would addanything to the policy criteria and are,therefore, unnecessary.

Draft Policy HS6 is worded restrictively.

Criteria within Draft Policy HS6 should be reworded as follows:

Criterion D should be amended to read '...without causingsubstantial harm to the historic environment or significantunacceptable harm to the character of the local landscape orits setting';

Criterion E should be amended to read '...no significant residualimpact (having taken mitigation into account)...'; and

Criterion F should be amended to read '...would not cause anunacceptable harm to valued landscapes or the intrinsic beautyand character pf the countryside by way of...'.

Table 7.7 Key Issues: Policy HS6 Conversion of Rural Buildings for Housing

HS7: Replacement Dwellings in the Countryside

Amendment to the PlanHBC ResponseKey Issue/Suggested Modification

N/AN/ANone identified

Table 7.8 Key Issues: Policy HS7 Replacement Dwellings in the Countryside

HS8: Extensions to Dwellings



No amendment.The Local Plan includes a number of DevelopmentManagement as well as strategic policies. In the contextof the development management issues in the district,the Council considers it appropriate to include this policy.

Policy should be dealt with as a SPDhaving no strategic impact.

Delete the Policy

Table 7.9 Key Issues: Policy HS8 Extensions to Dwellings

HS9: Rural Worker's Dwellings



No amendment.Comments noted. However, it is consideredthat the wording of Policy HS9 adequatelyreflects paragraph 5.56.

Policy should be reworded to support the justificationin 5.56.


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Criteria B should be amended as follows:(text deleted and text added)

"The need relates to a full-time worker, or one who isprimarily employed in rural employment and does notrelate to short/ medium term ortemporary part-time requirement employment"

No amendment.Whilst the Policy could be amended, assuggested by the respondent, the Councilconsiders that paragraph 5.58 adequately

The policy does not include a reference to anappropriate occupancy condition.

addresses this point, making clear that anypermission granted will be subject to anappropriate occupancy condition.

Include a reference to an appropriate occupancycondition.

Table 7.10 Key Issues: Policy HS9 Rural Worker's Dwellings

HS10: Providing for the Needs of Gypsies and Travellers



N/ANoted.Support Policy Criterion C (Historic England)

NoAmendment

National Planning Policy does not state thatsingle-pitch should be avoided and in fact statesin the Planning Policy for Traveller Sites (Aug

Sites should not be single-pitch plots including greenbelt land in current use. Planning responsibility requiresa purpose built site in a locality near to local facilities

2015) that local authorities should 'relate thenumber of pitches or plots to the circumstancesof the specific size and location of the site andthe surrounding population's size and density'

NoAmendment

The methodology used in the GTAA has beensupported by Planning Inspectors in a number ofDecision Notices. The household growth rate

Should not apply a national formula to a specific areawhere compelling evidence is against it. According to theGypsy Council, no additional sites are needed andadditional site provision would only lead to migration fromelsewhere.

used for the assessment of future needs has alsobeen informed by local evidence for each localauthority. This demographic evidence has beenused to adjust the national growth rate up or downbased on local authority specific demographics.

The GTAA advises that HBCmust make provisionfor additional pitches however it is important tonote that because the three existing sites (K40,K41 and K42) only have temporary permission,they constitute this need. If the Local Plan wasnot allocating these existing sites, there would bea need to find additional sites.

NoAmendment

The GTAA is an up to date, robust and credibleevidence base enabling the Council to complywith the relevant Gypsy and Traveller legislation

GTAA should be questioned and a review undertaken

and regulations. Themethodology used has beenadaptive to changes in planning policy as well asthe outcomes of Local Plan Examinations andPlanning Appeals.

NoAmendment

The Gypsy and Traveller AccommodationAssessment (2017) addresses the planningdefinition issue and what actually constitutes

Para 5.61 Disagree that the residents on the threeallocated sites meet the planning definition of Gypsiesand Travellers

travelling. To understand whether the Gypsiesand Travellers in our district meet the planning


Housing 7



definition, the consultants undertook interviewswith the residents of the occupied pitches andconcluded that they met the planning definitionof Gypsies and Travellers.

NoAmendment

National policy states that traveller sites shouldenable gypsies and travellers to be able to accesseducation, health, welfare and employmentinfrastructure and that local Plan policies should"provide a settled base....."

Given HBC's historic and consistent failure to deliver onany of their commitments for Gypsy and Traveller sitesrequirements, these sites offer an easy and convenient'get out clause' for the next five years, and that this is thereason for HBC citing that the Travellers need a 'settledbase to travel from'

NoAmendment

The Gypsy and Traveller AccommodationAssessment (2013) used a number of criteria toidentify broad locations and the subsequent area

Para 5.63 Not clear why Ripon and some of the largertowns have been excluded from the area of search

of search. These criteria take account of nationalpolicy, guidance, the results of the needsassessment and identified policy constraints.Whilst the need figures have been updated in the2017 study, the broad locations conclusions fromthe 2013 study still remain valid.

NoAmendment

The policy is consistent with the provisions ofthe NPPF and the Planning Policy For TravellerSites. With reference to para 152, a Sustainability

Para 5.63 Concern about sustainability of this policy.Not consistent with NPPF para 152.

Appraisal has been carried out and has notidentified significant adverse impacts. It has infact identified positive outcomes.

NoAmendment

Noted. The Gypsy and Traveller BackgroundPaper August 2018 defines why therecommended approach has been taken and why

Para 5.65 Disagree with the exceptional circumstancesoffered in the justification

omission of assessment of publicly owned landthere are exceptional circumstances. Para 17 ofthe Planning Policy for Traveller Sites states thatsmall number of pitches required - 83.3% of the

requirement is within a 2.77sq m area. Norecognition in the plan of any cumulative impact.

local planning authorities can make exceptionallimited alteration to the defined green beltboundary to accommodate a site inset within theGreen Belt to meet a specific, identified need fora Traveller site.

three insets are a trend not 'exceptional insets'

privately owned - further land owned by Gypsiesand Travellers so further risk for unauthoriseddevelopment

misleading to suggest that the pitch requirementscan only be met if the current proposals in theLocal Plan are met

well established sites because failure of HBC toenforce planning law

NoAmendment

Policy GS4 states that "within the sites inset inthe Green Belt and allocated as Gypsy andTraveller sites, only uses appropriate in the Green

Para 5.66 - must be subject to the caveat that oncealternative sites are identified the sites and pitches willbe located elsewhere and the existing land will remainin Green Belt belt will be permitted should the sites no longer

be needed for Gypsy and Traveller purposes".This is sufficient to protect the future use of thesites

NoAmendment

The wording within Paras 5.61, 5.62 and 5.65 isnecessary and provides context and justificationfor Policy HS10. The suggested wording is not

Re-word Paras 5.61, 5.62 and 5.65 of Policy HS10 toread:

appropriate wording for a Local Plan Policy or"To avoid the repetition of past failings and to ensure thatHBC does not in the future find itself in a position in whichexpedient, unsound and legally unsupported action is

justification and would not support the Council'sapproach which is justified in the Gypsy and


7Housing



Traveller Background Paper. Many of the issuesraised in the suggested wording are alreadycovered by the existing policy/supporting text

required, it will work harder to ensure that therequirements of the NPPF and PPTS aremore effectivelyand fully met. Within the plan’s time span the Councilundertakes to fully: wording and the evidence base documents

(Gypsy and Traveller AccommodationAssessment and the Gypsy and TravellerBackground Paper).

Address the current issues by:

1.Applying the ‘new’ (PTTS 2015) definition of Gypsiesand Travellers with immediate effect, to all newapplications – including those from existing residents onsites with lapsed / expired permissions.

2.Conducting a complete search for alternative sites (toK40, K41 and K42), including public (HBC) owned landacross the whole District to be identified and allocatedby 30.3.2019.

3.Retaining in full size and scope, as it exists at 1.3.2018,Knaresborough’s Green Belt including the land currentlyidentified as K40, K41 and K42.

4.Allowing the current traveller sites (at K40, K41 andK42) time limited temporary permission until 30.3.2020at the latest. By which time HBC planners will haveidentified and provided sufficient, adequate other sitesto meet the full 5 year plan GT sites requirement includingproviding alternative sites for sites K40, K41 and K42 onland which is not in Green Belt.

5.Refusing any and all temporary or permanent planningpermissions for Gypsy and Traveller sites in the area tothe south of Knaresborough which includes the 2.77sq.m. areas in and around Calcutt, including sites K40,K41 and K42.

6.Reviewing, in line with national guidance andlegislation, whether the current residents of the sitesqualify as travellers, and thus whether the sites also doso.

Going Forwards:

1.To avoid continued repetition of past failings, HBCplanners will by 30.3.2019 have:

a.conducted a complete search of land across the wholedistrict, by reviewing and adding to the sites assessmentin HBC planners’ Gypsy and Traveller Background Paper(November 2017) and the previous GTSA, a search ofall the land publicly owned by HBC and any other siteswhich subsequently become available.

b.identified and set aside sufficient, adequate sites forthe full five years of the Plan period. This will takeaccount of the fair distribution of Gypsy and Travellersites across the whole district with the exception of landto the south of Knaresborough which will be excludeddue to the existing disproportionately large number ofsites.

c.ensured that all (existing and proposed) GT sites arecommensurate with the nearest settled community – bothindividually and cumulatively, in the short, medium andlong terms - fully in line with NPPF and other legislation


Housing 7



and to include this element in all future planning. Havingfirst made public the numerical / objective base for thecalculation of what qualifies as ‘commensurate with thenearest settled population’ which HBC works from.Allowing the public to hold the Council to account.

d.engaged the nearest settled community in early, open,meaningful and fair discussion in line with NPPFrequirements of all current and proposed Gypsy andTraveller sites, and avoid limiting engagement only toLocal Plan consultation. The methods of engagementwill be timely and take into account the fact that noteveryone has access online or regularly readsnewspapers.

e.published progress reports on the achievement of allthe criteria included in this statement on the Councilwebsite at quarterly intervals and by 30.6.18, 30.9.18,31.12.18, 31.3.19, 30.6.19, 30.9.19, 31.12.19 and30.3.2020, in addition to supplying the same informationto interested parties, including the Knaresborough andCalcutt Green Belt Protection Action Group.

Ensure that planning enforcement is conducted effectivelyby:

a.making publicly available HBCs revised and detailedplanning enforcement policy to which members of thepublic can refer and which allows any future failings inenforcement to be identified and the Council held toaccount.

b.enforcing planning law in line with the policy fairly,equitably and consistently across the whole population– no matter whom the people are who are suspected tohave infringed it and so will include for example peoplewho are; settled or non-settled, regardless of race,wealth, political affiliation, where they live, the risk ofbeing threatened, or any other circumstances.

c.ensuring that unlawful settlement of land is not, at alater time, rewarded by being granted planningpermission.

d.avoiding unauthorised settlements, in green belt orotherwise and respond quickly and effectively to resolveany issues as per the formal enforcement policy

NoAmendment

Not withstanding the point that the sites areinitially unauthorised the sites are now beenallocated formally in the Local Plan and all have

Consistent failure by HBC to provide sites with 100% ofnew sites coming about not through the planning systembut unlawfully through unauthorised settlement.

temporary planning permission. As stated inPlanning Policy for Traveller Sites, it isappropoaite to identify land in the Green Belt tomeet a specific need but is should only be donethrough the plan-making process.

NoAmendment

Planning Policy for Traveller Sites states that thescale of sites in rural or semi-rural settings shouldnot dominate the nearest settled community. The

Lack of communication or engagement with the localsettled community - no evidence that the interests of thelocal settled community have been considered

proposed allocations which already havetemporary permissions allocated are very smallscale and meet the requirement of the policy.


7Housing



Consultation on the allocation of these sites hasbeen undertaken at Additional Sites stage andPublication Draft stage.

NoAmendment

The Gypsy and Traveller Background Paperprovides the assessment for the existing sites andall alternative sites and includes consideration asto whether the size of the site is commensurateto the nearest settled community.

No evidence that sites individually, cumulatively havebeen related to the nearest settled population to the threesites

NoAmendment

The allocation of existing sites within the LocalPlan means that permanent planning permissionshould be sought which would include a number

No attempt has been made to reduce the tensionsbetween the settled and traveller communities.

of conditions that have to be complied with. Thenon-allocation of Gypsy and Traveller sites withinthe Local Plan will continue the current problemof unauthorised sites as well as tension with thesettled community. It will also restrict the council'sability to enforce against unauthoriseddevelopment as our ability to enforce is relatedto our productivity in meeting the need for newprovision.

Table 7.11 Key Issues: Policy HS10 Providing for the Needs of Gypsies and Travellers

Gypsy and Traveller Allocations

K40: Green Acres, Cass Lane, Knaresborough



NoAmendment

NotedSupport the site

NoAmendment

The site is in Green Belt and whilst the Planning Policy forTraveller Sites states that local planning authorities can makeexceptional limited alteration to the defined green belt boundaryto accommodate a site inset within the Green Belt, to meet aspecific, identified need for a Traveller site.

The Site is in Green Belt

Negative impact on local roads/traffic

No or poor access to shops andservices

This site has been subject to a sustainability appraisal and nosignificant adverse impacts have been identified.

No or poor access to public transport

Other

NoAmendment

The Gypsy and Traveller Background Paper August 2018 defineswhy the recommended approach has been taken and why thereare exceptional circumstances. Para 17 of the Planning Policy

No exceptional circumstances forremoving site from the Green Belt asthere is a viable alternative at Pannal

for Traveller Sites states that local planning authorities can makeexceptional limited alteration to the defined green belt boundarySite should not be removed from the

Green Belt to accommodate a site inset within the Green Belt to meet aspecific, identified need for a Traveller site. Due to thecircumstances of the three current sites in Knaresborough, the

Not treating adjacent residents fairlyand equally by taking sites out of GreenBelt

lack of a deliverable site(s) and the small number of pitchesrequired, the three existing Gypsy and Traveller sites can betaken out of the Green Belt and allocated.

The Draft Allocations at Pannal was consulted on, howeverfollowing further engagement with the Gypsy community, theupdated Gypsy and Traveller Accommodation Assessment, the


Housing 7



number of vacant pitches on the existing sites and the need forthe site to help meet the objectively assessed housing need, itwas necessary to consider allocating another site/s.

NoAmendment

The Gypsy and Traveller Accommodation Assessment (2017)addresses the planning definition issue and what actuallyconstitutes travelling. To understand whether the Gypsies and

Disagree that the residents of the sitemeet the planning definition of Gypsiesand Travellers

Travellers in our district meet the planning definition, theconsultants undertook interviews with the residents of theoccupied pitches and concluded that they met the planningdefinition of Gypsies and Travellers.

NoAmendment

Site has benefit of temporary planning permission. Followingallocation, permanent permission would need to be applied for.

Residents are being rewarded forunauthorised occupation of the site

NoAmendment


Impact on public right of way


Table 7.12 Key Issues : K40, Green Acres, Cass Lane

K41: The Paddocks, Cass Lane, Knaresborough



NoAmendment


NoAmendment




No or poor access to shops andservices



Other

NoAmendment

The Gypsy and Traveller Background Paper August 2018 defineswhy the recommended approach has been taken and why thereare exceptional circumstances. Para 17 of the Planning Policy

No exceptional circumstances forremoving site from the Green Belt asthere is a viable alternative at Pannal

for Traveller Sites states that local planning authorities can makeexceptional limited alteration to the defined green belt boundarySite should not be removed from the

Green Belt to accommodate a site inset within the Green Belt to meet aspecific, identified need for a Traveller site. Due to thecircumstances of the three current sites in Knaresborough, the

Not treating adjacent residents fairlyand equally by taking sites out of GreenBelt

lack of a deliverable site(s) and the small number ofr pitchesrequired, the three existing Gypsy and Traveller sites can betaken out of the Green Belt and allocated.

The Draft Allocations at Pannal was consulted on, howeverfollowing further engagement with the Gypsy community, theupdated Gypsy and Traveller Accommodation Assessment, the


7Housing



number of vacant pitches on the existing sites and the need forthe site to help meet the objectively assessed housing need, itwas necessary to consider allocating another site/s.

NoAmendment

The Gypsy and Traveller Accommodation Assessment (2017)addresses the planning definition issue and what actuallyconstitutes travelling. To understand whether the Gypsies and

Disagree that the residents of the sitemeet the planning definition of Gypsiesand Travellers

Travellers in our district meet the planning definition, theconsultants undertook interviews with the residents of theoccupied pitches and concluded that they met the planningdefinition of Gypsies and Travellers.

NoAmendment

Site has benefit of temporary planning permission. Followingallocation, permanent permission would need to be applied for.


NoAmendment


Impact on public right of way


Table 7.13 Key Issues : K41, The Paddocks, Cass Lane

K42: Thistle Hill Stables, Knaresborough



NoAmendment


NoAmendment

The site is in Green Belt and whilst the Planning Policy forTraveller Sites states that local planning authorities can makeexceptional limited alteration to the defined green beltboundary to accommodate a site inset within the Green Belt,to meet a specific, identified need for a Traveller site.



No or poor access to shops and services

No or poor access to public transportThis site has been subject to a sustainability appraisal and nosignificant adverse impacts have been identified.

Other

NoAmendment

The Gypsy and Traveller Background Paper August2018 defines why the recommended approach has been takenand why there are exceptional circumstances. Para 17 of the

No exceptional circumstances for removingsite from the Green Belt as there is a viablealternative at Pannal

Planning Policy for Traveller Sites states that local planningauthorities can make exceptional limited alteration to theSite should not be removed from the Green

Belt defined green belt boundary to accommodate a site insetwithin the Green Belt to meet a specific, identified need for aTraveller site. Due to the circumstances of the three current

Not treating adjacent residents fairly andequally by taking sites out of Green Belt

sites in Knaresborough, the lack of a deliverable site(s) andthe small number ofr pitches required, the three existing Gypsyand Traveller sites can be taken out of the Green Belt andallocated.

The Draft Allocations at Pannal was consulted on, howeverfollowing further engagement with the Gypsy community, theupdated Gypsy and Traveller Accommodation Assessment,


Housing 7



the number of vacant pitches on the existing sites and theneed for the site to help meet the objectively assessed housingneed, it was necessary to consider allocating another site/s.

NoAmendment

The Gypsy and Traveller Accommodation Assessment (2017)addresses the planning definition issue and what actuallyconstitutes travelling. To understand whether the Gypsies

Disagree that the residents of the site meetthe planning definition of Gypsies andTravellers

and Travellers in our district meet the planning definition, theconsultants undertook interviews with the residents of theoccupied pitches and concluded that they met the planningdefinition of Gypsies and Travellers.

NoAmendment

Site has benefit of temporary planning permission. Followingallocation, permanent permission would need to be appliedfor.


Table 7.14 Key Issues: K42, Thistle Hill Stables


7Housing

8 Transport and Infrastructure

TI1: Sustainable Transport



N/ANotedSupport the policy

N/ANotedSupport the policy (North Yorkshire LEP)an appropriate response to LEP economic andtransport strategy and objectives.

This LEP will work with HBC, NYCC and partners toimprove east-west connectivity through the LocalPlan area, focused on improvements to the A59 andthe York-Harrogate-Leeds railway line (includingHarrogate Station), plus measures to reducecongestion in Harrogate and Knaresborough.

Noamendment.

Disagree. It is not considered necessary toinclude a policy or allocation in the Local Planas the matter is covered within national policy.

Failure to identify provision of roadside facilities formotorists, including Motorway Service Areas (MSAs)contrary to NPPF paragraph 31 there are no full MSA's

Any proposal received will be considered onnorth of Wetherby Services until Durham MSA, a distanceits merits and subject to other provisions of theof over 60 miles. In accordance with the provision of DfTPlan such as impact on landscape characterand the natural environment, designated andnon-designated heritage assets and amenity.

Circular 01/13, there is a proven need for a new motorwayservice area on the A1(M) north of Wetherby Services. Planis not justified as it does not promote the most appropriatestrategy for the district.

Policy TI1 should be amended to include reference to thedelivery of a new MSA serving the A1 (M).

Noamendment.

Para 6.4. outlines four proposals from NYCCLocal Transport Plan which are of relevanceto Harrogate. Development of the Plan and thesite selection process has taken account oftransport issues and infrastructure delivery.

Para 6.4 - four areas highlighted do not link the major areasof housing development. It is not clearly linked to thetransport issues that exist already in addition to the onesthat will be created through the additional housing stock.

Noamendment.

Disgaree. Infrastructure, including transportand highways provision, to support the plannedlevel of growth and specific site allocations is

Consideration of significant investment in road networkappears to be lacking as nomajor improvements to supportprojected growth have been set out in Local Plan.

set out in the Infrastructure Delivery Plan andwill be delivered through the implementationof policy TI4.

Noamendment.

Noted, although it is considered that the policyas worded is consistent with NPPF.

Consider policy requirements to be reasonable but shouldhave regard to NPPF para 32. Developments should notbe over-burdened by policy requirements if would result inless than severe impacts.

Noamendment.

Disagree. The council considers that policyTI1 outlines an appropriate strategy to promotemore sustainable patterns of travel and balancethe transport system in favour of sustainabletransport modes.

Transport section is weak . If HBC is to meet its own carbonemissions targets more proactive policies necessary. Planshould include a commitment to produce a strategicsustainable transport plan will be developed in conjunctionwith NYCC to ensure that there are viable choices for themajority of journeys and to discourage unnecessary vehicleuse.

Noamendment.

North Yorkshire County Council, working inpartnership with Harrogate Borough Council,has commissioned a traffic model for

HBC should be in favour of at least consultation on thepossiblity of an inner relief road and preferably offeringsupport to NYCC's efforts.

Harrogate, Knaresborough and Ripon. This is


Transport and Infrastructure 8



being used jointly by both authorities to testlocal plan development options and potentialrelief road corridors.

Noamendment.

It is not the role of the Local Plan to stipulatea service level provision as this is a function ofmarket demand and/or policies of North

HBC/NYCC should have policy in place to provide publictransport service to smaller communities, particularly wheregrowth is proposed, particularly affordable homes.

Yorkshire County Council. However, the LocalPlan can set out the need for newPlan needs to include more detail on how it is intended to

resolve main issues restricting growth and for listed keyinfrastructure projects (paragraph 6.4) need for at least atimetable for implementation.

developments to deliver new public transportor contribute to existing public transportservices. The Infrstructure Delivery Planprovides more information on key infrastructureprojects.

Noamendment.

The policy sets out the mechanisms throughwhich the council will seek to deliver transportimprovements and more sustainable travel

The plan makes no attempt to quantify infrastructure issuesin detail. The Council has ambitions to encourage walkingand cycling commuting. Given the topography of west

patterns. The infrastructure, including transportHarrogate I do not consider this ambition to be achievablein any meaningful sense, particularly in the months ofOctober to March.

and highways provision, to support the plannedlevel of growth and specific site allocations isset out in the Infrastructure Delivery Plan andwill be implemented through the operation ofpolicy TI4.

Noamendment.

Where a village lies on a relatively major road,the highway network is covered by thetransport model. Not withstanding this, most

No evidence of potential impact of the increased trafficcaused by cumulative development in rural villages and onthe wider Nidderdale AONB. The Harrogate District

of the impact in villages of development isTransport Model reports from 2016 and 2018 focus on therelatively localised and development proposalswill have to be accompanied by a full transportassessment

developments within the local towns but do not considerthe local impact of housing allocations in rural areas suchas the Summerbridge and Dacre Banks area, which aresmaller in scale but where the magnitude of change couldbe more significant.

Noamendment.

Disagree. The council has carried out trafficmodelling work that indicates that withmitigation the level of new development beingproposed can be accommodated.

Size of proposed housing development will produce a levelof increased traffic that cannot be catered for by the minimalimprovements to the roads.

Noamendment.

Disagree. The council has worked, and willcontinue to work, closely with North YorkshireCounty Council and transport providers on the

Plan says the Council will work with NYCC to reducecongestion – but there’s nothing of substance to show howthat is to happen.

delivery of transport and other infrastructurerequirements to support the planned level andlocation of growth.

Noamendment.

The impact of development on level crossingsand any appropriate mitigation measures willbe addressed through Transport Assessments.

We consider improvements are needed to StarbeckCrossing to ease congestion and reduce harmful airpollution. Options include a road bridge or underpass.Consideration should also be given to the construction ofa platform on the York side of the crossing so thatYork-bound trains could halt there without the need for thecrossing gates to close (Starbeck Residents Association).

Noamendment.

A separate paper addressing transport issueswill accompany the Submission Plan but thecouncil has carried out traffic modelling work

Strategic Transport Priorities Study and SustainableTransport Supplementary Planning Document should beprepared and consulted on before development landallocations are agreed. that indicates that with mitigation the level of

new development being proposed can beaccommodated.

Noamendment.

Disagree. The council considers that policyTI1 outlines an appropriate strategy to promotemore sustainable patterns of travel and balance

No evidence that NPPF requirement for the transport systemto be balanced in favour of sustainable transport modes isbeing followed. Many of the proposed developments are





remote from the railway, poorly served by public transportwhich is likely to continue. No serious attempt to minimisethe additional traffic which will result as main focus to deal

the transport system in favour of sustainabletransport modes. The site selection processhas had regard to the ability to access essentialservices by non-car modes and/or the potentialto improve this.

with this appears to be to improve key junctions atconsiderable cost to enable more - though only marginallymore - traffic to get through.

Development to west of Harrogate

Noamendment.

The site requirements for H49 and related sitesto the west of Harrogate include the need fora transport assessment and travel plan, as well

Development to west of Harrogate should be matched withinvestment in sustainable transport to support thedevelopment with new infrastructure built ahead of theresidential development. as a requirement for the related sites to work

together to address transport and infrastructureissues. No

amendment.The planned development to the west of Harrogate willresult in increased usage of Weeton Station. Demand forparking at the station is already well in excess of the parking Master planning of H49, through the provision

of a concept diagram prepared in accordancewith these requirements, will be produced atthe Submission stage.

capacity creating issues on Weeton Lane. Ideally, thereshould be provision of a Park and Ride facility somewhereclose to Pannal Station or near the A61/A658 junction orsignificant extra parking facilities provided at WeetonStation.

Noamendment.

Western bypass should be built as road through NorthRigton is very narrow and cannot cope with the presenttraffic let alone additional traffic that would be caused byfurther development to the west of Harrogate.

Ripon

Noamendment.

Draft Policy T1 states that the Council will workin partnership with other authorities, transportproviders and local groups to promote a

Policy should recognise that Ripon is significantly lesswell-connected than the other Main Settlements andacknowledge need for significant transport infrastructureinvestment to accompany new development, which isaddressed in the Ripon City Plan.

sustainable and improved transport systemand specifically includes the aim to reducecongestion in Ripon. Detailed travel plans willbe required as part of the masterplanning forallocated sites in Ripon.

Noamendment.

Congestion in Ripon needs to be tackled:

Harrogate to Ripon bus has reduced in frequency

No significant bus service to Knaresborough or York

No train service or investigation of reinstatement ofthe railway

No plans for increased parking

No plans for improving cycling to the city orpedestrianization of the market area

An integrated Transport Strategy is needed for Riponcovering future growth, walking, cycling, mobility, busservices, park and ride, public realm and reducing trafficin Cathedral precinct and Spa Quarter.

Table 8.1 Key Issues : Policy TI1 Sustainable Transport



TI2: Protection of Transport Sites and Routes



Noamendment.

It is not considered necessary to include a policyin the Local Plan as the matter is covered withinnational policy. Any proposal received will be

Failure to identify provision of roadside facilities formotorists, including Motorway Service Areas (MSAs)contrary to NPPF paragraph 31 and there is a provenneed for a new motorway service area north ofWetherby Services

considered on its merits and subject to otherprovisions of the Plan such as impact onlandscape character and the natural environment,designated and non-designated heritage assetsand amenity.

Reference should be made to the provision of roadsidefacilities, including MSAs.

Noamendment.

Disagree. The council considers that new sitesand routes which have the potential to contributetowards the provision of a sustainable andimproved transport system should besafeguarded.

Policy should take account of mitigating factorsincluding that larger schemes may present alternativeoptions to deliver necessary improved infrastructure.

Provide more flexibility in policy wording to permitdevelopments that may impact on existing or proposedtransport infrastructure in certain circumstances.

Noamendment.

The route indicated follows the route of the formerrailway line.

The protected route shown on the Lofthouse policymap should probably remain on the NYCC highwayand not going down through the "village play field".

Noamendment.

Disagree and in any case NPPF identifies theneed to balance the transport system ‘in favourof sustainable transport modes, giving people areal choice about how they travel.’ (Para29).

It is naive that the council can claim that people willwalk and cycle along former railway line routes to fulfilpart of their transport requirements. There is not theclimate or topology for it.

Table 8.2 Key Issues : Policy TI2 Protection of Transport Sites and Routes

TI3: Parking Provision



N/ANotedSupport

No amendment.It is considered that the policy allows sufficientflexibility to be effective in both urban and ruralareas.

The needs of residents in rural settlements need tobe considered separately to those in urban areas.

No amendment.While Harrogate Borough Council is responsiblefor off street car parks under the council’s control,NYCC is responsible for on-street parking

All properties should have parking for 2 vehicles -for both electric car charging and adaptability forwheelchair use.

throughout the district. The North YorkshireNo amendment.Parking standards should allow for the larger cars

in use.County Council Parking Strategy (2011) relatesto all aspects of parking under the control of thecounty council.

No amendment.Policy T1 promotes improvements to publictransport, including the provision of better parkingat rail stations and park and ride facilities.

Reducing the available car parking and to restrictdemand through pricing is an unsound strategy giventhe lack of quick, comfortable and reliable publictransport. It is disappointing to see that there are noplans to introduce park and ride schemes.

No amendment.The Plan seeks to encourage the provision ofcharging points for vehicles and the generic siterequirements in Policy DM1 stipulate that the

For fast charging of electric vehicles (full charge in5 hours) a 32 amp connection is required (above the16 amp Building Regulation requirement).

charging points should conform to a minimum ofa ‘Mode 3’ standard, with a minimum 16amprating.

Electric vehicle charging points should be requiredfor ALL new development.





No amendment.Noted. However it should be noted that althoughno park and ride / park and rail sites are allocatedin the Plan, such proposals would be supportedwhere the criteria of Policy TI3 were met (para6.24).

The opportunity for Park and Rail should beaddressed, especially regarding the alternative NewSettlement sites.

Park and ride and park and rail should be includedwithin the Local Plan.

Table 8.3 Key Issues : Policy TI3 Parking Provision

TI4: Delivery of New Infrastructure



Noamendment.

Disagree. The council considers that this policy isconsistent with NPPF.

To ensure obligations are only sought where canbe fully justified, policy should refer to wording ofNPPF para 204.

Amend policy to refer to wording of NPPF para204.

Noamendment.

It is considered that the policy provides anappropriate framework for infrastructure provisionincluding waste water. The matter is furtheraddressed within the generic site requirementsoutlined in Policy DM1 (Criteria number 11).

Pumping and treating wastewater can be costlyin energy terms. It can't be treated in isolation ofthe local plan process as decisions need to betaken early to determine site viability. I believe thatsignificant problems with waste water managementhave not been taken account of.

Noamendment.

Major infrastructure requirements are detailed in theInfrastructure Delivery Plan.

Water provision is dependent upon major worksin central Harrogate however no costing has beenundertaken for any such work.

Noamendment.

Disagree. Policy TI1 sets out the mechanismsthrough which the council will seek to deliver transportimprovements and more sustainable travel patterns.

Lack of commitment to rail improvements and lackof provision of road improvements

The infrastructure, including transport and highwaysprovision, to support the planned level of growth andspecific site allocations is set out in the InfrastructureDelivery Plan and will be implemented through theoperation of policy TI4.

Noamendment.

The council is progressing CIL and has published aPreliminary Draft Charging Schedule for consultationbetween 25 May to 4.30pm on 6 July 2018.

Policy TI4 does not include proposals for CILwhich has implications for delivery of infrastructurein Ripon City Plan. (Ripon City Council)

CIL should be put in place (Ripon City Council).

Table 8.4 Key Issues : Policy TI4 Delivery of New Infrstructure

TI5: Telecommunications



NoAmendment.

NotedHistoric England support criteria B and C.

NoAmendment.

The NPPF states that Local Plansshould support the expansion ofelectronic communications networks

Developments that do not make good provision suffer. Having apolicy specifically for broadband provision is out of place when thehousing industry is reliant on third party service suppliers. If the





connectivity exists house developers will use it. No need thereforefor the section of the policy entitled 'Broadband access in newdevelopments'

including telecommunications and highspeed broadband and therefore it isappropriate to have a policy in theLocal Plan.

Delete Criteria D, E and F

NoAmendment.

Disagree. It is considered that thepolicy wording provides an appropriatebalance between supporting the

One of the constraints against development of many of the ruralparts of the District relate to the lack of telecommunication andbroadband infrastructure. The establishment of high speed

development of telecommunicationsand broadband infrastructure andother planning considerations.

communication links in rural areas will facilitate better employmentopportunities, improving the wage level across the District howeverthe proposed policy is not sufficiently proactive and in part, couldrepresent an impediment against an otherwise acceptabledevelopment.

The underlined wording should be added to Policy TI5 as follows:

"b) Supporting the provision of new communications infrastructurewhere it can be demonstrated that using existing infrastructure orequipment would not be feasible and provided the proposal doesnot have a significant permanent adverse impact on the characteror appearance of the surrounding area. Where apparatus orassociated infrastructure is proposed to be located on a building,the proposal will be supported provided the siting, scale and designof the apparatus or associated infrastructure does not have asignificant permanent adverse impact on the external appearanceof the building.

c) Ensuring the location and design of proposalsavoid permanent harm to sensitive areas or buildings/structures andaccord with local plan policies HP2, NE3 and NE4.

e) All new development will be required to enable fibre to thepremises where viable. Where it cannot be demonstrated that theprovision of fibre to the premises is viable, proposals should providea minimum download connection of 24mbps or, where this is notcurrently available, the maximum speed which is economically viableand incorporate suitable infrastructure to support delivery of fibre tothe premises at a future date".

Noamendments

The Council has recently launched its'2024 programme' which includes anelement entitled 'Digital Harrogate'

The Council should bring forward a strategy to positively encourageand assist in the financial delivery of telecommunication andbroadband access to rural areas. In addition, we believe that areasonable time frame ought to be set out for the achievement ofthis aim and would suggest that 3 years from adoption is suitable.

which is looking to harness theopportunities in digital technology.Policy TI5 is a positive policy in itselfthat encourages the delivery oftelecommunications. Financialassistance is available in the form ofGovernment grants.

SeeProposedModificationsSchedule foramendmentsto the policy

It is agreed that that the policy needsto be updated to include reference tomobile telecommunications. Thispolicy is also being amended toupdate it in line with new digitalrequirements.

The connection of fibre to premises represents the best long termprovision however the roll out of this infrastructure is a medium tolong term aspiration. The use of mobile broadband provision couldbe rolled out more quickly and therefore the policy should morepositively support this as an interim measure.

Noamendment.

The policy provides flexibility for thosedevelopments where provision of NextGeneration Access broadbandconnection is not viable.

As inclusion of digital infrastructure is not within direct control ofdevelopment industry could create deliverability issues fordevelopment and developers. Paras 43 to 46 of NPPF does notseek to prevent development that does not have access to such





networks. Council should work proactively with telecommunicationsproviders to extend provision and not rely on development industryto provide such infrastructure.

Criteria D and E should be deleted

Noamendment

The wording within the justification isadequate

Unclear what evidence would be required to demonstrate compliancewith policy or who would be responsible for assessing proposals.Ability to achieve broadband speeds can be result of several factors,which a developer may have little influence over.

Noamendment

Whilst it would be beneficial to ensurethat all existing development hadequal telecommunications access, this

Whilst this section does cover current and new developments, thereis a lack of leveraging new developments to ensure that local existingdevelopments benefit from those new developments. I.e. when a

is not something that the developersnew development is implemented with telecommunications accesscould be expected to pay for orprovide under the PlanningObligationsregulations.

that is superior to the local existing developments - there needs tobe a complementary activity of the new development helping to bringbetter telecommunications access to the existing developments.

New developments should not only be delivered with these hightelecommunications capabilities, but ensure that the local existingdevelopments have at least equal access to that hightelecommunications capability as part of the new developmentimplementation.

Table 8.5 Key Issues : Policy TI5 Telecommunications

TI6: Provision of Educational Facilities



N/ANotedSupport

No amendmentThe allocations for new school or extended provision arein sustainable locations. The impact on the road networkand the availability of public transport would be a material

The plan makes very little attempt to locatenew schools to minimize commutingcongestion.

consideration for the determination of any new schoolapplication. The objectives of the Local Plan as a wholeinclude the promotion of sustainable patterns ofdevelopment and reducing the impacts of transport on theenvironment and communities.

No amendmentThe landowner has confirmed that the site is deliverableNS7 is not deliverable unless sites NS2,NS4 and NS5 are also developed.

No amendmantPN20 was assessed as part of the wider PN19 and issuitable for development. NYCC have identified a needfor additional educational land in Pannal and this site is the

Land at PN20 not suitable for building (riskof flooding) and would be better used asallotments.

most sustainable option for this purpose. The Council iscurrently in discussion with Pannla dn Burn bridge ParishCouncil regarding the provision of allotments within thevillage.

No amendmentThe BT site contains private, commercial training facilitiesand therefore its loss does not need to be compensatedfor.

Further education facilities should beincluded within the plan to cater for growth- The BT site at St Georges road containshigh quality education facilities as is to bedemolished to make way for 88 houses.





No amendmentLand for education is to be provided as part of thecommitment on H46. It is to be secured through an agreedSection 106 agreement so it is not necessary to reflect itin Policy TI6.

Land for education facilities to be providedwithin housing commitments H45 and H46should be secured and safeguardedthrough policy TI6.

Delete K20 fromTI6 and thePolicies Map

Agree. The site has planning permission for housing andis no longer deliverable. NYCC Education have confirmedthat now extended school can accommodate the need sothere is no need for an alternative site to be allocated.

Amend Policy TI6 to remove draftallocation KL20

No amendmentThe masterplanning of PN19 and PN20 will be undertakentogether and will include access. PN20 will make adequateprovision for identified need.

In addition to PN20, provision ofeducational facilities and improved accessshould be incorporated in masterplan fordevelopment of PN19.

Table 8.6 Key Issues : Policy TI6 Provision of Educational Facilities

Educational Facilities Allocations

B22: Educational facilities for Boroughbridge High School



N/ANotedSupport allocation to provide for extension of High School.

Para 6.50 of Policy TI6to be amended tomakereference to B22 beingfor playing fields only.

NYCC have confirmed that therewill be no school development onthis site as the expected expansionrequirement can be achieved on the

Historic England comment that the site likely to containsignificant amount of archaeological remains with highprobability that many of these remains will be of nationalimportance. Before allocating site there is need for

existing site. B22 will solely beused to re-provide playing field lostthrough the development.

evaluation of impact loss of site and future developmentmight have upon elements which contribute to significanceof heritage assets in the vicinity. If harm would result, Planneeds to clearly set out measures by which harm might beremoved or reduced. If despite mitigation measures stilllikely to be harm, site should not be allocated. Educationalfacilities could take palce on northern part of site B4.

Table 8.7 Key Issues : B22 Educational facilities for Boroughbridge High School

KL20: Educational facilities for Killinghall Primary School


Delete the K20 allocationfrom Policy TI6 andremove the notation fromthe Policies Map

The site now has planingpermission for housing sois no longer available foreducation use.

Draft allocation was added to Local Plan without discussion withlandowner. Not received any requests from NYCC about availabilityof land for education use, only sought financial contribution inresponse to current planning application. Planning applicationsought to respond to issues at school through provision of car parkto help alleviate parking concerns. No further educational use wouldbe offered.

May be requirement for further school capacity but there is landadjacent to school which would be more appropriate. Allocation isnot deliverable as would not be offered by landowner for educationuse.

Remove draft allocation KL20 from Local Plan

Table 8.8 Key Issues : KL20 Educational facilities for Killinghall Primary School



NS7: Educational facilities at North Stainley



N/ANotedSupport

No amendmentNYCC highways have now been consulted.It should be noted that they did not raise anyconcerns regarding access from the much

The Local Plan has failed to take due account of roadsafety and traffic issues in relation to the siting of thiseducational facility. Safe access to and egress from the

larger allocated site NS3 onto the A61 justsite cannot be created either from the main road throughto the north of NS7. Detailed highwayrequirements can be dealt with at planningapplication stage.

the village (A6108) or from the residential road nearest tothe site (Watermill Lane). The Borough Council did notconsult with the Highways Authority before allocating thissite for educational facilities and, until this has be done, thePlan cannot be considered sound.

Table 8.9 Key Issues : NS7 Educational facilities at North Stainley

PN20: Educational facilities for Pannal Primary School

8.1 Many of the issues raised regarding this site were submitted as part of general objectionsto the housing and employment allocations (PN17, PN18 and PN19) hence why they arenot directly relevant to the development of PN20 for a school.



N/ANotedSupport (Pannal County primary School)

Noamendment

NYCC Education haveidentified a need for 8additional classrooms at

Legal compliance

Issues with evidence basePannal County Primary

The site is too big School and the existingsite is unable toCoalescence accommodate this level

A large amount of development has already been granted in the local area of expansion. There istherefore an identified

The site is outside the current development limit need for a site toaccommodate this

Previous applications to develop the site have been refused. expansion and PN20being adjacent to the

Local infrastructure cannot cope. current school providesthe opportunity for this.

Local schools are full. The site is owned byHBC and is thereforeNegative impact on local roads/traffic deliverable. The school

No or poor access to public transport. is supportive of theproposed allocation. The

No or poor access to shops and services site was assessed in theSustainability Appraisal

Risk of flooding as part of the widerPN19 and is considered

Negative impact on the landscape to offer the greatestsustainability benefits

The site is in a designated special landscape area (SLA) and considerations suchas the scale ofThe site is a greenfield sitedevelopment, access,

The site is the Green Belt. and impacts onhighways landscape,

Loss of public open space/sports pitches. ecology, heritage assetsand flooding were taken

Negative impact on the local community into account during thesite assessmentprocess.Negative impact on local wildlife and biodiversity





Negative impact on the conservation area Potential adverseimpacts of developmentof the site wereIssue with consultationconsidered through the

Other: site assessmentGrowth should be at school's initiative not the council's process.Where potential

adverse impacts wereLoss of site identified for new allotments identified, it is

considered that theseare not insurmountableOther available sites in Pannal that are more sustainableand could potentially bemitigated. Furtherassessment of theseissues will beundertaken as part of theplanning applicationprocess if required atthis stage.

It is recognised that newdevelopment, bothindividual sites and fromthe cumulative impact ofseveral sites, will placeextra pressure onexisting infrastructureand may need new orimproved infrastructureto support it. The councilcontinues to work withthe County Council,utility and otherinfrastructure/serviceproviders to make surethe infrastructureimplications of theallocated sites are fullyassessed and wherenecessary mitigationmeasures are identifiedand put in place toaddress developmentimpacts. Fundingcontributions fromdevelopers will besought where needed toincrease capacity toprovide localinfrastructure.

It should be noted thatthis site is not in theGreen Belt.

Table 8.10 Key Issues : PN20 Educational facilities for Pannal Primary School



9 Climate Change



No amendment.The Key Facts section was updated as a resultof representations to the Draft Local Plan andAdditional Sites Consultation 2017. It is felt thatthis paints an appropriate picture of the policycontext and drivers.

Further research needed to ascertain why our CO2emissions and energy usage are significantly abovenational and most regional levels. Policy should thenfollow this evidence.

Key Facts need to include data from the most recentGovernment Scientific projections on climate change.

Table 9.1 Key Issues : Climate Change

CC1: Flood Risk and Sustainable Development


HBC ResponseKey Issue / Suggested Modification

Noamendment.

This policy follows the guidance in theNPPF. However, the policy builds on thisand reflects the more detailed flood risk

Question need for policy as it reiterates approach within NPPF.

Delete policy.information in the Harrogate DistrictStrategic Flood Risk Assessment (2016) andsubsequent Addendum (2017).

Noamendment.

The policy is concerned with flood risk fromall sources. In line with national policy, itrequires site-specific flood risk assessmentsto show how flood risk from all sources willbe dealt with.

Policy fails to address local circumstances (use of combinedsewerage and surface water systems). It lacks necessarydetail to be effective, only addressing issue of surface waterrun-off and not that combined drainage system also carriesfoul water. Further work needs to be undertaken to understandextent of problem and identify necessary solutions and for thisto be reflected in the policies.

Noamendment.

The potential site yields outlined in the Planare calculated using a methodology whichrecognises that larger sites will require a

Concerns over the impact of CC1 on overall housing numbersand delivery. HBC should have undertaken a comprehensiveStrategic Assessment of the extent to which the Draft Policy

proportion of the site will be required forCC1 requirements for flood risk avoidance and Sustainableamenities open space and SUDS etc. It isDrainage Systems (SuDS) decrease the overall housingalso important to note that most of the sitesnumbers that could realistically be deliverable on the potentialallocated lie within flood zone 1 and in areaswhere the risk of surface water flooding islow (as outlined in the Sequential Test).

development sites allocated in the Draft Local Plan. Thecumulative impact of CC1 requirements, especially SuDS, islikely to be a significant reduction in achievable building landareas.

A comprehensive Strategic Assessment should be carried outto make a realistic, evidence-based, estimate of the potentiallydeliverable housing numbers for all the allocated developmentsites, and the overall number. This Assessment should accountfor the probable effects of SuDS and flood risk on the potentialbuilding areas and on the cost-effectiveness of development,and evaluate the implications of such an Assessment for theoverall goals of the Local Plan andmake appropriate changesto the Plan's overall strategies.

Noamendment.

Whilst it is agreed that the risk of gypsumdissolution forms a valid exception to whereSuDS are not appropriate, it is felt the policy

SuDS are capable of penetrating ground layers which containgypsum and is capable of dissolution resulting in unstableland (Ripon City Council).

wording already allows for this exception aswell as remaining flexible enough to includeother exceptions.


Climate Change 9


HBC ResponseKey Issue / Suggested Modification

Add to paragraph “All development… Priority should be givento incorporating Sustainable Drainage Systems (SuDS) tomanage surface water drainage, unless it is proven that SuDSare not appropriate, for example, where there is a risk ofgypsum dissolution. …” (Ripon City Council).

Noamendment.

Policy NE5 sets out requirements for Greeninfrastructure and includes reference to itsimportance. An update to the GreenInfrastructure Supplementary PlanningDocument (SPD) is also scheduled.

Paragraph needs to be strengthened to ensure greeninfrastructure to reduce flooding and surface water run off thatis show on initial design proposals is not changed at a laterdate to be concrete storage tanks. The result of these changeswould result in biodiversity loss. The local plan needs topositively support biodiversity gain and ensure planning designthat shows green infrastructure is adhered to.

Table 9.2 Key Issues : Policy CC1 Flood Risk and Sustainable Development

CC2: Rivers



No amendment.Noted.Support

No amendment.The policy requires that all new developmentshould have regard to the relevant policies anddirectives which seek to protect and improve the

Quoting an 8 metre buffer zone may not fit allcircumstances. A buffer zone of at least 8 metresmay not be sufficient and each planning application

quality of water bodies and ecological systems.should take into consideration what wildlife needsIt also clearly states that the 8m buffer is aminimum requirement in order to provide aneffective and valuable river corridor.

protecting and how far it stretches. Considerationmust also be given to what reducing the surroundingarea to 8 metres would mean to water flow andpossible flooding downstream.

Table 9.3 Key Issues : Policy CC2 Rivers

CC3: Renewable and Low Carbon Energy



Amend Criterion B toread: 'Proposals forwind

Noted. Amend to ensure clarity.Historic England support policy but Criterion B needs tobe cross referenced back to requirements of Criterion Ato ensure no confusion about considerations that wouldneed to be taken into account in determining applicationsfor wind turbines.

Amend Criterion B to read: 'Proposals for windturbine developments in addition to satisfying therequirements of Criterion Amust also ...' (Historic England)

turbine developmentsin addition tosatisfying therequirements ofCriterion A must also...'

No amendment.Disagree. It is felt that this policy issufficiently positive and flexible tobring forward renewable and lowcarbon energy across the wholedistrict on a variety of scales.

Paragraph 7.22 - Currently no sites for energy generationare identified in this local plan. There is an urgent need toproduce energy from renewable non fossil fuel sources inorder to meet HBC’s own carbon emissions targets whichneed to be met before the end of the term of this LocalPlan. Basing the assessment of both the potential for andsuitability of sites for renewable and low carbon energygeneration on an out of date report renders this elementof the plan unsound. More detailed assessment is neededinto suitable sites for such generation is required.


9Climate Change



No amendment.Disagree. The council considers thatthe draft policy, as worded, providesan appropriate framework for

Evidence BaseThe Harrogate District Planning and Climate ChangeStudy (2011) is now 7 years out of date. It is notpossible to properly assess the suitability and weighing the positive benefits of

renewable energy proposals againstany negative adverse impacts.

constraints of new and emerging technologies whensuch technologies were not commercially viable atthe time of the report’s writing.

The Climate Change Study (2011)provides a starting point to determinewhere a particular technologymay be

Additionally the implied weight given here to thequality of the District natural and built environmentneed to be balanced with the urgent need to developrenewable energy generation to meet the District’sclimate change objectives.

suitable. It is felt that the policy isflexible enough to allow for newtechnology be brought forward.

No amendment.Disagree. Policy CC4 requires alldevelopments reduce CO2 emissionsthrough a sequence of priorities,including encouraging renewable andlow carbon energy generation.

Paragraph 7.29 is encouraging but further opportunitiesfor renewable and low carbon energy are missedhere. Further small scale generation could be achieved byencouraging all new developments to maximise renewableand low carbon energy generation in order to increase thesupply of energy for the whole district.

No amendment.Noted, however the council believesthat this policy, along with CC4:Sustainable Design, provides a

Paragraph 7.30 - While maximising the reduction in energyuse is a priority, every opportunity to encourage locallygenerated renewable energy will be needed to meet the

positive framework to both reduceClimate Change targets including allowing larger thannecessary energy generation installations as their benefitswill feed into the energy supply for the whole District.

energy use and encourage a rangeof renewable and low carbon energygeneration.

Amend the final sentence of paragraph 7.30 toread: Through such an approach it may be possible toreduce any unacceptable adverse impacts to an acceptablelevel by reducing the need for energy at the same time asmaximising energy generation.

No amendment.The Minerals and Waste Joint Plancontains a number of policies relatedto hydrocarbon development it is notconsidered appropriate or necessaryfor the Local Plan to duplicate these.

The Plan fails to address the issue of Fracking.

The Plan should outline the Council's position in regard toFracking.

No amendment.The council considers that the draftpolicy, as worded, provides anappropriate framework for weighing

“Permission will be granted…….” will need to becomemore directive if our CO2 emissions and energy use areto be reduced to target levels. It is regretted that so much

the positive benefits of renewableenergy proposals against anynegative adverse impacts.

of the script in paras 7.16 to 7.36 sets the conditions andconstraints applying to renewable energy initiatives. It isdifficult to see that a significant quantity of renewableenergy will be forthcoming from such limitations. Localcommunities appear to hold a veto over renewables.

There should be fewer conditions and constraints applyingto renewable energy initiatives.


Climate Change 9



No amendment.It is not felt that the Plan is anappropriate place to report progresson carbon reduction targets. In

This section talks well to broader government expectationsbut does not state where Harrogate District is in achievingthose targets. For example, 20% electricity from zero

addition the council believes that thiscarbon sources by 2020? This is only 2 years away -policy, along with CC4: Sustainablewhere is the district as a whole on this scale. To achieveDesign, provides a positive frameworkthe 80% reduction by 2050 requires this plan to set its ownto both reduce energy use andencourage a range of renewable andlow carbon energy generation.

targets on the way to 2035. We cannot simply rely onlarge wind turbines and local hydro: using photo voltaicand similar technologiesmore consistency in every housingdevelopment above 10 houses is where wewill makemajorchanges. For existing housing stock - it is up to theowners, so new housing and commercial stock mustcompensate, with costs coming down all the time. It is farcheaper to design in these solutions than add later.

Specific actions, targets and triggers are required forclimate change and sustainable design.

Table 9.4 Key Issues : Policy CC3 Renewable and Low Carbon Energy

CC4: Sustainable Design



N/ASupport noted.Support

Noamendment.

Disagree. The National Planning PolicyFramework (NPPF) states that planningauthorities should adopt proactivestrategies to mitigate and adapt toclimate change.

Matter is covered by Building Regulations

Delete policy

Noamendment.

Disagree. The policy does not setadditional standards and is the council'sproactive strategy to mitigate and adaptto climate change as outlined in NPPF.

Policy is overly prescriptive and not consistent with approach fromcentral Government of seeking to remove such requirements fromLocal Plans. Written Ministerial Statement of 25th March 2015 isclear local authorities should not set additional standards forrenewable energy or low carbon technologies in Local Plans.

Revert to policy wording in Draft Local Plan (October 2016)

Noamendment.

Sustainable transport infrastructure isaddressed within a specific Policy, TI1:Sustainable Transport.

There is nomention of transport infrastructure in CC4: SustainableDesign. One of the key ways that new developments can “supportand contribute to wider resilience” is through design withsustainable transport in mind.

Amend to include reference to transport infrastructure andexamples as per NPPF paragraph 29.


9Climate Change



Noamendment.

Disagree. The council considers that thepolicy as worded provides an appropriateframework to mitigate and adapt to

The Policy does not advocate sustainable design stronglyenough.

climate change. It requires allReplace "encourage" with "promote and enable"

Policy should be amended to require zero carbon developmentand require all developments to include environmentallysustainable features to meet to highest environmental standardsat the time of construction and to plan for low carbon occupation:

development to be designed to reduceboth the extent and impacts of climatechange.

A. All developments should demonstrate how they will seek tomitigate carbon dioxide emissions during construction and up to2050...

B. The council will require that developers demonstrate that theyhave considered the latest environmental design measures andhow these have been incorporated into their plans, including butnot limited to: ...

C: All new housing must have a minimum standard of energyefficiency at the highest level at the time of completion;

D: All new housing must publish a sustainability report and makethis available online for all in the local area for public scrutiny.

Table 9.5 Key Issues : Policy CC4 Sustainable Design


Climate Change 9

10 Heritage and Placemaking

HP1: Harrogate Town Centre Improvements


N/A.Noted.Support criterion D (Historic England).

N/A.Noted.Support vision for Harrogate town centre (HistoricEngland).

Table 10.1 Key Issues : Policy HP1 Harrogate Town Centre Improvements

HP2: Heritage Assets


N/A.Noted.NYCC Support. Robust policy that echoes sustainabledevelopment principles of NPPF in regards to heritageassets.

N/A.Noted.Support, as takes a positive approach to permittingdevelopment relating to designated and non-designatedheritage assets and their settings.

No amendment.Disagree. The policy isdeliberately flexible to ensurewide ranging potential forprotection.

Criteria in relation to non-designated heritage assets isvague and does not reflect their wide variety and nature.

Amend wording to state that proposals involvingnon-designated heritage assets should be assessed on acase by case basis and informed by specific HeritageAssessments.

Amend second sentence toread: '.. of key views andvistas from and towards theGeorgian pleasure grounds...'

HBC agree to amendcriterion.

Historic England fully endorse Policy, subject toamendments to criteria C and H, and the justificationprovided for the Policy.

Criterion C - not just views from within World Heritage Site(WHS) that are important. Views from surroundingcountryside also contribute to appreciation of this heritageasset.

Amend second sentence to read: '.. of key views and vistasfrom and towards the Georgian pleasure grounds...'(Historic England).

Amend para 8.19 fromsecondsentance to read'Development proposals

Paragraph 8.19 of thejustification to the policyincludes the same intention.

Historic England fully endorse Policy, subject toamendments to criteria C and H, and the justificationprovided for the Policy.

which may affectTo add this to the policyarchaeological sites shall bewould make it lengthy. HBCCriterion H - policy does not provide any guidance to

decision maker on how should deal with application whereharm is considered acceptable in principle.

informed by an appropriatedesk-based assessment (andwhere necessary a field

suggest rewording of para8.19 after the secondsentence to include HE’ssuggested amendment.At end add: 'In those cases where development affecting

such sites is acceptable in principle, mitigation of damagewill be ensured through preservation of the remains in situ

evaluation). This evaluationshould determinewhether: theremains merit preservationin-situ; whether the remainsas a preferred solution. When in situ preservation is notmerit preservation by record;justified, the developer will be required to make adequateor whether no further actionprovision for excavation and recording before or duringis necessary. The findings ofdevelopment. Subsequent analysis, publication andthis assessment will be adissemination of the findings will be required to be

submitted to the local planning authority and deposited withthe Historic Environment Record.' (Historic England).

material consideration whichinforms the determination of


10Heritage and Placemaking


the planning application Inthose cases wheredevelopment affecting suchsites is acceptable inprinciple, mitigation ofdamage will be ensuredthrough preservation of theremains in situ as a preferredsolution. When in situpreservation is not justified,the developer will be requiredto make adequate provisionfor excavation and recordingbefore or during development.Subsequent analysis,publication and disseminationof the findingswill be requiredto be submitted to the localplanning authority anddeposited with the HistoricEnvironment Record

No amendment.Disagree. It is felt that HP2sets a clear framework for theprotection of heritage assets.

Policy does not fully reflect guidance set out in NPPF.

Amend wording to reflect guidance in paras 132 to 135 ofthe NPPF. Planning Practice Guidance

makes clear that Local Plansshould avoid unduerepetition.

No amendment.Disagree. It is felt that HP2sets a clear framework for theprotection of heritage assets.

Policy does not fully accord with Section 12 of theNPPF or statutory duty set out in section 66 and section72 of the Planning (Listed Building and Conservation Areas)Act 1990.

Amend policy wording to reflect NPPF and statutory duty.

No amendment.WHS are already subject toa high level of protectionthrough the NPPF and the

As currently drafted policy does not provide an appropriatepolicy for the protection of the WHS. Wording of HP2Clacks clarity and is potentially misleading. Also need to

council does not feel thatidentify development beyond designated boundaries mayalso need to have regard to the WHS. Maintain should bebespoke policy guidance for WHS (National Trust).

additional guidance wouldoffer any additionalprotection.

Include a bespoke WHS policy or

Amend second sentence to read: 'Key views and vistas toand from the WHS including its buffer zone and RPG willbe protected and there will be a strong presumption againsttall or very large buildings and structures within the ....'

Add to HP2C: 'Proposed development outside theboundaries of the Buffer Zone will be assessed for theireffect on the OUV of the WHS. Applicants will be requiredto demonstrate that their scheme will not harm thoseelements which contribute to the Outstanding UniversalValue of the world heritage site.' (National Trust).

No amendment.Disagree. The policy asworded does not excludeinternationally importantheritage assets.

Policy also needs to recognise there are designatedheritage assets of international importance (National Trust).


Heritage and Placemaking 10


No amendment.It is considered that thepolicy gives adequateprotection of World HeritageSites.

Supporting text to Policy HP2 (paragraphs 8.27 - 8.30)needs to be more robust in protection of OUV of the WHS;text should highlight that WHS Management Plan isreviewed every six years; should explicitly state may beinappropriate development beyond WHS boundaries thatcould impact on OUV of the WHS and its setting; inclusionof reference to guidance on impact assessments; correcttitle of WHS should be used throughout the Plan (NationalTrust).

Amend paragraphs 8.27 - 8.30. (National Trust).

No amendment.It is considered that thepolicy gives adequateprotection of World HeritageSites

Amendments to paragraph 8.16 are needed to ensureconsistency with national policy to protect theWHS (National Trust).

Amend paragraph 8.16, second bullet point to read: ‘..World Heritage site and RPG, the outlying routes ,landscapes and bridges,…’ (National Trust).

Amend para 8.35, 8.42 and8.44 to read '....including theirsetting will not be permittedunless it can be shown.....'

Agree to suggested minormodification.

The words ‘will not be permitted’ have been omitted fromparagraphs 8.35, 8.42, 8.44. (National Trust).

Amend paragraphs 8.35, 8.42 and 8.44 to read: ‘…including their setting, will not be permitted unless it canbe shown ….’ (National Trust).

No amendment.Noted, although disagreethat specific reference isneeded. When a

Notwithstanding this policy, where a made neighbourhoodplan is in existence, to afford local distinctiveness, policyregarding the skyline impact of development proposals

neighbourhood plan is madewhich includes, but not exclusively, any part of the WorldHeritage Site Buffer Zone shall continue to apply (RiponCity Council)

it will form part of thedevelopment Plan and will betaken into accountaccordingly.Add to policy: Notwithstanding this policy, where a made

neighbourhood plan is in existence, to afford localdistinctiveness, policy regarding the skyline impact ofdevelopment proposals which includes, but not exclusively,any part of the World Heritage Site Buffer Zone shallcontinue to apply. (Ripon City Council).

Table 10.2 Key Issues : Policy HP2 Heritage Assets

HP3: Local Distinctiveness


No amendment.Disagree. Local Plans shouldavoid repetition.

Policy repeats many aims of other specific policiessuch as biodiversity, landscape and density. To beeffective reference to those policies would be usefulto ensure applicants are fully aware of policies thatneed to be addressed in regard to specific matters.

Amend policy wording to reference to specificpolicies.




Add additional criterion: 'Retain andrepair traditional shopfronts wherepracticable'

Add new para to the justification toread " Traditional shopfrontsrepresent an important element of

Support noted. HBC agree toadd additional criterion. Alsoadd new para 8.65 to thejustification and add HBCShop Front Design Guide tothe Further information box atthe end of the policy.

Historic England support policy which providesappropriate framework to help ensure localdistinctiveness is maintained or reinforced.

As traditional shopfronts are one of the elementsthat contributes to distinctive character of district'stowns, would be helpful if policy specifically set outa requirement for these to be retained whereverpossible.

our District's built environment withnumerous examples surviving inHarrogate, Ripon, Knaresboroughand also the smaller towns ofAdd additional criterion: 'Retain and repair traditional

shopfronts where practicable' (Historic England). Boroughbridge, Pateley Bridge andMasham. They contribute positivelyto the character and appearance oftown centres. Traditionalshopfronts vary in form but ingeneral follow certain designconventions which are indicative ofchanging styles over time. Qualityof workmanship and joinery detailscontribute greatly to thesignificance of surviving examples.

Add HBC Shop Front Design Guideto the Further information box atthe end of the policy.

No amendment.Disagree. The council feelsthe policy provides anappropriate framework to

Add additional criterion: 'Retain and repair traditionalshopfronts where practicable' Policy needs moreteeth to protect the high quality environment and

encourage high qualitydesign and localdistinctiveness.

should require ‘Design Review’ arrangements forlarge/contentious schemes as well as the thepreparation of master plans, design codes or‘handbooks’ to inform designs on prominentdevelopment sites and specifically, those that arenot in a Conservation Area or covered by CharacterAppraisals. NB. This is supported in the NPPF -Paragraph 59. Further updates to other designguidance needed.

Include design review arrangements forlarge/contentious schemes

No amendment.Noted, although disagree thatspecific reference is needed.When a neighbourhood plan

Add to policy: "Notwithstanding this policy, wherea made neighbourhood plan is in existence, to affordlocal distinctiveness, policies regarding quality ofbuilding, urban and landscape design shall continueto apply" (Ripon City Council).

is made it will form part of thedevelopment Plan and will betaken into accountaccordingly.

Table 10.3 Key Issues : Policy HP3 Local Distinctiveness



HP4: Protecting Amenity



No amendment.It is felt that sufficient flexibilityhas already been included withinthe policy.

In some urban areas will not be possible to provide private outdoorspace for all units. Policy allows some flexibility but wording shouldbe relaxed to require outdoor space only where viable anddeliverable to do so.

Amend policy wording to require provision of well-designed andlocated outdoor amenity space only where viable and deliverableto do so.

Table 10.4 Key Issues : Policy HP4 Protecting Amenity

HP5: Public Rights of Way


N/AN/ANone

Table 10.5 Key Issues : Policy HP5 Public Rights of Way

HP6: Protection of Existing Sport, Open Space and Recreation Facilities



N/A.Noted.Support Criterion B (Historic England).

No amendment.Noted, although it is not felt thatthis is necessary to reiterate withinthe Local Plan policy.

Add to policy: Notwithstanding this policy, where a madeneighbourhood plan is in existence, to afford localdistinctiveness, policies regarding protection of amenity andrecreational open space sites shall be supported by identificationof such sites on the neighbourhood plan policies map. (RiponCity Council).

Table 10.6 Key Issues : Policy HP6 Protection of Existing Sport, Open Space and Recreation Facilities

HP7: New Sports, Open Space and Recreation Development



Amend Criterion AVi. Outdoor sportsfacilities: 1.16 ha per

The Council is in the process ofcommissioning for the update to theOutdoor Sports Strategy and a Indoor

Evidence Base (Sport England)Where policy dictates locations for new facilities,no evidence to support this due to the currentevidence base being outdated. 1000 people the

provision of outdoorsports facilities from

Sports Strategy and the work will haveprogressed significantly by theExaminiation. On this basis, Criterion AOutdoor space standards are not derived from

up to date Outdoor Sports Strategy that coversthe Plan timeframe. May also be case that moreappropriate way to meet need would be throughpitch quality improvements.

developments will beinformed by an up todate and robustOutdoor SportsStrategy'

vi should be amended to state that thestandard will be informed by the newstrategy.

Update evidence base. (Sport England).

Amend A. vi to remove standard for outdoorsports facilities and replace with ‘the provision ofoutdoor sports facilities from developments willbe informed by an up to date and robust playingpitch strategy’





No amendmentThe inclusion of standards within thepolicy is acceptable and not somethingunique to the Harrogate Local Plan. The

Policy needs:

to be flexible enough deal with any changes tostandards over plan period justification in para 8.90 makes reference

to providing a developer contribution foroff site provision or enhancement inbe clearer that standards can be secured through

a commuted sum circumstances and also to the SPDwhichprovides all the necessary detail aboutthe implementation of the policy.

The assessment of standards should also have haveregard to the quality of spaces and facilities, which ispromoted by NPPF para 73.

Amend policy:

to delete list of specific standards and refer tomeeting standards in latest SPD

to be clearer on when a commuted sum could beoffered in place of on-site provision

Provide further evidence regarding quality of spacesand facilities.

No amendmentThis wording is consistent with thewording of other policies within the LocalPlan so is appropriate.

Item B ii introduces “significant traffic congestion” as atest. NPPF includes a ‘severity’ test and we wouldexpect this to be applied to sports and recreationproposals rather than having a local criteria.

Table 10.7 Key Issues : Policy HP7 New Sports, Open Space and Recreation Development

HP8: Protection and Enhancement of Community Facilities



Noamendment.

Disagree. NPPF is clear that planning policiesshould plan positively for community facilitiesfor and guard against the unnecessary loss ofvalued facilities and services.

Policy is disproportionate response to need to protectcommunity facilities and has number of flaws: where facilitiesreplicated within settlement should not afford facility sameprotection; fails to recognise modern marketing methodsi.e.social media; fails to provide mechanisms for recognisingchanging markets or that after period of time business hasnot traded then ceases to be regarded as community assetwhere policy would apply.

Amend wording to recognise current conditions forbusinesses and/or current marketing approaches.

The policy does not exclude or discourage theuse of modern marketing methods but sets abaseline for the applicant to ensure that allreasonable attempts have been made tomarket the site.





Noamendment.

Disagree. The council considers that culturalfacilities are given adequate protection in thePlan.

Welcome some protection to cultural facilities throughinclusion within Policy EC6 but to classify as touristattractions overlooks wider social purpose and value incontributing towards sustainable communities and socialwellbeing. Coverage of cultural facilities alongside the uses In line with NPPF (para 70) HP8 aims to

guards against the unnecessary loss of valuedfacilities and services, particularly where thiswould reduce the community’s ability to meetits day-to-day needs.

already referenced within Policy HP8 would align with thegrouping of facilities set out within the NPPF. (TheatresTrust).

Amend supporting text to Policies HP8 and HP9 to addcultural facilities such as theatres to list of uses to whichpolicies apply and remove them from Policy EC6.

Table 10.8 Key Issues : Policy HP8 Protection and Enhancement of Community Facilities

HP9: Provision of New Community Facilities


None

Table 10.9 Key Issues : Policy HP9 Provision of New Community Facilities



11 Natural Environment



No amendment.Applications for fracking would be subject to all thepolicies within the Local Plan, not just the NaturalEnvironment chapter. A decision on a fracking

All of the policies policies NE1 to NE8 would bedirectly threatened by Fracking. The Councilshould outline its position within this section andexplain that Fracking would breach all of theNatural Environment policies.

The Council should outline its position on frackingwithin this section.

proposal would have to be be considered on a caseby case basis taking into account the magnitude ofboth the positive and negative impacts of thescheme.

Table 11.1 Key Issues : Natural Environment

NE1: Air Quality



Noamendment.

Traffic which travels through an AQMA may well begenerated from a development site outside of the AQMAand therefore restricting air quality assessments to only

Criterion A - neither policy or supporting textadequately define 'affect'. Would normallyexpect air quality information to be submittedfor proposals within an AQMA, not necessarilyoutside of it.

developments within AQMAs would be insufficient.Whether a development will affect an AQMA will beconsidered on a case by case basis and subject to futureguidance which will be prepared by the council.Criterion A - amend wording so that

requirement only relates to proposals within anAQMA.

Noamendment.

Guidance will be prepared with the council'senvironmental protection team and the local highwayauthority to identify locations, land uses and sizethresholds above which applications for developmentproposals will be required to provide assessments.

Criterion D - wording refers to 'significantamounts of traffic', but 'significant' is notdefined.

Criterion D - explain what is meant by'significant'.

Table 11.2 Key Issues : Policy NE1 Air Quality

NE2: Water Quality



Noamendment.

The Infrastructure Delivery Plan has, following consultationwith utility providers including Yorkshire Water, identifiedthe likely key infrastructure requirements to accommodatethe level of growth planned.

Whilst welcome wording of policy, does notgo far enough as fails to mention existingproblems of drainage system servingHarrogate. Should address how existingproblems associated with using openwatercourses for sewer overflows will not beexacerbated by further development.

Policy NE2, together with Policy TI4, seeks to ensure thatproposed developments are adequately served byinfrastructure and necessary improvements are put in place.This should be determined through drainage strategies anddetailed discussions with the utility providers.

Table 11.3 Key Issues : Policy NE2 Water Quality


Natural Environment 11

NE3: Protecting the Natural Environment


N/A.Noted.Support (Respondents include YorkshireWildlife Trust and Natural England)

Amend wording ofjustification paragraph 9.23to: Applications for

Agree that BS42020 is a good standard towork to. Agree that membership of CIEEMis a good method of ensuring a surveyor's

In order to ensure that wildlife sites, speciesand habitats are fully protected and biodiversitynet gain is achieved it will be important thatsurveys of baseline conditions are carried outto a high standard.

development likely to affectany of the aforementioned

competence to undertake the work,however, it does not follow that a surveyor

natural assets will beexpected to include a

who is not a member of the CIEEM is notcompetent and that adding thisrequirement may have unintendedimplications.

Ecological surveys to be carried out toBS42020 by qualified surveyors who aremembers of the Chartered Institute of Ecologyand Environmental Management. (YorkshireWildlife Trust).

suitable ecological surveyand assessment carried outto BS42020 (or as updated)containing sufficientinformation to allow a properevaluation to be made of theimpact upon the site. Allmajor applications will berequired to submit aPreliminary EcologicalAppraisal carried out toBS42020 (or as updated).

Amend wording ofjustification paragraph 9.35to: All major applications willbe required to submit aPreliminary EcologicalAppraisal carried out toBS42020 (or as updated) anda calculation of thebiodiversity impact of theproposed developmentbased on this standardmetric.

Amend wording of criterionG to:

Criterion B does not prevent developmentthat affects local sites but does require anecological appraisal to show that

Number of criteria are onerous.Criterion B - approach set out is notadvocated in NPPF. Amend approachto require assessment to be undertakenwhich seeks to incorporate the Local Siteor if necessary provide mitigation.

Requiring proposals tomakeuse of opportunities torestore and re-create priorityhabitats and other naturalhabits within and adjacent todevelopment schemes.

significant harm can be avoided, mitigatedor compensated for. This is in keeping withNPPF paragraph 113.

The policy seeks to encourage alldevelopment to provide a net gain inbiodiversity and this includes takingopportunities to restore and re-create

Criterion G - the restoration orre-creation of priority habitats may onlybe required on some occasions andshould be determined on a case by case

habitats. It is noted that these opportunitieswill not be present on all sites and that thisshould be clarified in the policy wording.

basis. Amend wording to refer to needfor restoration or re-creation beingdetermined on a case by case basis andinformed by a site specific assessment.

No amendment.The selection of sites for designation issubject to a process separate to that of theLocal Plan preparation. The North

Reports and surveys to show how SINCs havebeen assessed as part of Local Plan processnot provided as part of evidence base.

Yorkshire SINC Panel have produced aLandowner not provided with opportunity toreview and comment on that evidence,therefore, SINC allocation unjustified.

document 'Guidelines for Site Selection'(2002, as amended) which can providefurther details on the process undertaken.


11Natural Environment


No amendment.Criterion D is making reference toirreplaceable habitats rather thanlandscapes. Irreplaceable habitats such

Object to Criterion D relating to species richgrasslands. NPPF para. 109 states that theplanning system should contribute to and

as individual veteran trees, ancientenhance the natural environment by protectingwoodlands and grasslands may not bedesignated formally but still commandprotection.

and enhancing valued landscapes. Any site tobe protected should, therefore, be formallydesignated.

No amendmentThe draft NPPF does suggest a directionof travel in terms of the protection offeredirreplaceable habitats however there is no

Weight should be given to Paragraph 173 ofDraft NPPF (which deals with irreplaceablehabitats such as ancient woodland) as it shows

guarantee that the details within the drafta clear direction of travel from centralGovernment to strengthen the protection ofirreplaceable ancient woodland.

NPPF, such as a requirement for amitigation strategy, will be included withinthe next iteration of the NPPF. It is notclear how mitigation strategies forCriterion D should be revised to read:

“Development resulting in the loss ordeterioration of irreplaceable habitats (such as

irreplaceable habitats can be judged andmay be better addressed when nationalpolicy is confirmed.ancient woodland) should be refused, unless

there are wholly exceptional reasons and asuitable mitigation strategy exists.”

(The Woodland Trust).

No amendment.Noted, however, the policy as worded isin keeping with the current NPPFparagraph 109 which requires plans tominimise impacts on biodiversity andprovide net gains where possible.

9.19 requires stronger wording to be moreeffective. The local plan should be aiming fora net gain rather than merely 'avoiding' netloss.

Reword E so that net gain of biodiversitycomes before net loss and is thereforepresented in a more positive way. Net gainshould be the standard, net losses shouldbecome unacceptable

Table 11.4 Key Issues : Policy NE3 Protecting the Natural Environment

NE4: Landscape Character



N/ANoted.Support the Policy (including Historic England andCPRE)

Noamendment.

These criteria are used in the assessment ofdevelopment proposals to ensure that theprotection and enhancement of landscape

Further information and wording amendments required.Part C - reference to 'proposals that protect and/orenhance' is high test to pass particularly in termsof character and visual amenity. character is taken into account and this will not

prevent otherwise acceptable development comingforward.

The criteria based policy ensures that applicantscarry out landscape assessment work todemonstrate the proposals are appropriate.

Part D - further information is required as to whichskylines, hills and valley sides are sensitive inorder to enable thorough assessment to beconducted.

Part F - use of term 'Avoid significant loss of keycharacteristics' of Special Landscape Areas (SLA)is a high test to pass. Most development in or

The purpose of the SLA is to identify those areasof high quality landscape that contribute to thesetting of Harrogate, Knaresborough or Ripon andwithin proximity of SLA will result in some

inevitable significant loss/change to characteristicsat site level.

to ensure that any development within them doesnor affect the high quality of the landscape andthe setting of those settlements adversely. All





development will result in some change to thelandscape but it is not inevitable that the changeis significant.

Noamendment.

Criteria C is used in the assessment ofdevelopment proposals to ensure that theprotection and enhancement of landscapecharacter is taken into account. A 'response' tothe landscape will not suffice.

Amend wording of Part C to require that developmentproposals 'are response' to the character. appearanceand local distinctiveness of the landscape.

Provide further information on which skylines, hills andvalley sides are sensitive.

Applicants will undertake landscape assessmentwork to demonstrate the proposals areappropriate.

Noamendment.

Policy NE4 does not preclude development withinthe SLAs but provides a criteria based approachto avoid inappropriate development which would

As part of consideration of planning application(17/00213/OUTMAJ) officers concluded that site couldbe developed without harming wider Special

adversely impact on the quality of the area. TheLandscape Area (SLA) objectives. As such, unjustifiedto include site at Rossett Green Lane in the SLAdesignation.

decision to designate an area of a SLA has beenbased on the site as a whole, at a landscape level,and is not a reflection of the value of an individual

As site (H77) is proposed for allocation (as part of siteH51) and therefore suitable for development seemsanomalous that Special Landscape Area designationshould be extended to cover site.

parcel of land in isolation. Development within theSLA will have to meet criteria to avoid impactingon the quality of the SLA landscape whether it isnew build or further development (such as houseextensions) later in the plan period.

Have concern regarding the overlap between some ofthe SLAs and allocations for housing and mixed usedevelopment and question validity of maintaining the

Policy NE4 is in keeping with NPPF para 113which requires protection to be commensuratewith the status of the landscape and give thedesignation appropriate weight to its importance.

SLA designation once development has occurred. SLAdesignation should be removed from allocations or if notacceptable there should be greater explanation of whatthis means in practice for the allocations affected.

How can the impact of proposed developments be"carefully considered" as clearly if you build a housingestate on a SLA then the SLA is lost for good. This planrenders the SLA designation as meaningless and ridesroughshod over all the good work done before.

Noamendment.

Disagree. The emerging Local Plan allocatessufficient sites to meet the housing requirement.Notwithstanding this, the policy does not precludedevelopment from taking place, only that it has tomeet set criteria.

Given fundamental need to significantly increase housingdelivery, requirement to apply policy criteria flexibly. Addexplanatory text to highlight that policy criteria will bebalanced by need to provide significant uplift in housingdelivery over plan period.

Noamendment.

Paragraph 109 of the NPPF refers to protectingand enhancing 'valued landscapes' - the SLAdesignation indicates that this is a valuedlandscape and as such is afforded appropriateprotection.

NPPF para 17 only makes reference to recognizing theintrinsic character and beauty of the countryside andnot, as set out in the Policy, protecting and enhancingit.

Evidence base on which SLA designations were madeis out of date and, in certain circumstances, overtakenby recent changes in circumstances. The 2016 update

The 2016 SLA review continues to provideproportionate evidence base for SLA designationin light of the emerging policy approach towardsSLAs where development could take place subjectto meeting the criteria of NE4.

does not include new assessments or conclusions fromthe 2011 study and designation of precise boundariesis questionable given rely on out of date evidence.

Number of allocations are covered by SLA designation.The approach is confusing and could lead to delay indelivery of allocations given conflicting policyrequirements.





Noamendment.

When justified by a robust assessment carriedout by an appropriately qualified person thanamendments to SLAs may be included within the

Whilst Special Landscape Areas is a district wide policythe boundary of each Special Landscape Area shouldbe determined at neighbourhood level where aneighbourhood plan has been made. relevant neighbourhood plans. However,

neighbourhood plans are not required to includelandscape policies and the scale of a landscapedesignation may not be appropriate for allneighbourhood areas.

Noamendment

Paragraphs 2.17 - 2.22 of the Local Plan explainthat Neighbourhood Plans may set detailedpolicies to address specific issues of concern

Add to policy

Notwithstanding the strategic nature of this policy in thatthere shall be Special Landscape Areas, where a madeneighbourhood plan is in existence, to afford local

locally. They do not have to cover every topic.Once a Neighbourhood Plan is made it will beused to determine planning applications fordistinctiveness, the Special Landscape Area boundary

itself shall be taken to be as that shown in the relevantneighbourhood plan’s policies map.

development within the neighbourhood area. It istherefore not necessary to annotate each detailedpolicy which may or may not be addressed by afuture neighbourhood plan.

Noamendment

It is not necessary to remove the SLA designationfrom areas with draft allocations as Policy NE4does not preclude development within the SLAs

Amend policy to reflect guidance in NPPF para. 17.

Remove SLA designation from allocated sites.but provides a criteria based approach to avoidinappropriate development which would adverselyimpact on the quality of the area.Remove SLA designation from sites which are allocated

for development or if retained change wording of policyto explain that dual status of SLA with allocation should The SLA has been designated at landscape level

and all parcels of land will retain the designationthroughout the plan period to ensure that all future

be used during this plan period to inform a higherstandard of landscape scrutiny and design butacknowledge that designation will ultimately change inthese areas if and when they are developed.

development within the SLA (new builds, houseextensions, change of use etc) will have to meetcriteria to avoid impacting on the quality of theSLA landscape.

Noamendment

To resist all development on SLA land would becontrary to para 113 of the NPPF. Protection ofSLAs should be commensurate with their statusand given appropriate weight to their importance.

This page needs teeth. Protect SLA – do not allowdevelopment on SLA land. Drop all areas that includeareas of SLA off the plan, including those areas alreadycommitted.

Table 11.5 Key Issues : Policy NE4 Landscape Character

NE5: Green Infrastructure



N/ANoted.Support (including Historic England)

No amendment.The Green Infrastructure SPD is referenced incriterion B. Paragraph 9.49 explains the council'sintention to undertake an update to this SPD.

Policy needs to be read in context of backgroundevidence, which should be better referenced in mainbody of policy text to guide developers.

No amendment.Paragraphs 2.17 - 2.22 of the Local Plan explainthat Neighbourhood Plans may set detailed policiesto address specific issues of concern locally. They

Whilst this policy includes reference to specificGreen Infrastructure, this should not be deemed adefinitive and exclusive list. Neighbourhood

do not have to cover every topic. It is therefore notnecessary to annotate each detailed policy whichmay be addressed by a future neighbourhood plan.

planning bodies should be invited to support andidentify Green Infrastructure proposals which arelocally distinctive to their neighbourhood.

Table 11.6 Key Issues : Policy NE5 Green Infrastructure



NE6: Local Green Space



Tests of soundness

Noamendment

The Local Green Space Assessment Update 2017 setsout the approach that the Council took to identifying LocalGreen Spaces. It can be seen at Section 3 of the

Issues with ConsultationConsultation focused on Parish Councilsthereby excluding engagement with localcommunity assessment that the Council consulted on the

identification of Local Green Space in a number of ways,including consulting directly with Parish Councils andresidents groups as well as through the District WideIssues and Options Consultation, which invited the widercommunity to submit sites. Parish Councils were advisedthat, order to meet the criteria for Local Green SpaceDesignation, they would need to consult with their localcommunity. The Community were also able to submitsites independently through the Issues and OptionsConsultation and further sites were also submitted by thecommunity at he Draft Local Plan consultation.

Noamendment

Policy NE6 states that: 'Development will not be permittedwithin a Local Green Space designated either within theHarrogate District Local Plan or an approvedNeighbourhood Plan'.

Neighbourhood PlanningThis policy does not recognise that LocalGreen Space can be designated in aNeighbourhood Plan as well as in a LocalPlan. Supporting documents (November

Supporting paragraph 9.50 states: 'Local Green Spacecan be designated through a local plan or throughneighbourhood plans.'

2017) prepared for the Local Plan shouldnot be assumed to be the definitiveassessment of a site, although theirmethodology should be of assistance toneighbourhood planning bodies seekingto designate Local Green Space (RiponCity Council/Ripon Civic Society).

Omission Sites

Noamendment

The Local Green Space Assessment Update 2017 setsout the findings of the Councils Assessment. It isconsidered that the findings of the assessment arecorrect.

LGS100 (The Garth, Follifoot)Assessment findings of site are incorrect

Noamendment

The Pinewoods Conservation Group have submitted afresh application for this site, along with additionalinformation to support the application. This information

Irongate field should be designated within thepolicy.

has been assessed against the designation criteria andit has been determined that, whilst it is acknowledged thatthe site is a focus of community concern and is specialto the local community in that area, insufficient evidencehas been submitted to demonstrate that the sites holdsparticular local significance in relation to the designationcriteria. The site is also considered to be adequatelyprotected by existing and emerging Local Plan policiesand as such it has not been recommended that the sitebe designated as Local Green Space.

Noamendment

The Local Green Space Assessment Update 2017 setsout the findings of the Councils Assessment. It isconsidered that the findings of the assessment are correct.

LGS32 (Bilton Fields) should be designatedwithin the policy.

Assessment findings of site are incorrect.

Bilton Fields West (part of LGS32)





To overcome the issues outlined in theLGS Update Report, it is requested thatthe Western field of Bilton Fields (part ofLGS32) should be designated

LGS33 (Bilton Triangle) should be designatedwithin the policy.

LGS74 The Embankment should be designatedwithin the policy.

LGS77 Land to the West of MasseyField should be designated within the policy.

Request designation of additional sites:LGS99 (The Oval, Harrogate).

LGS107 (Beechwood Crescent)

Request designation of Bilton Fields, BiltonTriangle Nidd Gorge and green fields and woodsaround the Nidderdale Greenway.

Table 11.7 Key Issues : Policy NE6 Local Green Space

Local Green Space Allocations



Noamendment.

The area shown ringed in red on the submittedamended map was not included within theboundary for the Pinewoods within the originalsubmission. The area highlighted wasassessed as part of LGS29 Nursery Lane East.

LGS28The map shown is incorrect (amended mapsubmitted).

Disagree with Assessment of LGS28 (pinewoods)as the designation excludes the area known asIrongate Field - submission made requesting thatIrongate Field be assessed and considered as aLocal Green Space individually.

The second point regarding Irongate Field isnoted - a separate submission for IrongateField has been made and is dealt with above.

N/ANotedLGS110 Support

LGS111 Support

LGS48 Support (including Historic England)





Table 11.8 Key Issues : Local Green Space Allocations



NE7: Trees and Woodland



No amendment.The first statement of the policy requests thatdevelopment should protect and enhance treesthat have wildlife, landscape, historic, amenity,productive or cultural value or contribute to thesetting of a settlement.

Criteria on retention of trees is too narrow and does nottake account that trees can vary greatly in quality andfunction.

N/A.Noted.Historic England support policy and especially thatelement which relates to the protection of trees ofhistoric and cultural value or which contribute to thecharacter and/or setting of a settlement.

No AmendmentThe policy requires development which resultsin the removal or damage of trees to providereplacement trees on-site.

Wording should be amended to ensure that wheretrees are removed their value is established andfollowing this appropriate mitigation offered in terms ofnew planting.

Table 11.9 Key Issues : Policy NE7 Trees and Woodland

NE8: Protection of Agricultural Land



N/ANoted.Support the Policy

No amendment.Policy NE8 protects soil resourcesby criteria to ensure thatdevelopment on the highest grade

Policy goes beyond requirements of national policy, there is noreference to need for best and most versatile agricultural land tobe protected from development nor requirement that planningpermission should only be granted in exceptional circumstances. soil is not undertaken when it could

be accommodated on lower gradePolicy does not accord with NPPF para 112, which states LPAsshould take into account the economic and other benefits of bestand most versatile (BMV) agricultural land. It does not, as Policydoes, set an absolute embargo on loss of BMV except inexceptional circumstances.

soil. The policy also requiresdevelopers to protect soil resourcesduring development. This is in linewith NPPF paragraph 112.

Policy NE8 does not prevent alldevelopment on best and mostversatile agricultural land.

As worded, policy is incompatible with required scale of newhousing required and nature of the district. To deliver newsettlement, realistic to assume that agricultural land will be requiredto be developed but majority of land is Grade 3a or above. Policyis overly restrictive and potentially prohibitive of sustainabledevelopment.

Add sectionwithin FurtherInformationbox:

Agree, this document fed into thedevelopment of the policy andshould be included as furtherinformation/ guidance for applicants.

Natural England welcome the updates made to policy NE8 andits supporting text and recommend that Defras Construction Codeof Practice for the Sustainable Use of Soil on Development Sites(2009) is included in the further information section.

Furtherinformation/guidance forapplicants:

Departmentfor theEnvironment,Food andRuralAffairs(DEFRA):Construction





Code ofPracticefor theSustainableUse ofSoil onDevelopmentSites(2009)

Add referenceto NaturalEnvironmentsection ofbibliography:

Departmentfor theEnvironment,Food andRuralAffairs(DEFRA):ConstructionCode ofPracticefor theSustainableUse ofSoil onDevelopmentSites(2009)www.gov.uk/government/publications/code-of-practice-for-the-sustainable-use-of-soils-on-construction-sites

No AmendmentPolicy NE8 is in keeping with NPPFparagraph 112.

Amend policy to bring it more in line with NPPF.

Delete policy.

No AmendmentThe new settlement will not be anexception to this policy and will haveto meet the criteria.

Amend wording to include a reference to the new settlement asan exception to this policy.

Table 11.10 Key Issues : Policy NE8 Protection of Agricultural Land

NE9: Unstable and Contaminated Land



Noamendment.

All proposals for development within areasof unstable land or land suspected to becontaminated will be subject to this policy,

Sites should be considered on a case by case basis and ifadequate assurance could be provided in the form of landstability/contamination reports and/or remediation, should benot reason to prevent sites coming forward for development orbeing considered less favourably.

including allocated sites and windfall sites.The procedure for assessing sitespromoted for inclusion in the Local Plan isoutlined within the SustainabilityAppraisal.



www.gov.uk/government/publications/code-of-practice-for-the-sustainable-use-of-soils-on-construction-sites



For both unstable land and land suspectedto be contaminated the policy requires thatproposals need to provide appropriateassessments to demonstrate the level ofrisk and how these can be overcome. Thepolicy does not prevent sites from beingconsidered at planning application stage.

NoAmendment

The policy states that development issubject to development control proceduresand advice providing more detail on this

Amend the policy to be fully in line with evidence submitted bythe British Geological Survey. (Ripon Civic Society).

Replace paragraph 2 “With specific regard to subsidence dueto gypsum dissolution in the Ripon area, significant buildingdevelopment in areas which are suspected as being potentially

procedure accompanies the policy. Thisincludes the criteria for a competentperson in paragraph 9.86 of thejustification text and the footnote to table9.2.

susceptible to the problem will be subject to development controlprocedures, based on the development guidance categories inthe section below titled 'Gypsum Related Subsidence in theRipon Area' and as shown on the Policies Map. The Paragraph 9.87 of the justification text

explains that declaration forms should notbe subject to any caveat or disclaimers of

accompanying advice on 'Gypsum Related Subsidence in theRipon Area', including the requirements for Ground StabilityAssessment Reports and Declaration Forms in certain areasshould be taken into account in all applications for development.“

responsibility and that in thesecircumstances the correspondingapplications would fail to meet therequirements of policy NE9.

With the following;

"Planning permission will not be granted for new buildings orchange of use involving increased exposure of the public to aknown risk of subsidence within the area shown as Zone C onthe Policies Map identified as being potentially susceptible tosubsidence owing to gypsum dissolution unless a ‘GroundStability Report’ and a ‘Ground Stability Declaration Form’prepared and signed by a Registered Ground EngineeringSpecialist or Advisor as defined by the UK Register of GroundEngineering Professionals have been submitted; suchapplications will be subject to specific development managementprocedures"

It will not be acceptable for the design of any mitigationmeasure(s) to be the subject of disclaimer. (Ripon City Council).

Noamendment.

The alternative qualification is only one ofthe criteria for a competent person, thepolicy also requires the person has

This policy is insufficient to deliver effective scrutiny of land atrisk of instability arising from gypsum dissolution owing to theflexibility offered for alternative qualification, i.e other thanRoGeP, and the lack of a requirement that disclaimers are notaccepted was regards mitigation works. (Ripon Civic Society).

specific, demonstrable experience andexpertise in dealing with issues relating tosubsidence arising from gypsum

This policy should have full regard to recommendations of theBritish Geological Survey as regards the ineffectiveness ofcurrent policy and practice for gypsum dissolution in the Riponarea. (Ripon City Council).

dissolution within the Ripon area. This isexplained in paragraph 9.86 of thejustification text and the footnote to table9.2.

Paragraph 9.87 of the justification textexplains that declaration forms should notbe subject to any caveat or disclaimers ofresponsibility and that in thesecircumstances the correspondingapplications would fail to meet therequirements of policy NE9.

Table 11.11 Key Issues : Policy NE9 Unstable and Contaminated Land



12 Delivery and Monitoring



N/ANoted.Support for 10.30 - 10.36 (North Yorkshire LEP)

The policy approach set out in 10.30 to 10.36 is welcomed totake appropriate account of past under provision of housingand provide flexibility to avoid a continuation of this pattern.The measures to monitor and remedy any future underprovision against targets are appropriate.

This LEP will work with HBC, Homes England, developersand other partners to implement the measures in 10.35 andunblock delivery of new housing, in line with the Local Planprovision of 16,077 dwellings.

N/ANoted.Paragraph 10.38 - as local highway authority will continue towork with HBC on development of Infrastructure DeliveryPlan, particularly on measures relating to funding and deliveryof critical transport requirements. (NYCC)

Noamendment.

The windfall allowance figure is based onan assessment of past completion rates forwindfall sites within the district and only

Windfall allowance excessive as stock of windfalls has beensteadily reducing.

included small sites (sites of 4 or lessdwellings). This did not indicate that the rateof windfall development was reducingsignificantly.

Noamendment.

The expected timing and rate of completionshas been informed by the stage the site hasreached in the planning application process

Query sudden jump in completions on large sites at such earlystage of plan. Experience that taking up to 2/3 years socompletions should be spread over longer period. Deliverytimescales for allocations also optimistic.

Completion dates for large sites/allocations should be morerealistic and extended by at least 1 year if not 2.

and information from the sitepromoter/developer on expecteddelivery/build out rates. In a number of casesthe Council has taken a more pessimisticview of anticipated completions then the sitepromoter.

Noamendment.

Policy GS1 states that the housingrequirement is a minimum provision over theplan period, demonstrating the Council'sapproach to meeting the needs of the districtin full, as well as providing flexibility.

Housing requirements in plan should be viewed as minimumrequirement. To achieve this and provide flexibility a bufferof sites will provide greater opportunities for the plan to deliverits housing requirement. (including Home Builders Federation)

Provide 20% buffer of housing sites.In terms of the number/type of sites proposedfor allocation the Local Plan provides adegree of flexibility so that in the event sitesPara 10.32 indicates level of provision is 14.4% above the

District’s OAN but this includes provision for the previousshortfall in delivery. Ignoring the shortfall provision, the

do not come forward when anticipated ordeliver the yield expected the housingrequirement will be met.flexibility provided is actually only 7.5%. To meet housing

targets identified vital for the Council to be realistic about whatcan be delivered and when and that in order to deliver thenumbers envisaged will have to consider increasingallocations further, including the DIO land at Ripon. (DefenceInfrastructure Organisation)

Increase contingency allowance to closer to 20%.

In paragraph10.2 add newbullet point

It is agreed the site requirements shouldrefer to the AONB and that the design of newdevelopment should reflect its location withinthe AONB.

Natural England notes that the M8 , M13, P1, P5, P7, P10,BW9, BW10, DB5, DR1, DR14, KM4, KM5, SB1, SB5 havethe potential to have significant impacts on Nidderdale AONB.


12Delivery and Monitoring



We recommend that the AONB is specifically referred to inthe site requirements to ensure it is given the necessaryweight in decision making.

to read: 'Forsites locatedin the AONBbe designedto reflect theFurthermore we note that the Sustainability Appraisal identifies

that mitigation will be difficult in a number of cases, for theseallocations we advise that remedial, offsetting and

specialqualities ofthe AONB,compensation should be a requirement and that the wider

sustainability imperatives and alternatives should be set outin the assessment.

including theuse ofvernacularstyles andIn addition we advise that good design in relation to the special

qualities of the AONB is specifically referred to in therequirements, this should include the use of vernacular styles

materialswhereappropriate.'and materials where appropriate. We advise that you consult

the Nidderdale AONB Team and Joint Advisory Committeeregarding the assessment, design and mitigation for theseallocations (Natural England)

Noamendment.

The Infrastructure Capacity Study providesinformation on the capacity of existinginfrastructure to accommodate growth and

Little detailed information is provided on improving communityinfrastructure to support growth. Junction improvementsreferred to appear to be reaction to dealing with current neednot increased volume of traffic associated with plannedhousing.

the Infrastructure Delivery Plan (PublicationLocal Plan Appendix 3) identifies theinfrastructure necessary to deliver theplanned growth. Policy TI4 requires that thenecessary infrastructure is provided andavailable when needed.

The identified junction improvements willprovide additional capacity to accommodatethe planned levels of growth.

Noamendment.

The Local Plan inset maps do showcommitments, although only those sites thathad been promoted through the SHELAA.

Your maps of sites show detailed houses already in situ andproposed developments, but NOT those sites which havealready obtained planning permission but not yet completed(eg Beckwith Head Road). Thus it is difficult to obtain a trueview of what the area may look like when complete. Thismakes comments on your intentions very hard.

Local Plan mapping should show committed sites too.

Noamendment.

The approach has followed the NPPF andPPG whereby the national projections areused as a starting point with subsequent

Economic uplift applied to the housing need identified in thePublication Draft Local Plan is inflated and not required tomeet the needs of the District and results in an unattainable

increases in the OAN to deal with marketsignals, affordable housing need andeconomic growth.

5 year housing supply target. The growth strategy anddelivery plan identify housing allocations in areas which willnot enable sustainable development, in particular the ruralHarrogate to Pateley Bridge public transport corridor.(Hampsthwaite Action Group) The level of housing need is not above the

forecast level of economic growth but in linewith it.

The SA has assessed growth options andhas been updated to provide more detail ofthe process adopted.

The Harrogate District Local Plan SubmissionDraft August 2018 , Sustainability AppraisalVol.1/Vol.2 updated following PublicationDraft Consultation will be included in theExamination Library


Delivery and Monitoring 12



Noamendment.

The SA has been updated to provide astrengthened assessment of cumulativeimpacts.

The level of growth in Summerbridge and Dacre Banks willhave a significant and detrimental impact on thesecommunities.

The Harrogate District Local Plan SubmissionDraft August 2018 , Sustainability AppraisalVol.1/Vol.2 updated following PublicationDraft Consultation will be included in theExamination Library

The council has provided no supporting evidence of thepotential impact of the increased traffic caused by the potentialcumulative development in these rural villages and, togetherwith other housing allocations, on the wider Nidderdale AONB.The Harrogate District Transport Model reports from 2016and 2018 focus on the developments within the local townsin the region but do not consider the local impact of housingallocations in rural areas such as the Summerbridge andDacre Banks area, which are smaller in scale but where themagnitude of change could be more significant.

The sustainability appraisal is unsound as considerscumulative impacts of allocations for towns but not for ruralareas such as the Nidderdale AONB. This is a significantoversight given the significant and clustered housingallocations in Summerbridge and Dacre Banks

Noamendment.

Taken as a whole it is considered thepolicies of the Plan are positive in supportingthe rural economy.

There is no evidence to suggest how the local plan intendsto develop the rural economy to sustain the proposed housingcommitments and allocations and promote a sustainabletransport policy

The growth strategy seeks to managepatterns of growth to make the fullestpossible use of public transport, walking andcycling and focusing development inlocations which are or can be madesustainable.

Noamendment.

The level of development allocated toPannal is considered to be commensuratewith its role as a Primary Service Village.

Object to overall level of development proposed for Pannalwhich will overwhelm transport network and will harmsustainability of school. Development proposed to thesouthern edge of Harrogate will exacerbate these problemsfurther.

Traffic modelling work undertaken indicatesthat with mitigation traffic generated fromdevelopment can be accommodated. Theimpact of development on communityfacilities would be considered under PolicyTI4 (Delivery of New Infrastructure), includingappropriate mitigation mitigation if required.

Noamendment.

Darley sits within one of the District's keypublic transport corridors and in deciding tomake allocations in Secondary Service

Question whether there is any market for the housesproposed. Darley has no employment so people will need tocommute as the bus service is not adequate or sustainable.Negative impacts on local roads and traffic. Villages, the Council has given consideration

to meeting the local and affordable housingneeds of communities. The potential for newRemove the proposed site allocations DR14 and DR1 as they

represent clear over-development of a secondary servicevillage and are inappropriate in the AONB.

development to have an impact on thecharacter of the village and whether anyimpact could be mitigated has been carefullyconsidered in identifying sites for allocation

Proposed allocations in Darley are in conflict with Draft PolicyGS3, GS8 and NE4 and bear no relationship to the existingpattern of development in the village. Development of thescale proposed in Darley would fundamentally change thecharacter of the settlement. (Darley and Menwith ParishCouncil)





More appropriate to direct development towards otherSecondary Service Villages which are not the subject ofrestrictive planning designations.

Table 12.1 Key Issues: Delivery and Monitoring General

DM1: Housing Allocations

Policy DM1: Housing Allocations


N/ANotedSupport (Respondents include NYCC)

No amendment.The SA recognises that the loss of playingfields will require mitigation in accordance withPolicy HP6, and informed by the most recent

Allocations H16, H36 and R25 all impact onplaying fields (although only site H16 mentionsplaying fields on site) but allocations have not

evidence available. In the case of site R25 therebeen justified by up to date evidence and ifreplacement provision is required this couldaffect the delivery of the sites (Sport England)

is the potential to retain facilities on site as partof the comprehensive redevelopment of the site(along with sites R24 and R27).

It should be noted that site H36 is the subjectof a current planning application (there is aresolution to permit subject to completion of aS106 agreement) which considered the issueof the loss of the playing fields.

No amendment.It is necessary to disaggregate the two asplanning commitments have received formalplanning consent whilst allocations still need toobtain planning permission and thereforecomply with the site requirements.

No rationale for disaggregating the allocationsand commitments within the Policy since all ofthese sites have been judged suitable andachievable over the plan period.

Generic Site Requirements


At end of bullet point 5add: 'These shouldinclude consideration of

Agree.In para 10.2, bullet point 5 add reference totransport assessments including considerationof impact of traffic/pedestrian movements onrailway crossings and other rail infrastructure(Network Rail).

the impact oftraffic/pedestrianmovements on railwaycrossings and other railinfrastructure wherenecessary.'

No amendment.It is considered appropriate to highlight the keymatters to be addressed in developingproposals for the allocated sites.

Generic site requirements could be condensedinto having Requirement 1 only as remainingrequirements repeat developmentmanagement policies in the Local Plan.

Table 12.2 Key Issues: General/Generic site requirements

Omission Sites/Place Specific Issues

Harrogate

No amendment.The council has allocatedsufficient deliverable anddevelopable housing sites to

Land at Penny Pot Lane, Harrogate (site H1) should beallocated:




meet the housing requirementand an additional buffer toprovide flexibility over the plan

Sustainability Appraisal of site does not takeaccount of consented scheme to north of site,which represents a significant material change incircumstance which should trigger are-assessment

period and, as such, does notconsider the allocation ofthese sites is needed.

location consistent with growth strategy

no technical reasons that would precludedevelopment

Land off Leeds Road, Harrogate (site H8) should beallocated:

site not fairly assessed in context of errors raisedthrough previous representations

location of site accords with growth strategy

no technical constraints to development - highwaysassessment demonstrates site can be safelyaccessed and not result in detriment to localhighway network

potential to deliver biodiversity improvements

compares favourably to sites proposed forallocation

Land at Nitter Hall, Harrogate (site H13) should beallocated:

Main settlements capable of delivering morehousing than plan preparing for

SHELAA acknowledges site has developmentpotential, propose development for lower numberof dwellings to address site constraints

Site well located, in close proximity to shops andservices

Any landscape impacts can be mitigated

Land at Bogs Lane/Kingsley Road, Harrogate (part ofsite H24) should be allocated:

smaller parcel of land should have been assessed

adjoining sites have planning permission or areproposed allocations demonstrating site is insustainable location for development

identification as SINC unjustified

Land at Burley Bank Road, Harrogate (site H32) shouldbe allocated:

site area promoting is significantly less than thatassessed by Council




development would assist in obtaining andretaining social and community facilities in thisarea of Harrogate

compares well to other sites in sensitive locationsaround Harrogate and Knaresborough

Land at Penny Pot Lane, Harrogate (site H34) shouldbe allocated:

logical extension to built form

location of site fits with strategy of GS2

promoting reduced site area with yield of 350dwellings, potential to deliver some houses inyears 1-5 of plan

Site west of Yew Tree Lane, Harrogate (H52) shouldbe allocated:

borders site subject of current planning applicationfor residential development (H36)

land to north is within allocation H70 and sitewould be appropriate rounding off

Land at Phase 3 Skipton Road, Harrogate (site H59)should be allocated:

consistent with growth strategy

has been inconsistent approach to allocations,number of sites allocated which have greaternumber of negative attributes in SustainabilityAppraisal than site H59

Land at Rossett Green Lane, Harrogate should beallocated:

location on edge of main settlement consistentwith spatial strategy

accessible to services and facilities

previously considered by officers as a suitable forresidential development

Willing landowner and developer

The Gas Works site, Ripon Rd should be allocated forhousing as its close to facilities and public transport.

Land at Fulwith Grange, Harrogate would be consistentwith spatial strategy, no constraints affectingdevelopment of site.

No amendment.The NPPF is clear that GreenBelt boundaries should onlybe altered in exceptional

Land at Longlands Farm, Harrogate (site H10) shouldbe allocated:

Main settlements capable of delivering morehousing than Plan is preparing for circumstances. TheGreen Belt

Background Paper 2018 setsout the reasons why the




council has concluded that itdoes not need to undertake aGreen Belt review in order to

Should not be dismissed by virtue of Green Beltlocation, ‘urban fringe’ landscape

meet the emerging planShould be seen in context of long term vision forimproved transport links within the area requirements in a way that

represents sustainabledevelopment. The government

Land at Forest Head Farm, Bogs Lane, Harrogate (siteH11) should be allocated:

has re-iterated its commitmentto the protection of the GreenBelt in the Housing WhiteMain settlements capable of delivering more

housing than Plan preparing for Paper. In this they make clearthat Green Belt boundariesshould only be amendedShould not be dismissed by virtue of Green Belt

location, ‘urban fringe’ landscape where exceptionalcircumstances can bedemonstrated having exploredall other reasonable options.Should be seen in context of long term vision for

improved transport links within the area

The council's position remains,therefore, that as there areother options for meeting

Land at Forest Lane, Harrogate (site H39) should beallocated:

development needs in theMain settlements capable of delivering morehousing than plan preparing for district, exceptional

circumstances to trigger aGreen Belt review cannot bedemonstrated.‘urban fringe’ landscape

Green Belt on eastern side of Harrogate shouldbe rolled back

Land at Henshaws College, Harrogate should beallocated for a mix of specialist housing and to providecross subsidy an element of market housing.

Land between Maple Close and Fairways Avenue,Harrogate (site H79) is available, suitable and deliverablefor housing development.

Knaresborough


Land at Hay-a-Park, Knaresborough (K15) should beallocated:

Main settlements capable of delivering morehousing than Plan preparing for meet the housing requirement

and an additional buffer toprovide flexibility over the planCould be developed in conjunction with site K20period and, as such, does notconsider the allocation ofthese sites is needed.

Do not agree with SHELAA assessment of site

Land at Hay-a-Park, Knaresborough (site K20) shouldbe allocated:

Main settlements capable of delivering morehousing than Plan is preparing for

Strategic location, north of permitted Manse Farmdevelopment. Other areas of Knaresboroughsubject to constraints

Accessible to services and facilities inKnaresborough

Land at Bar Lane, Knaresborough (K27) should beallocated:




uncertainty over delivery of new settlementrequires additional allocations to provide flexibilityto meet housing needs

logical location for development following build outof adjacent site

proximity of SSSI should not act as constraintsubject on appropriate mitigation

Identified supply in Knaresborough is heavily reliant ondelivery of larger sites. Need for smaller allocations.

Land at Ripley Road and Preston Bottoms Lane shouldbe allocated:

adjacent built form of settlement

good access to local services/facilities

not within protective landscape designations

No AmendmentThe NPPF is clear that GreenBelt boundaries should onlybe altered in exceptional

Land at Forest Moor Road, Calcutt (site K16) should beallocated:

should not be dismissed because in Green Belt,it is an urban fringe location circumstances. TheGreen Belt

Background Paper 2018 setsout the reasons why theaccessible locationcouncil has concluded that itdoes not need to undertake ano great landscape impact due to surrounding

existing development Green Belt review in order tomeet the emerging planrequirements in a way that

Land at Forest Moor Road, Calcutt (site K19) should beallocated:

represents sustainabledevelopment. The governmenthas re-iterated its commitmentShould not be dismissed on basis that within

Green Belt, ‘urban fringe’ landscape to the protection of the GreenBelt in the Housing WhitePaper. In this they make clear

Sustainable location that Green Belt boundariesshould only be amendedwhere exceptionalFailure to provide variety of site sizes to provide

opportunity for both small and large developers. Smallsite at Thistle Hill Nurseries, Knaresborough should beallocated for housing.

circumstances can bedemonstrated having exploredall other reasonable options.

The council's position remains,therefore, that as there areother options for meetingdevelopment needs in thedistrict, exceptionalcircumstances to trigger aGreen Belt review cannot bedemonstrated.

Ripon


Land at Bellwood Farm, Ripon (R3) should be allocated:logical extension to built form

meet the housing requirementpromoting reduced site area (reflecting pendingoutline planning application) and an additional buffer to

provide flexibility over the plan





one of least constrained sites around edge ofRipon.

site investigation work in respect of Gypsumsuggests reduced site area could fall wholly withinZone A

Land at Hutton Road, Ripon (site R4) should beallocated:

Main settlements capable of delivering morehousing than Plan is preparing for

SHELAA acknowledges development potential ofsite

Well connected to existing built form of settlement,‘urban fringe’ landscape

Land at Tower Road/North Street, Ripon (site R7) shouldbe allocated:

will be natural infill within settlement developmentlimit

accessible to range of services and facilities

have objected to designation of site in draft RiponCity Plan as local green space on grounds thatdoes not meet criteria for designation

Land at Studley Road, Ripon (site R9) should beallocated:

located in highly accessible area

urban fringe landscape

Land at Hutton Bank, Ripon (R10) should be allocated:brownfield site, underused with negativeenvironmental impact

reason for allocating site that need to retain sitein employment use is not consistent with approachto allocation of site R27 which is an existingemployment site

site has not proved attractive to employment uses

not suited to employment use due to proximity toexisting housing: commercial use recently ceaseddue to complaints raised and intervention by HBCEnvironmental Health

Land at Snow Close Farm, Ripon (site R13) should beallocated:

constraints identified in Sustainability Appraisalcan be mitigated

site is as sustainable as nearby proposedallocations and not clear why these sites havebeen allocated




location within an area susceptible to Gypsumdoes not preclude development subject to criteriain Policy NE9 being addressed

need for additional housing land to be identified

Land at Kirkby Road, Ripon (site R15) should beallocated.

Land at Princess Road, Ripon (site R26) should beallocated:

Main settlements capable of delivering morehousing than Plan preparing for

SHELAA acknowledges development potential ofsite

Accessible location to services and facilities

Mitigation measures could be incorporated to dealwith presence of Gypsum

Land at Ripon Rugby Club should be allocated:identified as suitable for development in draftRipon City Plan

accessible to services and facilities and close tocity centre

within existing built form of Ripon

Land off Bishopton Lane, Ripon should be allocated:accessible to services and facilities

Willing landowner and developer

no constraints to development

Boroughbridge


Land at Roecliffe Lane, Boroughbridge (site B3) shouldbe allocated:

logical extension to settlementmeet the housing requirementand an additional buffer toreduced developable area to address

archaeological contraints provide flexibility over the planperiod and, as such, does notconsider the allocation ofthese sites is needed.

potential for public benefit through creating publicaccess to heritage asset which does not presentlyexist

Land at Three Arrows Field, Boroughbridge (northernpart of site B14) should be allocated:

development would be rounding off




accessible location

limiting development to northern part would ensureappropriate relationship to standing stones to thesouth

Masham


Masham Auction Mart (site M14) should be allocatedfor housing.

meet the housing requirementand an additional buffer toprovide flexibility over the planperiod and, as such, does notconsider the allocation of thissite, which does not compareas favourably to other sitesassessed and identified asallocations, is needed.

Pateley Bridge

No amendment.The council considers thatsufficient deliverable anddevelopable housing sites to

Flooding issues identified in SFRA (January 2018) asaffecting land at the Coal Yard, Pateley Bridge (site P12)capable of being addressed: surface water flooding is

meet the housing requirementconsequence of run-off from third party land to the eastand in process of resolving matter. Exclusion of siteshould be reassessed.

and an additional buffer toprovide flexibility over the planperiod have been allocated inthe Plan and, as such, doesnot consider the allocation ofthis site is needed.

However, as a brownfield sitewithin the Pateley Bridgedevelopment limit, the sitecould come forward fordevelopment without it beingallocated in the Local Plan.

Birstwith


Land at Wreaks Road, Birstwith (site BW3) should beallocated:

limiting allocations fails to recognise status ofsettlement, provide mix of site sizes or provide netpositive community benefit

meet the housing requirementand an additional buffer toprovide flexibility over the planperiod and, as such, does notconsider the allocation of thissite is needed.

allocation of site would provide secured communityuse and improved school facilities on widerlandholding

scale and layout could minimise any perceivedharm to AONB unlike proposed allocations

Bishop Thornton


Allocate land at Colber Lane, Bishop Thornton.Site comprises St Joseph's Catholic PrimarySchool (Closed 2016) and adjacent agriculturalland. meet the housing requirement

and an additional buffer to




provide flexibility over the planperiod and, as such, does notconsider the allocation of thissite is needed.

Site originally submitted in 2015 (ref: BT1) andsubsequently updated to include the school.

Presents an opportunity to plan positively for thissite, which is in the heart of the village.

Burton Leonard


Land off Scarah Lane, Burton Leonard (BL1) should beallocated:

site was proposed for allocation in Sites andPolicies DPD and no changes in circumstancesto justify different conclusion now being reached

meet the housing requirementand an additional buffer toprovide flexibility over the planperiod and, as such, does notconsider the allocation ofthese sites is needed.

consider development would not lead to anysignificant adverse landscape impact

help deliver affordable housing for which there isa significant need

Land at Station Lane (site BL3) should be allocated:no significant harm to heritage assets

committed landowner/developer to bring siteforward

not subject to designations or technical constraintsto development

Land west of High Peter Lane, Burton Leonard (siteBL4) should be allocated:

do not agree with conclusion of SHELAAassessment that Lane is unsuitable to provideaccess, potential for additional access throughBurnett Close

Land east of High Peter Lane, Burton Leonard (site BL5)should be allocated:

do not agree with conclusion of SHELAAassessment that Lane is unsuitable to provideaccess, potential for additional access throughBurnett Close

Land at Church Lane, Burton Leonard (site BL6) shouldbe allocated:

should be some natural growth to support services

logical site for development

Land adjacent the Cemetery, Church Land, BurtonLeonard (site BL7) should be allocated:

SHELAA acknowledges site has developmentpotential

sustainable village for development

not allocated any preferred sites in Burton Leonard




Land at Copgrove Road, Burton Leonard (siteBL8) should be allocated:


SHELAA identifies site as being suitable fordevelopment

no technical constraints to development

subject of pending outline planning application

Darley


Land at Main Street, Darley (site DR10) should beallocated:

SHELAA acknowledges development potential ofsite meet the housing requirement

and an additional buffer toprovide flexibility over the planVillage is sustainable location for developmentperiod and, as such, does notconsider the allocation ofthese sites is needed.

Relates well to existing built form of development

Land at Cherry Tree Farm, Darley (site DR13) shouldbe allocated for housing:

planning permission for 18 dwellings on northernpart of site

development of southern part of site should beseen in context of change to landscape characteras consequence of development of proposedallocation DR14

allocation of all of site DR13 would allow foralternative vehicular access to DR14, as knownproblems with securing access from SheepcoteLane

Dishforth

No amendment.It is considered premature tomake reference to this site inthe manner suggested given

As Dishforth Airfield expected to be disposed of by 2031,within plan period, Local Plan should plan for release ofthis significant strategic site. Local Plan should set outopportunities for development and clear policies on whatwill or will not be permitted and where (NPPF para 154).

any development potential ofthe site is unlikely to berealised until the very end orbeyond the current planperiod. Para 3.17 of the LocalPan already references thatconsideration of thedevelopment potential of theAirfield would be undertakenas part of any future planreview.

Goldsborough


Land at Station Road, Goldsborough (site GB3) shouldbe allocated:




meet the housing requirementand an additional buffer toprovide flexibility over the plan

Development would be continuation of lineardevelopment along Station Road

period and, as such, does notconsider the allocation of thissite is needed.

Settlement could accommodate more growth thanthat from proposed allocated site, which wouldsupport local shops and services

Great Ouseburn


Land at Branton Lane, Great Ouseburn (part of siteGO2) should be allocated:

site is suitable for developmentmeet the housing requirementand an additional buffer toplanning application currently pending and council

is supportive of principle of development on site provide flexibility over the planperiod and, as such, does notconsider the allocation ofthese sites is needed.Land north of Branton Lane, Great Ouseburn (southern

part of site GO2) should be allocated:location of site accords with growth strategy

in promoting only southern part of site GO2scheme can be designed which would not resultin harm to conservation area or protected trees

Green Hammerton

No amendment.The application has beenapproved subject tocompletion of S106 andtherefore the allocation of thissite is needed.

Land north of York Road, Green Hammerton (site GH6)is subject of pending outline planning application, whichexpect to be recommended for approval. Thereforeappropriate for site to be included as allocation with yieldof 80 dwellings.


No opportunities for small housebuilders to participatein local housing market in Green Hammerton. Land atBack Land and Yule Lane (site GH7) would provideopportunity for a modest development: meet the housing requirement

and an additional buffer toinconsistent assessment of landscape andheritage when compared to that of proposedallocation site GH2, which is located in closeproximity to site GH7

provide flexibility over the planperiod and, as such, does notconsider the allocation ofthese sites is needed.

Land west of Elms House Farm, Green Hammerton (siteGH14) should be allocated:


makes use of partial previously developed site

Hampsthwaite


Land at Hollins Farm, Hampsthwaite (HM3) should beallocated:

Site previously discounted due to access issues.Now have promotional agreement in place inrespect of The Maltings, immediately west ofexisting field access onto Hollins Lane, enablingsuitable site access to be created.

meet the housing requirementand an additional buffer toprovide flexibility over the planperiod and, as such, does notconsider the allocation ofthese sites is needed.No significant harm to any heritage asset unlike

other housing allocation options.




Land in Hampsthwaite (HM4/HM5) should be allocated.Subject of recent planning applications/appeal.

Hampsthwaite appropriate site for further developmentand land to west of Hollins Lane, Hampsthwaite (siteHM10) should be allocated as an additional housing site.

Killinghall


Land at Ripon Road, Killinghall (site KL3) should beallocated:

Logical site for developmentmeet the housing requirementand an additional buffer toSite could be developed so as to protect areas of

landscape value provide flexibility over the planperiod and, as such, does notconsider the allocation ofthese sites is needed.Land at Otley Road, Killinghall (site KL5) should be

allocated:uncertainty over delivery of new settlementrequires additional allocations to provide flexibilityto meet housing needs

undertaken review of SLA which recommends sitebe removed from SLA

development focused on northern portion of sitewith landscape buffer and planting to south toreinforce physical and visual separation betweenKillinghall and Harrogate

Land at Daleside Nurseries, Killinghall (site KL7) shouldbe allocated for housing.

Kirby Hill


Land at Church Banks, Kirby Hill (KB6) should beallocated:

potential for further growth to be directed to KirbyHill meet the housing requirement

and an additional buffer toprovide flexibility over the planno showstoppers to development that could not

be dealt with through mitigation period and, as such, does notconsider the allocation of thissite is needed.

Kirby Malzeard


Land at Ripon Road, Kirkby Malzeard (site KM3) shouldbe allocated:

Extension of existing built form of villagemeet the housing requirementand an additional buffer toSustainable village for developmentprovide flexibility over the planperiod and, as such, does notconsider the allocation of thissite is needed.

Landscape not high quality when considered incontext of other landscapes within area

Kirkby Overblow


Land at Ivy Farm, Kirkby Overblow should be allocated:without allocations, services and facilities in villagemay come into question

circumstances. TheGreen BeltBackground Paper 2018 sets




out the reasons why thecouncil has concluded that itdoes not need to undertake a

partly brownfield site

no showstoppers that could not be dealt with bymitigation or scheme design Green Belt review in order to

meet the emerging planrequirements in a way thatrepresents sustainabledevelopment. The governmenthas re-iterated its commitmentto the protection of the GreenBelt in the Housing WhitePaper. In this they make clearthat Green Belt boundariesshould only be amendedwhere exceptionalcircumstances can bedemonstrated having exploredall other reasonable options.


Long Marston


Land atWetherby Road, LongMarston (site LM1) shouldbe allocated:

Should be removed from Green Belt to provideinfill opportunity circumstances. TheGreen Belt

Background Paper 2018 setsout the reasons why theSustainable village for developmentcouncil has concluded that itdoes not need to undertake a

Despite being a Secondary Service Village noallocations in Long Marston. Inclusion of land south ofWetherby Road (site LM3), which is supported by Parish

Green Belt review in order tomeet the emerging planrequirements in a way thatrepresents sustainableCouncil and south of B1224 (site LM4) would provide

new homes to support continued sustainability of villageservices.

development. The governmenthas re-iterated its commitmentto the protection of the Green

Land adjacent Tockwith Road, Long Marston (LM2)should be allocated for 100% affordable housing.Withoutnew housing in village, primary school will beunsustainable.

Belt in the Housing WhitePaper. In this they make clearthat Green Belt boundariesshould only be amendedwhere exceptionalcircumstances can bedemonstrated having exploredall other reasonable options.


Markington




Amend the boundary ofcommitment MK9 to reflect thearea of planningpermission 17/02938/FULMAJ.

The site is shown on theMarkington Policies Map iscorrectly shown as a planningcommitment but it is agreed

Boundary of site MK9 should be amended to reflect areaof planning permission 17/02938/FULMAJ

that on the map includedunder Policy DM1/MK8 theboundary does not fully reflectthe area which benefits fromplanning permission.

Marton cum Grafton


Allocate land known as MG5 Reas Lane, Marton cumGrafton

Land at Prospect Farm, Marton cum Grafton should beallocated:

meet the housing requirementand an additional buffer to

assessed by SHELAA as having developmentpotential

provide flexibility over the planperiod and, as such, does notconsider the allocation of thissite is needed.more appropriate site than those allocated in Local

Plan

North Rigton


Should be more robust approach to housing deliveryand lack of any housing allocation in North Rigton shouldbe addressed with allocation of land at Bracken Lodge.

circumstances. TheGreen BeltBackground Paper 2018 setsout the reasons why thecouncil has concluded that itdoes not need to undertake aGreen Belt review in order tomeet the emerging planrequirements in a way thatrepresents sustainabledevelopment. The governmenthas re-iterated its commitmentto the protection of the GreenBelt in the Housing WhitePaper. In this they make clearthat Green Belt boundariesshould only be amendedwhere exceptionalcircumstances can bedemonstrated having exploredall other reasonable options.


North Stainley


Two landowners have sites in North Stainley in the planNS3 and NS6. The owner of NS3 has put forward anambitious plan for the extensive development of the

meet the housing requirement




and an additional buffer toprovide flexibility over the planperiod and, as such, does notconsider the allocation ofthese sites is needed.

whole village which excludes NS6 but includes his ownNS2, 4 and 5 along with NS3. This has two possibleoutcomes:

1) The council allows the extra sites. In this event, NorthStainley will bear a disproportionate amount ofdevelopment by comparison to other villages. NorthStainley lies towards the outer rural edges of the districtand has very limited transport links and infrastructure tosupport an almost 70% increase in houses and 120retirement dwellings, a total growth of 110%

2) Harrogate Borough Council continues to exclude sitesNS2, 4 and 5. Given that the landowner of NS3 issuggesting that his is an over-arching, all-or-nothing plan,it follows that NS3 and NS7 will not be deliverable.

The allocations for North Stainley (with the possibleisolated exception of NS6) are unsound on grounds ofdeliverability (effectiveness), meeting housing need(positively prepared) or appropriateness to this part ofthe district.

All 5 sites in North Stainley should be allocated - notjust those allocated in the Publication draft plan - toensure that a self sustaining community can be createdincluding an improved, safer primary school. Leaving outthese sites (NS2, NS4, NS5) undermines and diminishesthe value of NS3 and NS7.

A significant amount of time and planning has beeninvested in determining the optimum outcome out of theminimum sites at North Stainley. If the village is to sustainitself and fit with the bigger picture of village life survivalin our country, as the Government promote, then NS5,NS4 and NS2 should be included.

NS2 should be allocated. The proposed developmentof extra care/retirement housing is proposed to addressan identified need for this type of housing in the districtand increase housing delivery.

NS2 scored similarly to NS6 in the SA, but NS2 wasmarked down in relation to 'loss of trees which cannotbe fully mitigated and a 'high landscape sensitivity/lowcapacity. The site is no more sensitive than NS6.Question whether appropriate methodology has beenconsistently applied.

NS5 should be allocated - it is a suitable location fordevelopment and is available and achievable.

Sicklinghall


Local Plan should recognise development potential ofwhole of Diary Farm, Sicklinghall and opportunity toprovide small housing development of between 8-10units. circumstances. TheGreen Belt

Background Paper 2018 setsout the reasons why theLand at Back Lane, Sicklinghall provides opportunity to

provide small scale housing development, rounding offsouthern edge of village.

council has concluded that itdoes not need to undertake aGreen Belt review in order to




meet the emerging planrequirements in a way thatrepresents sustainabledevelopment. The governmenthas re-iterated its commitmentto the protection of the GreenBelt in the Housing WhitePaper. In this they make clearthat Green Belt boundariesshould only be amendedwhere exceptionalcircumstances can bedemonstrated having exploredall other reasonable options.


Sharrow


Land north of Dishforth Road, Sharrow (SH2) shouldbe allocated:

constraints identified in Sustainability Appraisalcan be mitigated meet the housing requirement

and an additional buffer toprovide flexibility over the plansite is as sustainable as nearby proposed

allocations and not clear why these sites havebeen allocated

period and, as such, does notconsider the allocation of thissite is needed.

need for additional housing land to be identified

Skelton on Ure


Land south of CrowGarth, Skelton on Ure (SU1) shouldbe allocated:

Policy GS2 suggests that as identified as SmallerService Village, should accommodate appropriatelevel of development

meet the housing requirementand an additional buffer toprovide flexibility over the planperiod and, as such, does notconsider the allocation of thissite is needed.

development limits are drawn too tightly sodevelopment unlikely to come forward as windfalls

Spofforth


Land adjacent to Hall Cottages, Spofforth providesopportunity to provide small housing scheme on edgeof sustainable village.

circumstances. TheGreen BeltBackground Paper 2018 setsout the reasons why thecouncil has concluded that itdoes not need to undertake aGreen Belt review in order tomeet the emerging planrequirements in a way thatrepresents sustainabledevelopment. The government




has re-iterated its commitmentto the protection of the GreenBelt in the Housing WhitePaper. In this they make clearthat Green Belt boundariesshould only be amendedwhere exceptionalcircumstances can bedemonstrated having exploredall other reasonable options.


Staveley


Land at Main Street, Staveley (SV2) should be allocated:concentrating housing in a large allocation(SV1) is disproportionate to settlement and couldhave implications if delivery delayed meet the housing requirement

and an additional buffer toprovide flexibility over the plansite is located adjacent built form of

settlement/logical extension period and, as such, does notconsider the allocation of thissite is needed.impacts on heritage asset can be addressed

Summerbridge

No amendment.It is considered that inaddition to the allocationsmade windfall development

Support allocations that have been made inSummerbridge but consider further land should beallocated, this would be broadly proportionate withprovisions of Policy GS2. and rounding off will provide a

level of new development thatis commensurate with the roleand character of the village.

Land off Riggs Lane, Summerbridge should be allocatedfor housing. Site is in suitable location and small numberof constraints can bemitigated through appropriate layoutand design.

Tockwith


Land at Fleet Lane, Tockwith (site TW5) should beallocated:

SHELAA acknowledges site has developmentpotential meet the housing requirement

and an additional buffer toprovide flexibility over the plansite is well connected to built form of settlementperiod and, as such, does notconsider the allocation ofthese sites is needed.Land at Tockwith Airfield (site TW8) should be allocated:


makes use of previously developed site and shouldbe considered ahead of new settlements ongreenfield sites

promoting extended site capable of delivering1,000 dwellings, primary school, public open space




Land at Tockwith West (TW11) should be allocated:brownfield site

logical extension to village

site could come forward in the short term

Given recognition of appropriateness of TW7,conclusions of SHELAA in respect of TW13 and itslocation within Tockwith development limit, appropriateto allocated site in its entirety for housing.

Land at Blind Lane, Tockwith (site TW9) should beallocated:

Do not agree with SHELAA assessment that sitehas no access to adoptable highway

Sustainable village for development

Development would appear in context ofbusinesses along Blind Lane and would not beisolated

Other Settlements


Land at Holgate Grange,Arkendale should be allocated:no insurmountable constraints to development

meet the housing requirementlandowner committed to development of siteand an additional buffer toprovide flexibility over the planallocation of site would ensure and safeguard

certainty of delivery of small scale, immediatesites, encouraging sustainable growth in rurallocations


Land at The Hill, Baldersby should be allocated:development has potential to contribute tosustainability of rural area and existing localservices

no insurmountable constraints to developmentidentified

Land at Tom Cat Lane, Bickerton (BC1) should beallocated:

failure to identify any housing sites in Bickertondoes not represent positive planning

SHELAA assessed site positively

within built up area of village

small scheme of around 5 dwellings would beappropriate

no impediments to development

Land at Copgrove (site CP2) should be allocated:




Do not agree with SHELAA assessment thatsuitable access cannot be achieved

Development would round off village

Services available in nearby settlements

Land at Corner Farm, Cowthorpe (site CW1) shouldbe allocated:

SHELAA acknowledged site had developmentpotential

Well connected to existing built form of settlement

Accessible settlement

Land at Warfield Lane, Cowthrope (site CW2) shouldbe allocated:

development has potential to contribute tosustainability of rural area and existing localservices

no insurmountable constraints to developmentidentified

subject to pending outline planning application

Land to rear of The Old Crown, Farnham offersopportunity to provide small housing scheme. Site is wellrelated to existing built form of village and no technicalreason for development not to proceed.

Land at Harrogate Road, Ferrensby (site FR1) shouldbe allocated:


Would allow for some natural growth to supportlocal amenities

Land at Moor Lane, Ferrensby (site FR3) should beallocated:


would allow some natural growth of settlement tosupport local amenities

sustainable village for development

Land at Hagworth Lane, Ferrensby (site FR5) shouldbe allocated:


Well connected to existing built form of village

Village is accessible to services and employmentopportunities in nearby villages




Land at east of Harrogate Road, Ferrensby (site FR7)should be allocated:

Development of site would allow for natural growthof village, supporting local shops and serviceswhich can be found in nearby settlements

Site well located in context of rest of village

Land at Flaxby (site FX2) should be allocated:SHELAA acknowledged site had developmentpotential subject to mitigation

Flaxby is sustainable village for development


Land at Weeton Lane, Dunkeswick (site DK1) shouldbe allocated:

Site should be removed fromGreen Belt to provideinfill opportunity circumstances. TheGreen Belt

Background Paper 2018 setsout the reasons why theSustainable village for development with services

and facilities available in nearby village council has concluded that itdoes not need to undertake aGreen Belt review in order to

Land at Hawthorne House Farm, Dunkeswick (site DK2)should be allocated:

meet the emerging planrequirements in a way thatrepresents sustainableShould be removed from Green Belt to provide

infill opportunity development. The governmenthas re-iterated its commitmentto the protection of the GreenSustainable village for developmentBelt in the Housing WhitePaper. In this they make clear

Four sites in Follifoot (FF2, FF3, FF4 and FF10) shouldbe allocated. Sites are sustainably located in settlementwhere growth is supported. Site FF10 was previouslyidentified by Council as preferred affordable housing site.

that Green Belt boundariesshould only be amendedwhere exceptionalcircumstances can bedemonstrated having exploredall other reasonable options.



Land at Newholme Farm, Grewelthorpe (site GW5)should be allocated:

Sustainable village for developmentmeet the housing requirementand an additional buffer toRelates well to existing built form of settlementprovide flexibility over the planperiod and, as such, does notconsider the allocation ofthese sites is needed.

Landscape not of high quality when compared toothers within area

Land at Hopperton Street,Hopperton (site HP5) shouldbe allocated:

do not agree with conclusion of SHELAAassessment on achieving site access




infill site, continuing linear development of village

services available in nearby villages

Former service station,Kirk Deighton (site KD7) shouldbe allocated as it is a brownfield site.

Land west of Wetherby Road (site KD4) should beallocated. Sustainable and logical opportunity tocontribute to meeting housing needs. Allocation of sitewould create defensible boundary to south of settlement.

Land to rear of Kilburn, Littlethorpe (R3) should beallocated:

selection process to determine which sites shouldbe allocated lacks clarity. Appears to have beenundertaken on subjective basis based on numberof red scores scored against sustainabilityobjectives

methodology for choosing sites for allocationthrough Sustainability Appraisal (SA) is not justifiedand therefore unsound. SA tables do not provideclear and cogent basis to enable meaningfulcomparisons to bemade on environmental impactsof each site. Renders the process outside of theRegulations. Importance of this point confirmedby High Court in Save Historic Newmarket Ltd andothers v Forest Heath DC et al. Tables fail toidentify how choices have been made and thushow they may be understood by the public


SHELAA assessment concluded that the site issuitable, available and achievable and 'could' bedeveloped

Sufficient deliverable sites should be identified sothat in event new settlement does not deliverdwellings to end of plan period the housing needcan be met

Case for providing somemodest housing growth in LittleRibston. Land south of Wetherby Road could provide5 dwellings:

development would be consistent with existingribbon development

site is of low ecological value

Land at Chapel Lane, Marton-le-Moor (ML1) shouldbe allocated:

principle of development supported under previousplanning applications

no technical constraints to development

to address concerns relating to impact oncharacter of area only part of site could beallocated




SHELAA concluded site would be suitable locationfor development

Sustainability Appraisal of site generally positive

Land at Melmberby Green Lane (site MB1),Melmberbyshould be allocated:

SHELAA acknowledges development potential

Development of site would allow for natural growthof village, supporting local shops and services

The former Middleton Hospital Site (site OC6) shouldbe allocated:

brownfield site so redevelopment is not consideredinappropriate development in the Green Belt

Land west of A168 (site OC7) should be allocated:brownfield site

development would improve site and surroundings

amenities available in Kirk Deighton, 0.5 miles tosouth west

Land at Ripley Road, Bedlam (site OC9) should beallocated:

Sustainability Appraisal assessment of site is notsupported by evidence and therefore unjustified

Village is accessible to services in nearby villages

No amendment.Whilst the Local Plan is notmaking allocations in smallervillages this site benefits fromoutline planning permission for3 dwellings.

Land at Church Lane, Rainton (site RN5) should beallocated:

Sustainable appraisal states site is deliverablewith mitigation

Sustainable village for development


Land at Low Lane, Scotton (site SC4) should beallocated:

Would relate to existing built form of villagemeet the housing requirementand an additional buffer toSustainable village for developmentprovide flexibility over the planperiod and, as such, does notconsider the allocation of thissite is needed.

Land east of the A61, South Stainley (site SS1) shouldbe allocated:


South Stainley would benefit from natural growth

Land at Spofforth Hill, Wetherby (WB1) should beallocated:




methodology for choosing sites for allocationthrough Sustainability Appraisal (SA) is not justifiedand therefore unsound

sustainable site located on a public transportcorridor

Land atWormald Green (siteWG1) should be allocated:SHELAA acknowledges development potential ofsite

Village would benefit from natural growth to helpsupport local shops and services, which can befound in nearby settlements

Table 12.3 Key Issues: Omission Sites

Harrogate Sites



No amendmentHarrogate is one of the district's main urbanareas and arguably the most sustainable and,therefore, it is appropriate that the Local Plan

Tests of soundness (West Harrogate)

Not positively prepared - infrastructure tosupport 6000 homes in West Harrogatehas not been provided

growth strategy should include a significantelement of new development for Harrogatereflective of its role. Traffic modelling work andliaison with infrastructure providers has indicatedthat the level of new development proposedcan, with mitigation be accommodated.

Not justified - evidence of housing needis contradictory - new settlement shouldbe provided instead of housing at WestHarrogate

In line with Government policy, all majordevelopments will be expected to deliver a mixof housing, including Starter Homes and otheraffordable housing tenures.

Not effective - low cost housing will notbe provided because of market forces

Not consistent with national policy -developments in West Harrogate are notsustainable and not in alignment withNPPF

The scale of development inWestern Harrogateis unsustainable given the existing capacityconstraints on the highway network. The planfails to provide an effective method for dealingwith this or the increased traffic that the plan willcreate.

Table 12.4 Key Issues: Harrogate sites general

H2: Land North of Knox Lane, Harrogate



N/ANoted.Support

Reasons do not support allocation of site:





No amendmentThere is an identified residual housingrequirement to be delivered during the planperiod (as set out in Chapter 10 of the Local

Issues with evidence baseInfrastructure Capacity Study/trafficmodel: Has the impact on the two routesthat give access Skipton Road beenadequately assessed?

Plan and the Housing Background Paper) and,through the Local Plan there is a need toallocate land to ensure this requirement is met.The council considers that this site can

Site boundary issues contribute to meeting this need and theapproach taken to the identification of this siteis based on reasonable evidence.

Insufficient justification provided for thereduction in the site area between thatincluded in the Additional Sites

As set out in the evidence base, many siteshave been considered through the site selectionprocess. Sites have been allocated that are

consultation and that included in thePublication Draft. The reason provided(flooding) can be easily solved withoutreducing the site area considered to offer the greatest sustainability

benefits and considerations such as the scaleof development, access, and impacts onReduced site area included will limit the

ability to provide footpath links from thesite to nearby residential areas andexisting play facilities

highways landscape, ecology, heritage assetsand flooding were taken into account during thesite assessment process.

Potential adverse impacts of development ofthe site were considered through the siteassessment process. Where potential adverse

The area excluded from the site will betoo small to be agriculturally worthwhile

impacts were identified, it is considered thatPrevious applications to develop the site havebeen refused

these are not insurmountable and couldpotentially be mitigated, as set out in the SiteRequirements. Further assessment of theseissues will be undertaken as part of the planningapplication process if required at this stage.


No or poor access to public transport.It is recognised that new development, bothindividual sites and from the cumulative impactof several sites, will place extra pressure on

Local schools are full

GP is full existing infrastructure and may need new or

Local infrastructure cannot cope improved infrastructure to support it. The councilcontinues to work with the County Council, utility

No or poor access to shops and services. and other infrastructure/service providers tomake sure the infrastructure implications of the

Risk of flooding allocated sites are fully assessed and wherenecessary mitigation measures are identifiedNegative impact on the land above the

flood plain near to the Knox Lane ford. and put in place to address developmentimpacts. Funding contributions from developerswill be sought where needed to increasecapacity to provide local infrastructure.Poor drainage

Negative impact on the Landscape The site area was amended from that includedas part of the Additional Sites consultation inorder to protect the ecological interest of theexcluded (northern) part of the site andprotected trees.

The site is in a Special Landscape Area (SLA)

Loss of agricultural land

Coalescence

A large amount of development has alreadybeen granted in the local area

No local need for additional housing

The site is a greenfield site

Negative impact on the local communityThe existing peace and tranquility of thearea giving access to the countryside willbe lost





Negative impact on the amenity forwalkers, cyclists and horse riders on thelower part of Knox Lane

Unacceptable level of disruption to localresidents during construction

Concern for the amenity of neighbouringbungalows

Negative impact on local wildlife and biodiversitySite forms part of a green corridor forwildlife alongside the Oak Beck

Development will lead to loss ofhedgerows and/or trees/woodland,including trees protected by treepreservation orders (TPOs)

Negative impact on the conservation area.

Negative impact on a listed buildingGrade 2 listed Spruisty Bridge (formerpackhorse bridge)

Issue with consultation

OtherYorkshire Water have stated that sewageworks cannot accommodate furtherdevelopment and no upgrades areplanned before 2020

Negative impact on route/embankmentof former railway line (historic asset)

Initial ground works required for existingadjacent houses included 'blasting',concern that this may be required again.

Presence of overhead high-voltage powerlines presents a health and safety riskand should not be allocated if siteswithout the risk exist

In 2016 (draft Local Plan) the site wasconsidered unsuitable for inclusion in theplan, the site is now in the plan withoutfurther assessment. What has changed?

The cost of addressing the negativeimpacts identified by local people willmake the site undeliverable

Poor access to employment opportunities

Sites conflicts with Policy NE5 GreenInfrastructure which states that GreenInfrastructure specifically refers to“accessible countryside in urban fringeareas.”





Modifications sought

The representations made regarding this site sought the following modifications to the Plan:Remove site from Plan

Allocate a different site/more than one new settlement/focus development where infrastructure is already in place

Reduce number of houses in the Plan

Provide a new road access from Knox Lane directly to the A61 (Ripon Road) that avoids Grey Hill Road, SpruistyBridge and the ford

Amend site boundary to include full extent of site that was a draft allocation in the Additional Sites consultation (2017)

Site Requirements

N/AFollowing discussion Historic England havewithdrawn this objection.

Requirement 4 - as worded implies that it isacceptable, in principle, to harm this listedbuilding. (Historic England)

Amend to read: '.. development of the siteshould conserve those elements whichcontribute to the significance of this designatedheritage asset, including its setting.'

In Site Requirement 8delete the lastsentence.

As there is an existing footway along thefrontage of this site with Knox Lane the lastsentence of this requirement is unnecessary.

Requirement 8 - localised widening of KnoxLane is not possible as the lane is bordered byprivate property.

No amendment.Reference is made in the site requirement tothe Harrogate Ringway.

Requirement 10 - although nearby rights ofway are acknowledged, no mention is made ofthe Harrogate Ringway which runs around thissite. (NY LAF)

Site requirements should emphasise theimportance of links to the Ringway and look forenhancement of its use.

Table 12.5 Key Issues: Site H2 Land north of Knox Lane, Harrogate

H17: Heath Lodge Care Home, Harrogate



N/ANotedSupport






Noamendment

There is an identified residual housing requirement to bedelivered during the plan period (as set out in Chapter 10 ofthe Local Plan and the Housing Background Paper) and,

OtherCare home should not be lost asmore accommodation for olderpeople, including care homes, isneeded due to the aging population

through the Local Plan there is a need to allocate land toensure this requirement is met. The council considers that thissite can contribute to meeting this need and the approachtaken to the identification of this site is based on reasonableevidence.

Does not meet emerging policy HP8that seeks to protect communityfacilities-will lead to the loss of 28beds and a 6 bed dementia care unit,with no replacement proposed

Potential adverse impacts of development of the site wereconsidered through the site assessment process. Wherepotential adverse impacts were identified, it is considered thatthese are not insurmountable and could potentially beDoes not meet emerging policy GS7:

Health and Wellbeing mitigated, as set out in the Site Requirements. Furtherassessment of these issues will be undertaken as part of theplanning application process if required at this stage.Does not meet NPPF para 70 bullet

point 2It is recognised that new development, both individual sitesand from the cumulative impact of several sites, will place extrapressure on existing infrastructure and may need new orA good location for the elderly

residents, including due to good busservices to town centre and close tothe hospital

improved infrastructure to support it. The council continues towork with the County Council, utility and otherinfrastructure/service providers to make sure the infrastructureimplications of the allocated sites are fully assessed and wherenecessary mitigation measures are identified and put in placeA good location for the elderly

residents- easy for relatives to visit,which reduces potential for socialisolation

to address development impacts. Funding contributions fromdevelopers will be sought where needed to increase capacityto provide local infrastructure.

The site was submitted in response to the council's Call forSites as being available for development and with the intentionthat the care home facilities would be re-provided on analternative site in order to meet current standards andexpectations.

The site would be ideal for smallerunits and increase density as it’s in asustainable location, walking distanceto employment, namely key workersat the local schools

Remove the site from the plan

Table 12.6 Key Issues: H17 Heath Lodge Care Home, Harrogate

H18: Greenfield Court, 42 Wetherby Road, Harrogate








Noamendment

There is an identified residual housing requirement to bedelivered during the plan period (as set out in Chapter 10 of theLocal Plan and the Housing Background Paper) and, through

OtherCare home should not be lost asmore accommodation for olderpeople, including care homes, isneeded due to the aging population

the Local Plan there is a need to allocate land to ensure thisrequirement is met. The council considers that this site cancontribute to meeting this need and the approach taken to theidentification of this site is based on reasonable evidence.Does not meet emerging policy HP8

that seeks to protect communityfacilities-will lead to the loss of 39apartments and 10 bungalows, withno replacement proposed

Potential adverse impacts of development of the site wereconsidered through the site assessment process. Wherepotential adverse impacts were identified, it is considered thatthese are not insurmountable and could potentially be mitigated,as set out in the Site Requirements. Further assessment ofthese issues will be undertaken as part of the planningapplication process if required at this stage.

Does not meet emerging policyGS7: Health and Wellbeing

Does not meet NPPF para 70 bulletpoint 2 It is recognised that new development, both individual sites and

from the cumulative impact of several sites, will place extrapressure on existing infrastructure and may need new or

A good location for the elderlyresidents, including due to good busservices to town centre and close tothe hospital

improved infrastructure to support it. The council continues towork with the County Council, utility and otherinfrastructure/service providers to make sure the infrastructureimplications of the allocated sites are fully assessed and wherenecessary mitigation measures are identified and put in place

A good location for the elderlyresidents- easy for relatives to visit,which reduces potential for socialisolation

to address development impacts. Funding contributions fromdevelopers will be sought where needed to increase capacityto provide local infrastructure.

The site was submitted in response to the council's Call for Sitesas being available for development and with the intention thatthe care home facilities would be re-provided on an alternativesite in order to meet current standards and expectations.

A higher proportion of affordablehousing should be delivered on thesite and aimed at key workers givenits proximity to the hospital

Table 12.7 Key Issues: H18 Greenfield Court, 42 Wetherby Road, Harrogate

H21: Land at Kingsley Drive, Harrogate



No amendment.There is an identified residualhousing requirement to bedelivered during the plan period

Site boundary issues

Coalescence(as set out in Chapter 10 of the

No local need for additional housing Local Plan and the HousingBackground Paper) and, throughNegative impact on local roads/traffic the Local Plan there is a need to

Poor access to public transport allocate land to ensure thisrequirement is met. The council

Local infrastructure cannot cope considers that this site cancontribute to meeting this need

Local schools are full and the approach taken to theidentification of this site is basedon reasonable evidence.GPs/dentists are full

Loss of public open space/ sports pitches As set out in the evidence base,many sites have been consideredthrough the site selection process.


Negative impact on wildlife and biodiversity Sites have been allocated that areconsidered to offer the greatest

Negative impact on the local community sustainability benefits and




considerations such as the scaleof development, access, andimpacts on highways landscape,

OtherThis should be considered as a single site withH22, H23 and H48 as they areinterdependent. ecology, heritage assets and

flooding were taken into accountduring the site assessmentprocess.

Site conflicts with draft Local Plan Policy NE5.

Increased air pollution as a result of extratraffic, including HGVs during construction Potential adverse impacts of

development of the site wereconsidered through the siteassessment process. Wherepotential adverse impacts wereidentified, it is considered thatthese are not insurmountable andcould potentially be mitigated, asset out in the Site Requirements.Further assessment of theseissues will be undertaken as partof the planning applicationprocess if required at this stage.

It is recognised that newdevelopment, both individual sitesand from the cumulative impactof several sites, will place extrapressure on existing infrastructureand may need new or improvedinfrastructure to support it. Thecouncil continues to work with theCounty Council, utility and otherinfrastructure/service providers tomake sure the infrastructureimplications of the allocated sitesare fully assessed and wherenecessary mitigation measuresare identified and put in place toaddress development impacts.Funding contributions fromdevelopers will be sought whereneeded to increase capacity toprovide local infrastructure.

The site requirements are clearthat sites H22, H23 and H48 arerelated and identifies thosematters where there will be aneed to consider the developmentof the sites together.


The representations made regarding this site sought the following modifications to the Plan:Remove the site from the plan

Allocate a new settlement

reduce the density of the site

A new road should be developed from Skipton Road (at Granby Corner) to Bilton Hall Drive

Site Requirements




Amend Site Requirement 8 toread "provide pedestrian andcycle links within the site and

Agree that reference to theadjacent public right of wayshould be added to the siterequirements.

Should be a specific indication of the nearby right ofway which gives direct access to the KnaresboroughRound and Harrogate Ringway. (NY LAF)

from the site to connect withadjacent development sites,Amend site requirements to include and enhance the

access to Knaresborough Round and HarrogateRingway.

including H22 and H48, theadjacent public right ofway and existing areas in orderto provide convenient routesto the Knaresborough Roundand Harrogate Ringway andlocal services and facilitiesincluding those in the towncentre"

No amendment.An amendment to the genericsite requirement (under paragraph10.2) is proposed which makes

Site has potential (both individually and cumulatively)to increase traffic at Starbeck level crossing.Transport Assessment should consider likely impact

clear that any transportassessment should consider thematters raised by the respondent.

on level crossing and how alternativeroutes/measures could avoid/reduce attractivenessof level crossing as access to site. (Network Rail) Addwording to site specific requirements to refer to needto consider railway level crossing usage.

Table 12.8 Key Issues: H21 Land at Kingsley Drive, Harrogate

H22: Land at Granby Farm, Harrogate



N/ANoted.Support


No amendment.There is an identified residualhousing requirement to be deliveredduring the plan period (as set out in

Issues with evidence base

A large amount of development has already been grantedin the local area Chapter 10 of the Local Plan and the

Housing Background Paper) and,Affordable housing through the Local Plan there is a need

to allocate land to ensure thisNegative impact on the landscape requirement is met. The councilLocal infrastructure cannot cope considers that this site can contribute

to meeting this need and theNegative impact on local roads/traffic approach taken to the identification

of this site is based on reasonableevidence.Local schools are full

GPs/dentists are full As set out in the evidence base, manysites have been considered throughthe site selection process. Sites haveRisk of flooding

surface flooding is already a problem and moreconcrete would increase the problem

been allocated that are considered tooffer the greatest sustainabilitybenefits and considerations such asthe scale of development, access,

Drainage and impacts on highways landscape,sewage networks need upgrading to cope withincreased development

ecology, heritage assets and floodingwere taken into account during thesite assessment process.






Potential adverse impacts ofdevelopment of the site wereconsidered through the site

Loss of public open space/sports pitches

Negative impact on local communityloss of green wedge which is a valuable resource tolocal community - good public access, recreation andamenity value, good network of footpaths

assessment process.Where potentialadverse impacts were identified, it isconsidered that these are notinsurmountable and could potentiallybe mitigated, as set out in the Siteimpacts of construction - air, noise and water pollutionRequirements. Further assessmentof these issues will be undertaken aspart of the planning applicationprocess if required at this stage.

access road will divide the community of DevonshireGardens in half

Negative impact on local wildlife and biodiversity It is recognised that newdevelopment, both individual sitesand from the cumulative impact ofCoalescenceseveral sites, will place extra pressureConcern at the loss of green wedge divides Starbeck

from Bilton maintaining individual characteristics. on existing infrastructure and mayneed new or improved infrastructureto support it. The council continues

Negative Impact on the Conservation Area to work with the County Council, utilityand other infrastructure/serviceprovides green setting to the CAproviders to make sure theinfrastructure implications of the

Negative impact on a listed building(s) allocated sites are fully assessed andwhere necessarymitigationmeasures

Other are identified and put in place toConflicts with Policy NE5: Green Infrastructure address development impacts.

Funding contributions fromdevelopers will be sought whereneeded to increase capacity toprovide local infrastructure.

Access should be gained off Kingsley Drive

Need for comprehensive development of sites H21,H22, H23 and H48

The site requirements are clear thatsites H21, H22, H23 and H48 arerelated and identifies those matterswhere there will be a need to considerthe development of the sites together.

Alternative sites are available which would not havethe same environmental, landscape and infrastructureimpacts.



Allocate more than one new settlement

Comprehensive plan to redvelop H21, H22, H23 and H48 along with highways and infrastructure required.

New road should be built through the area joining Skipton Road to Bilton Hall Drive

Access should be from Kingsley Drive

Site Requirements

N/AFollowing discussion HistoricEngland have withdrawn thisobjection.

Requirement 2 - as worded implies that it is acceptable,in principle, to harm these listed buildings (Historic England).

Amend to read: '.. development of the site should conservethose elements which contribute to the significanceof these designated heritage assets, including their setting.'






Requirement 3 - as worded implies that it is acceptable,in principle, to harm the conservation area (HistoricEngland).

Amend to read: '.. development of the site should conservethose elements which contribute to the significance of thisdesignated heritage asset, including its setting.'. (HistoricEngland)

Amend SiteRequirement 4 toread: 'Retain existing

Agree that the amendments relatingto the green wedge and first sentenceshould be made.

Requirement 4 - delete reference to 'green wedge'. At endof first sentence add 'where possible'. Amend wording toreflect green infrastructure covered in separate requirement.

boundary trees andhedgerows wherepossible. ......particularly along thenorth-westernboundary in order tomaintain significantlinks with the 'greenwedge' and, incombination withadjacent development.....'

No amendmentIt is important to maintain the optionfor access through the redevelopedRugby Club to ensure that the site

Requirement 5 - delete reference to accessthrough redeveloped Rugby Club Site

can be delivered. Only referring toReference to the potential vehicle, cycle and pedestrianaccess through the redeveloped Rugby Club Site shouldbe deleted from Site Requirement 5

access through the adjacent draftallocation which is in a differentownership could stifle the futuredevelopment of the site.

No amendment.This requirement does not proposelinks through the former rugby ground(this is covered by Requirement 5)

Requirement 6 - reference to the potential pedestrian andcycle links through the former rugby ground should bedeleted.

but rather that links between the twodevelopments should be created. Thismay be of benefit to residents of therugby ground development as muchas those of this site.

No amendment.An amendment to the generic siterequirement (under paragraph 10.2)is proposed which makes clear that

Requirement 8 - site has potential (both individually andcumulatively) to increase traffic at Starbeck level crossing.Transport Assessment should consider likely impact on

any transport assessment shouldconsider the matters raised by therespondent.

level crossing and how alternative routes/measures couldavoid/reduce attractiveness of level crossing as access tosite (Network Rail).

Add wording to site specific requirements to refer to needto consider railway level crossing usage

No amendment.It is considered that Requirement 6adequately covers this.

Enhanced pedestrian access to the conservation area isrequired. (NY LAF)

Table 12.9 Key Issues: H22 Land at Granby Farm, Harrogate



H23: Land north of Kingsley Farm, Harrogate



N/ANoted.Support


No amendment.There is an identified residual housingrequirement to be delivered during the planperiod (as set out in Chapter 10 of the Local

Site boundary issuesThis should be considered as a single site withH22, H23 and H48 as they are interdependent.

Plan and the Housing Background Paper) and,through the Local Plan there is a need to

Coalescence allocate land to ensure this requirement is met.The council considers that this site canHousing will stretch from Claro Road to

Starbeck. contribute to meeting this need and theapproach taken to the identification of this siteis based on reasonable evidence.

No local need for additional housingAs set out in the evidence base, many siteshave been considered through the site selectionprocess. Sites have been allocated that are

Local infrastructure cannot cope

Negative impact on local roads/traffic considered to offer the greatest sustainabilityRoads are already congested and present asignificant risk to pedestrians and cyclists.

benefits and considerations such as the scaleof development, access, and impacts onhighways landscape, ecology, heritage assetsand flooding were taken into account during thesite assessment process.Loss of open space

Loss of green wedgePotential adverse impacts of development ofthe site were considered through the siteassessment process. Where potential adverseLocal GP's are fullimpacts were identified, it is considered that

Negative impact on wildlife and biodiversity these are not insurmountable and couldpotentially be mitigated, as set out in the SiteIssue with consultation Requirements. Further assessment of theseissues will be undertaken as part of the planningapplication process if required at this stage.

It is recognised that new development, bothindividual sites and from the cumulative impactof several sites, will place extra pressure onexisting infrastructure and may need new orimproved infrastructure to support it. The councilcontinues to work with the County Council, utilityand other infrastructure/service providers tomake sure the infrastructure implications of theallocated sites are fully assessed and wherenecessary mitigation measures are identifiedand put in place to address developmentimpacts. Funding contributions from developerswill be sought where needed to increasecapacity to provide local infrastructure.

The site requirements are clear that sites H22,H23 and H48 are related and identifies thosematters where there will be a need to considerthe development of the sites together.



Allocate a different site/ new settlement





Reduce the density of the site

A new road should be developed from Skipton Road (at Granby Corner) to Bilton Hall Drive

Site Requirements

No amendment.The north east and south eastern boundarieshave value as existing green infrastructurecorridors and are, therefore, appropriatelyreferenced as such. Requirement 8 refers to theprovision of new green infrastructure.

Requirement 4 - overly prescriptive and not justifiedby evidence. Requirement 8 demonstrates area notgreen infrastructure corridor as states greeninfrastructure provision should be considered.

Delete 'in order to enhance these green infrastructurecorridors' and replace with reason relating toenhancement of existing field boundaries and/orbiodiversity.

No amendment.It is considered the suggested amendment isoverly prescriptive and that the requirement isappropriately worded.

Requirement 7 – undermined by relative weaknessof statement. Should be specific that right of way isnot replaced by pavements (with road crossings)and/or narrow fenced ginnels. (NY LAF)

No amendment.An amendment to the generic site requirement(under paragraph 10.2) is proposed whichmakes clear that any transport assessmentshould consider the matters raised by therespondent.

Site has potential (both individually and cumulatively)to increase traffic at Starbeck level crossing. TransportAssessment should consider likely impact on levelcrossing and how alternative routes/measures couldavoid/reduce attractiveness of level crossing asaccess to site. (Network Rail).

Add wording to site specific requirements to refer toneed to consider railway level crossing usage

No amendment.The site is within 800m of a bus route offeringa good quality bus service.

There should be a requirement to provide access topublic transport

No amendment.New development will increase the amount oftraffic contributing to air pollution and, therefore,the amendment sought is not realistic. However,

There should be a site requirement to maintain airpollution at current levels.

the provision of pedestrian and cycle links fromthe development to provide convenient routesto local facilities and services will assist inminimising the need to travel.

No amendment.The site requirements seek to retain existingtrees and hedgerows where this is possible andfor green corridors to be enhanced with newnative tree and hedgerow planting

Should be a requirement to conserve biodiversity.

Table 12.10 Key Issues: H23 Land north of Kingsley Farm, Harrogate

H36: Former Police Training Centre, Yew Tree Lane, Harrogate

12.1 Since the Publication Local Plan was published for consultation, the Council have resolvedto grant planning permission for the development of this site subject to the completion of aSection 106 Agreement.






No amendment.Since the Publication DraftConsultation the Council hasresolved to grant planningpermission on this site.

Legal complianceno reference that Sports England have beenconsulted regarding loss of playing field.

Test of soundnessno justification for number of houses in the plan.

Coalescence

The site is too big

Large amount of development has already been grantedin the local area


Negative impact on local roads/ traffic



GPs/dentists are full

Loss of public open space/ sports pitches


The representations made regarding this site sought the following modifications to the Plan:Reduce the yield on the site to re-utilize existing buildings

remove the site form the plan and allocate new settlement instead

Council need to produce a holistic development plan for the west of Harrogate

Site Requirements

No amendment.Since the Publication DraftConsultation the Council hasresolved to grant planningpermission on this site.

Requirement 9 - importance of the connection to the Rightsof Way network (including the nearby Harrogate Ringway)needs to be specifically mentioned. (NY LAF)

Table 12.11 Key Issues: H36 Former Police Training Centre, Yew Tree Lane, Harrogate

H48: Land adjacent to Kingsley Farm, Harrogate


N/ANoted.Support


No amendment.There is an identified residual housingrequirement to be delivered during theplan period (as set out in Chapter 10 of

Site boundary issuesThis should be considered as a single site withH22, H23 and H21 as they areinterdependent. the Local Plan and the Housing

Background Paper) and, through theLocal Plan there is a need to allocate

Coalescence land to ensure this requirement is met.The council considers that this site can

No local need for additional housing contribute to meeting this need and the




approach taken to the identification ofthis site is based on reasonableevidence.



Loss of public open space As set out in the evidence base, manysites have been considered through thesite selection process. Sites have been

loss of green wedge

loss of recreational space allocated that are considered to offer thegreatest sustainability benefits and

allows car free access for Kingsley Drive arearesidents to the Harrogate Greenway, Biltonand the Nidd Gorge

considerations such as the scale ofdevelopment, access, and impacts onhighways landscape, ecology, heritageassets and flooding were taken intoaccount during the site assessmentprocess.Negative impact on the local community.

Increased air pollution as a result of extratraffic, including HGVs during construction Potential adverse impacts of

development of the site were consideredthrough the site assessment process.

Negative impact on local wildlife and biodiversity Where potential adverse impacts wereidentified, it is considered that these are

Negative impact on landscape not insurmountable and could potentiallybe mitigated, as set out in the Site

Other Requirements. Further assessment ofWarren like development out of character withthe area

these issues will be undertaken as partof the planning application process ifrequired at this stage.

Development will contribute to gridlock and airpollution It is recognised that new development,

both individual sites and from thecumulative impact of several sites, willCycle routes, for both residents of Kingsley

and for schoolchildren attending the HighSchool, are directed along roads used as rat

place extra pressure on existinginfrastructure and may need new or

runs to avoid Knaresborough Road and willbecomemore congested and dangerous if thisdevelopment takes place.

improved infrastructure to support it. Thecouncil continues to work with theCounty Council, utility and otherinfrastructure/service providers to makesure the infrastructure implications ofTraffic from a number of accumulated sites

would justify mitigation measures at Starbeckcrossing

the allocated sites are fully assessedand where necessary mitigationmeasures are identified and put in placeto address development impacts.Funding contributions from developerswill be sought where needed to increasecapacity to provide local infrastructure.

The site requirements are clear thatsites H21, H22, H23 and H48 are relatedand identifies those matters where therewill be a need to consider thedevelopment of the sites together.


The representations made regarding this site sought the following modifications to the Plan:Remove site from the planAllocate a different site/new settlement

Site Requirements

Amend Site Requirement7 to read "providepedestrian and cycle links

Agree that reference to the adjacentpublic right of way should be added tothe site requirements.

Site requirements make no mention of the nearbypublic footpath. (NY LAF)

within the site and fromthe site to connect with




adjacent developmentsites, including H21, H23and H47, the adjacentpublic right of way andexisting areas in order toprovide convenient routesto local services andfacilities including thosein the town centre"

No amendment.An amendment to the generic siterequirement (under paragraph 10.2) isproposed which makes clear that anytransport assessment should considerthe matters raised by the respondent.

Site has potential (both individually and cumulatively)to increase traffic at Starbeck level crossing.Transport Assessment should consider likely impacton level crossing and how alternativeroutes/measures could avoid/reduce attractivenessof level crossing as access to site. (Network Rail)

Add wording to site specific requirements to refer toneed to consider railway level crossing usage.

No amendment.This is already covered by generic siterequirement 4 which addressesmaximising sustainable modes of travelincluding public transport.

Should include provision for access to publictransport.

No amendment.This is already covered by generic siterequirement 4 which addresses reducingcongestion and improving air quality.

Should maintain or improve air pollution to currentlevels

No amendment.This is already covered by generic siterequirement 1 which ensures thatdevelopment should meet the

Should seek to conserve biodiversity

requirements of relevant policies of theLocal Plan which would include PolicyNE 3 : protecting the naturalenvironment.

Table 12.12 Key Issues: H48 Land adjacent to Kingsley Farm, Harrogate

H49: Windmill Farm, Otley Road, Harrogate


N/ANoted.Support


No amendment.There is an identifiedresidual housing requirementto be delivered during the

Legal ComplianceSustainable development not supported in relation toroad infrastructure and transport as no recent trafficsurvey done for Otley Road plan period (as set out in

Chapter 10 of the Local Planand theHousing Background

Test of soundness (RHS Garden Harlow Carr) Paper) and, through theLocal Plan there is a need toNot positively prepared as no strategy for integrated

infrastructure and service provision for H49 and adjacentsites

allocate land to ensure thisrequirement is met. Thecouncil considers that thissite can contribute toNot consistent with NPPF para 114 as H49 will sever

biodiversity network and green infrastructure by isolatingRHS Garden Harlow Carr.

meeting this need and theapproach taken to theidentification of this site isbased on reasonableevidence.

Site is not justified as the plan over provides for thedistrict by nearly 15% (16077 rather than 14049).




As set out in the evidencebase, many sites have beenconsidered through the site

Issues with evidence base (HEDNA)

The site is too big (RHS Harlow Carr)selection process. Sites

Coalescence have been allocated that areNegative impact on Beckwithshaw by effectively mergingthe village with Harrogate

considered to offer thegreatest sustainabilitybenefits and considerationssuch as the scale of

Large amount of development has already been granted in thelocal area

development, access, andimpacts on highwayslandscape, ecology, heritageAffordable housing assets and flooding weretaken into account during thesite assessment process.

The site is outside the current development limitlocation beyond outer fringe of town will not create strongand vibrant community

Potential adverse impacts ofdevelopment of the site wereconsidered through the siteNegative impact on the landscapeassessment process.Wherecontrary to emerging policy NE4 potential adverse impactswere identified, it is

adverse visual impact on Harlow Carr Gardens (RHSHarlow Carr)

considered that these arenot insurmountable andcould potentially be

impact on Birk Crag mitigated, as set out in theSite Requirements. Furtherassessment of these issues

Site is in SLA will be undertaken as part ofthe planning applicationprocess if required at thisstage.


No or poor access to public transportnot accessible to a railway station or on the key buscorridor It is recognised that new

development, both individualsites and from the

Local schools are full cumulative impact of severalsites, will place extra

GPs/dentists are full pressure on existinginfrastructure and may need

Local infrastructure cannot cope new or improvedinfrastructure to support it.

Risk of flooding The council continues toRHS Garden Harlow Carr already subject to floodingcaused by off site drainage issues related to HarlowBeck. Scale and proximity of H49 will exacerbatethis. (RHS Harlow Carr)

work with the CountyCouncil, utility and otherinfrastructure/serviceproviders to make sure theinfrastructure implications ofthe allocated sites are fully

Negative impact on local wildlife and biodiversity assessed and wherenecessary mitigation

Issue with consultation measures are identified andput in place to address

Other development impacts.impact on existing footpaths Funding contributions from

developers will be soughtThe plan acknowledges the need for minimisinggreenhouse gas emissions yet designates sites fordevelopment that will increase traffic and pollution

where needed to increasecapacity to provide localinfrastructure.

Site does not lend itself to the creation of strong andvibrant communities because because it is so farremoved from community facilities

It is clear from the siterequirements (requirement1) that development of thissite should be integrated




with that of nearby sites. TheHarrogate Transport Modelincluded Otley Road.



Allocate a different site

Reduce number of houses in the plan

Increase the size of the new settlement/allocate more than one

Council need to produce a holistic plan for the west of Harrogate

Require, through policy, a strategic approach to infrastructure provision along Otley Road for all proposed housingallocations in the area, including approved/not yet built schemes. (RHS Harlow Carr)

Specific transport improvements required including right turning lanes at junctions of Beckwith Rd, Beckwith HeadRd and Crag Lane and third lane along Otley Road

Update evidence base including HEDNA (use of standardised methodology)/infrastructure requirements/more detailedtransport model for west Harrogate and surrounding villages

Site Requirements

Amend Site Requirement10 to read "Protect andenhance the recreational

Agree that there should bereference to the Dales WayLink.

Requirement 10 - importance of access to the Harrogate Link– to the Dales Way – needs to be specifically mentioned. (NYLAF)

and amenity value of thepublic footpath (part of theHarrogate Ringway andleading to the Dales Waylink) that follows the site'seastern boundary.........."

No amendments.It is considered that thiscould be addressed throughthe provisions of siterequirements 4 and 10.

Reduce the scale of the site and identify a buffer of informalopen space or green wedge between the west boundary ofHarlow Carr Garden and site H49. This area could be utilizedto locate essential drainage infrastructure required to serve thenew housing development and protect Harlow Carr fromflooding.

Table 12.13 Key Issues: H49 Windmill Farm, Otley Road, Harrogate

H56: Land to the north of Cow Dyke Farm, Harrogate



HBCResponseKey Issue

N/ANoted.Support






No amendmentSince thePublication Draftconsultation, the

Issues with evidence base (HEDNA)

Negative impact on local roads/trafficCouncil have

No or poor access to public transport resolved to grantplanningNo or poor access to shops and services permission forthe developmentof the site.

Risk of flooding

Negative impact on the landscape


Site is in SLA

Site is greenfield


Other:The plan acknowledges the need for minimising greenhouse gas emissions yetdesignates sites for development that will increase traffic and pollution

Housing numbers included in the plan are not deliverable: short supply of labourfollowing brexit; lack of an infrastructure delivery plan

Modifications soughtRemove site from the planReduce number of houses in the planAmend site boundary to include adjoining site H33Allocate more than one new settlement

Site Requirements

Cycle linkage to site across land at Grange Farm will not be permitted

Requirement 9 – public footpath forms a section of the important Harrogate Ringwayand the site requirements should acknowledge the importance of this route on theRights of Way network. (NYLAF).

Table 12.14 Key Issues: H56 Land to the north of Cow Dyke Farm, Harrogate

H65: Harlow Nurseries, Harrogate



No amendment.There is an identifiedresidual housingrequirement to be delivered

Coalescence

Affordable housingHarrogate Affordable Homes Community Land Trust feelthat the stewardship of this site should fall to them to createa sustainable community in keeping with government thinkingof freeing up public land.

during the plan period (asset out in Chapter 10 of theLocal Plan and the HousingBackground Paper) and,through the Local Plan,there is a need to allocate

Loss of public open space/ sports pitches land to ensure thisEnjoyment of the Pinewoods and nearby public footpathswould be reduced by visual impact and traffic.

requirement is met. Thecouncil considers that thissite can contribute tomeeting this need and theLoss of site used by Harrogate Indoor Bowling Club.approach taken to the




identification of this site isbased on reasonableevidence.

This area is a well used footpath to both RHS Harlow Carrand for many commuters to Cardale Park, both by foot andbike. Any development is likely to restrict such usage.

As set out in the evidencebase, many sites have beenconsidered through the site

Other:Single track access not appropriate and cannot be wideneddue to Local Green Space designation and Asset ofCommunity Value designation.

selection process. Siteshave been allocated that areconsidered to offer thegreatest sustainabilityAccess to town is on Valley Drive and Harlow Moor Drive

both of which are double parked and barely wide enough forvehicles to pass.

benefits and considerationssuch as the scale ofdevelopment, access, andimpacts on highwaysSite includes the ‘operational areas’ of Pinewoods. Instead

these areas should be incorporated into an expanded LocalGreen Space.

landscape, ecology,heritage assets and floodingwere taken into accountduring the site assessmentprocess.Local infrastructure cannot cope

Negative impact on local roads/traffic Potential adverse impactsof development of the sitewere considered throughNegative impact on the landscapethe site assessment

The site is in the SLA process. Where potentialadverse impacts wereNegative impact on the local community. identified, it is considered

The community has spent time and money caring for thissite, including planting trees and removing invasive species

that these are notinsurmountable and couldpotentially be mitigated, as

Negative impact on the green social hub which has enormouscommunity value

set out in the SiteRequirements. Furtherassessment of these issueswill be undertaken as part

Negative impact on local wildlife and biodiversity of the planning applicationprocess if required at thisstage.

Impact on mature woodland habitat adjacent to the site.

Impossible to see how appropriate mitigation andcompensation for adverse ecological impacts can beachieved. The current site is mainly open and supports muchwildlife and increases bio-diversity within the site.

It is recognised that newdevelopment, bothindividual sites and from thecumulative impact of severalsites, will place extra

Negative impact on listed building pressure on existingHarlow Hill Water Tower infrastructure andmay need

new or improvedinfrastructure to support it.Harlow Hill Observatory TowerThe council continues towork with the CountyCouncil, utility and otherinfrastructure/serviceproviders to make sure theinfrastructure implications ofthe allocated sites are fullyassessed and wherenecessary mitigationmeasures are identified andput in place to addressdevelopment impacts.Funding contributions fromdevelopers will be soughtwhere needed to increasecapacity to provide localinfrastructure.




The impact of developmenton existing recreationalfacilities is covered byPolicy HP8.

In providing comments onthis site the highwaysauthority (NYCC) have notindicated that Valley Driveor Harlow Moor Drive areunsuitable to serve asaccesses to the site. Theneed for any improvementsto facilitate this will beconsidered at planningapplication stage.


The representations made regarding this site sought the following modifications to the Plan:Remove site from plan

Consider alternative use for site

Amend site boundary to exclude the "Operational areas" of Pinewoods

Site requirements

N/AFollowing discussionHistoric England havewithdrawn this objection.

Requirement 2 - as worded implies that it is acceptable, inprinciple, to harm these listed buildings (Historic England).

Amend to read: '.. development of the site should conserve thoseelements which contribute to the significance of these designatedheritage assets, including their setting.'

No amendmentNot referenced as such onmaps.

Requirement 6 - should be Nursery Lane East. (NY LAF)

Amend SiteRequirement 7 to read:

Agree that there should bereference to the Dales Way.

Requirement 7 - importance of footpath link in gaining access tothe Harrogate Link to the Dales Way and providing accessible,non-vehicular route into the town centre needs to be specificallymentioned. (NY LAF) '..... amenity value of the

public footpath thatcrosses the site, whichis an important linkbetween Otley Roadand the Pinewoodswoodland and inleading to the DalesWay Link; this shouldinclude .... '

Table 12.15 Key Issues: Site H65 Harlow Nurseries, Harrogate

H69: Land to the east of Knox Hill, Harrogate



N/ANoted.Support allocation of site:A logical extension to the north-western edge of Harrogate





A developer has shown a commitment to deliver the site and whilstthe housing trajectory is considered achievable, the site could comeforward before 2021/22

A scheme can be designed that addresses the site requirementsshown in the Local Plan

Whilst the SA assessment of the site shows some red scores thatwe do not fully agree with, the issues raised are not insurmountable


No amendment.There is an identifiedresidual housingrequirement to be


Issues with evidence base - (HEDNA)delivered during the plan

Negative impact on local roads/ traffic period (as set out inChapter 10 of the LocalNo or poor access to public transport Plan and the Housing

Local schools are full Background Paper) and,through the Local Plan,

GPs/dentists are full there is a need toallocate land to ensure

Local infrastructure cannot cope this requirement is met.The council considersYorkshire Water have stated that sewage works cannot

accommodate further development and no upgrades are plannedbefore 2020

that this site cancontribute to meeting thisneed and the approachtaken to the identificationof this site is based onreasonable evidence.


Risk of floodingAs set out in theevidence base, manysites have been

Poor drainage

Negative impact on the landscape considered through theLoss of agricultural land site selection process.

Sites have beenThe site is a greenfield site allocated that are

considered to offer theCoalescence greatest sustainability

benefits andNegative impact on the local community considerations such as

Negative impact on the amenity for walkers, runners, cyclists andhorse riders in the vicinity

the scale of development,access, and impacts onhighways landscape,ecology, heritage assetsThe existing peace and tranquility of the area giving access to the

countryside will be lost and flooding were takeninto account during thesite assessment process.

Negative impact on local wildlife and biodiversityPotential adverseimpacts of developmentof the site were

Development will lead to loss of hedgerows and/ortrees/woodland, including trees protected by tree preservation orders(TPOs).

considered through thesite assessment process.

Negative impact on listed buildings Where potential adverseimpacts were identified,Harm to Grade 2 listed Spruisty Bridge (former packhorse bridge)

contrary to NPPF paragraph 132 (also draft NPPF para 190) it is considered that theseare not insurmountableand could potentially be

Other mitigated, as set out inthe Site Requirements.





Further assessment ofthese issues will beundertaken as part of the

In 2016 (draft Local Plan) the site was considered unsuitable forinclusion in the plan, the site is now in the plan without furtherassessment. What has changed?

planning applicationprocess if required at thisstage.

Presence of overhead high-voltage power lines crossing thesite presents a health and safety risk

It is recognised that newdevelopment, bothindividual sites and from

Negative impact on route/embankment of former railway line (historicasset)

the cumulative impact ofThe cost of addressing the negative impacts identified by localpeople will make the site undeliverable several sites, will place

extra pressure onexisting infrastructureIt is "widely known" that the landowner is not willing to see this site

developed for housing or any other built form and may need new orimproved infrastructureto support it. The council

Site constraints include working saw mill, track used by horses,walkers, dog walkers and cyclists.

continues to work withthe County Council, utilityand other

Concerns at safety of neighbouring residents during constructionphase - particularly in relation to site traffic on the narrow KnoxLane.

infrastructure/serviceproviders to make surethe infrastructureimplications of the

No local employment to support such a development allocated sites are fullyassessed and wherenecessary mitigationmeasures are identifiedand put in place toaddress developmentimpacts. Fundingcontributions fromdevelopers will be soughtwhere needed toincrease capacity toprovide localinfrastructure.


The representations made regarding this site sought the following modifications to the Plan:Remove the site from the PlanAllocate a different site/more than one new settlementUpdate evidence baseProvide new road access directly to A61 (Ripon Road) that avoids Spruisty Bridge and the fordIntroduce park and ride on main roads into Harrogate, encourage more cycling, provide school transportProvide additional shops/services in local area, including secondary school and supermarketAlleviate traffic congestion on A59 through Harrogate with construction of relief road

Table 12.16 Key Issues: H69 Land to the east of Knox Hill, Harrogate

H70: Land east of Whinney Lane, Harrogate


N/ANoted.Support allocationThe site is available and achieveable. It has awilling and able developer, and part of the siteis subject to an outline planning application.






Issue with evidence base

Coalescence(as set out in Chapter 10 of the

Large amount of development has already beengranted in the local area

Local Plan and the HousingBackground Paper) and, throughthe Local Plan, there is a needThe site is outside the current development limit to allocate land to ensure this

location beyond outer fringe of town will notcreate strong and vibrant community

requirement is met. The councilconsiders that this site cancontribute to meeting this needand the approach taken to theidentification of this site is basedon reasonable evidence.

The site is in SLA


Negative impact on local roads/traffic As set out in the evidence base,many sites have beenconsidered through the siteLocal schools are fullselection process. Sites have

GPs/dentists are full been allocated that areconsidered to offer the greatest

No or poor access to public transport sustainability benefits andconsiderations such as the scaleNo or poor access to shops and services of development, access, and

Negative impact on the landscape impacts on highways landscape,ecology, heritage assets andAdverse landscape and visual effects on wider

landscape could be significantly reduced byamending site boundary.

flooding were taken into accountduring the site assessmentprocess.

Loss of public open space/sports pitches Potential adverse impacts ofdevelopment of the site wereconsidered through the siteNegative impact on the local communityassessment process. Where

Negative impact on local wildlife and biodiversity potential adverse impacts wereidentified, it is considered that

Negative impact on listed buildings these are not insurmountableand could potentially be

Issue with consultation mitigated, as set out in the SiteRequirements. FurtherOther assessment of these issues will

No cycle paths and too dangerous to cycle inthis area because of the sheer volume of trafficand pot-holes

be undertaken as part of theplanning application process ifrequired at this stage.

Negative impact on users of nearby publicfootpaths

It is recognised that newdevelopment, both individualsites and from the cumulative

Negative impact on air quality as a result ofincreased vehicle pollution

impact of several sites, will placeextra pressure on existinginfrastructure andmay need new

Increased noise pollution generated from theadditional traffic

or improved infrastructure tosupport it. The council continuesto work with the County Council,utility and other

Culmative Effects infrastructure/service providersto make sure the infrastructure

Development of this site, together with the 6 sitesproposed in this area is equivalent in size to a newsettlement without the comprehensive settlementplanning which would normally be necessary to createthe facilities for a strong and vibrant community.

implications of the allocated sitesare fully assessed and wherenecessary mitigation measuresare identified and put in place toaddress development impacts.Funding contributions fromdevelopers will be sought whereneeded to increase capacity toprovide local infrastructure.





The representations made regarding this site sought the following modifications to the Plan:Remove the site from the PlanAllocate more than one new settlementRethink the proposals for additional housing to the west of HarrogateSubstantially modify the boundaries of the site to avoid development of the prominent south-facing slopes andsignificantly reduce the adverse landscape and visual effects on the wider landscape.Green buffer zones should be introduced along the northern edge in order to avoid the development impactingnegatively on the character of the neighbourhood and the residential amenity of neighbours

Site Requirements

No amendment.As worded the site requirementdoes not exclude this.

Requirement 1 – should be reworded to enable siteto be brought forward in two distinct parcels (northand south) with pedestrian link between the two.

Reword to enable site to be brought forward as twodistinct parcels

Amend Requirement 3 to read(new text underlined, deletedtext struck through): 'Syke

This could be through, forexample, keeping the areasaround the farmsteads free from

Requirement 3 – not clear how development could‘enhance’ significance of non-designated heritageassets. Appears excessive requirement.

House Farm and the historicdevelopment but it is acceptedbuildings associatedwithCastlethat this could be made clearerRemove requirement to ‘enhance the significance’ of

the non-designated assets Hill Farm are on-sitenon-designated heritage assets;steps should be taken to

in the requirement wording andto ensure consistency of wordingwith similar requirements inrespect of other sites. minimise harm to these

non-designated heritage assets,including throughappropropriate conversion,design and layout; and seek toenhance their significance andshould be sensitivelyconverted and the areaimmediately around themshould remain free of other builtdevelopment in order tominimise harm to theirsignificance.

No amendment.As acknowledged by therespondent it would still bepossible to create a cycle link

Requirement 11 – not possible or necessary torequire developer to create links to H36 other thanthose shown on approved plans. A cycle link would

and, as such, the requirementbe deliverable on western boundary of H36 but onlyremains appropriate at this time.with co-operation of Barratt Homes. Site requirementsWhether it is capable offor H36 places reciprocal requirement on the site but

has not been secured through the planning applicationprocess.

implementation can bedetermined at planningapplication stage.

Remove reference to provide cycle link to site H36

Amend site requirement 12 toread "Protect and enhance therecreational and amenity value

Agree reference should bemade as suggested.

Requirement 12 – no mention of the footpathadjacent to the south edge of the site; this is theimportant route – the Harrogate Ringway. (NY LAF)

of the public footpaths thatcross the site; investigatecreating a north to south routeconnecting these footpaths inthe east of the site and theHarrogate Ringway on thesouthern edge of the site"




No amendment.It is considered that the siterequirements provide anappropriate level of guidance,

Site requirements should include design guidanceto reflect the local style.

which will be supplemented bythe preparation of a concept plan(site requirement 1).

Table 12.17 Key Issues: H70 Land east of Whinney Lane, Harrogate

Knaresborough Sites

K23: Land north of Bar Lane and east of Boroughbridge Road, Knaresborough

12.3 Since the Publication Local Plan was published for consultation, the Council have grantedoutline planning permission for the erection of up to 12 dwellings on this site. The decisionnotice was issued on the 4 July 2018.



N/ANoted.Support


No amendment.Since the PublicationLocal Plan waspublished for

A large amount of development has already been granted in the localarea

Poor access to shops and services consultation, theCouncil have granted

The site is too big outline planningpermission for theNo local need for additional housing erection of up to 12

Local infrastructure cannot cope dwellings on this site.The decision notice wasissued on the 4 July2018.





Negative impact on local wildlife and biodiversity

Negative impact on the conservation area

Otherdevelopment here would further contribute to the significantproblems of air quality at Bond End and York Place inKnaresborough

Sustainability Appraisal refers to this site as having poor access torail services, secondary schooling, GP Provision and shopping

Poor access to cycle routes – sustainable transport solutions shouldbe taken into account when planning new development


The representations made regarding this site sought the following modifications to the Plan:Remove site from the Plan

Table 12.18 Key Issues: K23 Land north of Bar Lane and east of Boroughbridge Road, Knaresborough



K24: Land at Halfpenny Lane and south of Water Lane, Knaresborough


N/ANoted.Support


No amendmentThere is an identified residual housingrequirement to be delivered during theplan period (as set out in Chapter 10 of

The site is too big

A large amount of development has already beengranted in the local area the Local Plan and the Housing

Background Paper) and, through theNo local need for additional housing Local Plan, there is a need to allocate

land to ensure this requirement is met.Local infrastructure cannot cope The council considers that this site canNegative impact on local roads/traffic contribute to meeting this need and the



No or poor access to shops and servicesAs set out in the evidence base, manysites have been considered through thesite selection process. Sites have been

Risk of flooding

Negative impact on the landscape allocated that are considered to offerthe greatest sustainability benefits andNegative impact on local wildlife and biodiversityconsiderations such as the scale of

Other development, access, and impacts onhighways landscape, ecology, heritageDevelopment of this site would further contribute

to the significant problems of air quality at BondEnd and York Place in Knaresborough

assets and flooding were taken intoaccount during the site assessmentprocess.

The area is a haven for wildlife - an excellentteaching resource for local schools Potential adverse impacts of

development of the site were consideredthrough the site assessment process.Where potential adverse impacts wereidentified, it is considered that these arenot insurmountable and could potentiallybe mitigated, as set out in the SiteRequirements. Further assessment ofthese issues will be undertaken as partof the planning application process ifrequired at this stage.

It is recognised that new development,both individual sites and from thecumulative impact of several sites, willplace extra pressure on existinginfrastructure and may need new orimproved infrastructure to support it. Thecouncil continues to work with theCounty Council, utility and otherinfrastructure/service providers to makesure the infrastructure implications ofthe allocated sites are fully assessedand where necessary mitigationmeasures are identified and put in placeto address development impacts.Funding contributions from developerswill be sought where needed to increasecapacity to provide local infrastructure.






Site Requirements

Amend SiteRequirement 9 to read:'... and broadly follows

It is considered that use of the phrase'protect and enhance' addresses therespondent's concern. However, it is

Requirement 9 – does not indicate that as footpathruns through centre of site will require extraordinaryplanning to protect and enhance the recreational and

the route of the formeragreed that reference could be made toamenity value of the path or that the path is a directrail line to Water Lane,the Knaresborough Round as this wouldlink to the Knaresborough Round and almost to

Knaresborough centre along a non-vehicularroute. (NY LAF).

providing a direct link tothe KnaresboroughRound; and the path .....'

be consistent with the approach takento site requirements in respect of otherallocated sites.

No amendment.It is considered that this could beaddressed through the provisions of SiteRequirements 5 and 6.

Requirements should include specific reference toan ecological buffer to the east of the site in order toavoid urban edge effects. (Natural England)

Table 12.19 Key Issues: K24 Land at Halfpenny Lane and south of Water Lane, Knaresborough

K25: Land at Highfield Farm, Knaresborough


N/ANoted.Support allocation



The site is too big

A large amount of development has already beengranted in the local area the Local Plan and the Housing

Background Paper) and, through the LocalLocal infrastructure cannot cope Plan, there is a need to allocate land to

ensure this requirement is met. TheNegative impact on local roads/traffic council considers that this site canLocal schools are full contribute to meeting this need and the

approach taken to the identification of thissite is based on reasonable evidence.Negative impact on local wildlife and biodiversity

As set out in the evidence base, manysites have been considered through thesite selection process. Sites have beenallocated that are considered to offer thegreatest sustainability benefits andconsiderations such as the scale ofdevelopment, access, and impacts onhighways landscape, ecology, heritageassets and flooding were taken intoaccount during the site assessmentprocess.

Potential adverse impacts of developmentof the site were considered through thesite assessment process. Where potentialadverse impacts were identified, it isconsidered that these are notinsurmountable and could potentially bemitigated, as set out in the SiteRequirements. Further assessment ofthese issues will be undertaken as part ofthe planning application process if requiredat this stage.

It is recognised that new development,both individual sites and from thecumulative impact of several sites, willplace extra pressure on existing




infrastructure and may need new orimproved infrastructure to support it. Thecouncil continues to work with the CountyCouncil, utility and otherinfrastructure/service providers to makesure the infrastructure implications of theallocated sites are fully assessed andwhere necessary mitigation measures areidentified and put in place to addressdevelopment impacts. Fundingcontributions from developers will besought where needed to increase capacityto provide local infrastructure.


The representations made regarding this site sought the following modifications to the Plan:Remove site from the PlanFocus should be on new large-scale developments such as Flaxby, Green Hammerton/Cattal, which can be built withthe associated infrastructure, transport links and service provision that is required

Site Requirements

No amendment.Noted.No public right of way over user worksrailway crossing on the northern boundary of the site.Requirements to connect to the public rights of wayon the north side of the railway cannot be achievedas the introduction of a public right of way will importrisk on to the railway and negatively impact on therail infrastructure. (Network Rail).

Table 12.20 Key Issues: K25 Land at Highfield Farm, Knaresborough

K37: Land at Boroughbridge Road, Knaresborough



N/ANoted.Support allocationSite is subject to pending outline planning application, insustainable location on edge of settlement and more thanreasonable prospect of development being achieved.


No amendment.There is an identified residualhousing requirement to bedelivered during the plan

Issues with Evidence BaseNo proof of local housing need justifying suchmassive increasein the number of new homes in the town

period (as set out in Chapter10 of the Local Plan and the

No or poor access to shops and services Housing Background Paper)and, through the Local Plan,

Negative impact on the landscape there is a need to allocate landto ensure this requirement is

Negative impact on the conservation area met. The council considers thatthis site can contribute toA large amount of development has already been granted in the

local area meeting this need and theapproach taken to theidentification of this site isbased on reasonable evidence.

The site is outside the current development limit

Negative impact on local roads/trafficAs set out in the evidencebase, many sites have beenconsidered through the site






Negative impact on the local community selection process. Sites havebeen allocated that areconsidered to offer the greatestNegative impact on local wildlife and biodiversitysustainability benefits and

Other considerations such as theNegative impacts to air quality and potential to adversely affectAir Quality Management Area (Bond End)

scale of development, access,and impacts on highwayslandscape, ecology, heritage

Sustainability appraisal indicates significant impacts in relationto transport, accessibility and cumulative impacts arising frompoor accessibility of the site to both traditional transportnetworks and public transport, cycle and pedestrian routes

assets and flooding were takeninto account during the siteassessment process.


Concerned about the potential for damage to the notifiedfeatures of the Hay-a-Park Site of Special Scientific Interest(SSSI) as a result of increased recreational disturbance. assessment process. WhereBroadly welcome the requirements for mitigation andcompensation, as set out in the site requirements, particularlyin relation to mitigating across the sites. (Natural England)

potential adverse impacts wereidentified, it is considered thatthese are not insurmountableand could potentially bemitigated, as set out in the SiteRequirements. Furtherassessment of these issues willbe undertaken as part of theplanning application process ifrequired at this stage.

It is recognised that newdevelopment, both individualsites and from the cumulativeimpact of several sites, willplace extra pressure onexisting infrastructure and mayneed new or improvedinfrastructure to support it. Thecouncil continues to work withthe County Council, utility andother infrastructure/serviceproviders to make sure theinfrastructure implications ofthe allocated sites are fullyassessed and wherenecessarymitigationmeasuresare identified and put in placeto address developmentimpacts. Funding contributionsfrom developers will be soughtwhere needed to increasecapacity to provide localinfrastructure.


The representations made regarding this site sought the following modifications to the Plan:Remove site from the PlanReduce Plan housing numbersFocus should be on new large-scale developments such as Flaxby, Green Hammerton/Cattal, which can be built withthe associated infrastructure, transport links and service provision that is required

Site Requirement





No amendment.Following discussion HistoricEngland have withdrawn thisobjection.

Requirement 5 - as worded implies that it is acceptable, in principle,to harm these listed buildings. (Historic England)

Amend to read: '.. development of the site should conserve thoseelements which contribute to the significance of this designatedheritage asset, including its setting.'

Table 12.21 Key Issues: K37 Land at Boroughbridge Road, Knaresborough

Ripon Sites

R1: Land adjacent to 63 Bondgate, Ripon



Site Requirement


Requirement 1 - as worded implies that it is acceptable, in principle,to harm these listed buildings. (Historic England).

Requirement 1 - amend to read: '.. development of the site shouldconserve those elements which contribute to the significance of thisdesignated heritage asset, and seek to enhance or better reveal itssetting.' (Historic England).

Table 12.22 Key Issues: R1 Land adjacent to 63 Bondgate, Ripon

R5: Land north of King's Mead, Ripon




Noamendment.

There is an identified residualhousing requirement to bedelivered during the plan period

Site boundary issue

The site is outside the current development limit(as set out in Chapter 10 of the

Previous applications to develop the site have been refused Local Plan and the HousingBackground Paper) and, throughNegative impact on local roads/traffic the Local Plan, there is a need to

Local schools are full allocate land to ensure thisrequirement is met. The council

No or poor access to shops and services considers that this site cancontribute to meeting this need

Risk of flooding and the approach taken to theidentification of this site is basedon reasonable evidence.

Soakaways would not be suitable due to gypsum

Negative impact on the landscape As set out in the evidence base,many sites have been consideredthrough the site selectionNegative impact on local wildlife and biodiversity

Loss of trees and hedgerows process. Sites have beenallocated that are considered tooffer the greatest sustainabilityImpact on nearby Ripon Parks SSSIbenefits and considerations suchas the scale of development,Loss of habitats within the siteaccess, and impacts on highwayslandscape, ecology, heritage

Site is greenfield





Negative impact on heritage assets assets and flooding were takeninto account during the siteassessment process.Ripon Neighbourhood Plan

HBC have, by including site R5, effectively ignored the views ofthe Ripon City team and are acting contrary to the principles setout by HM Government when Neighbourhood planning wascreated.

Potential adverse impacts ofdevelopment of the site wereconsidered through the siteassessment process. Wherepotential adverse impacts wereThe site is outside the development limit proposed in the draft

Ripon City Plan (Neighbourhood Plan) identified, it is considered thatthese are not insurmountable andcould potentially be mitigated, asThe draft Ripon City Plan (Neighbourhood Plan) states that there

is no need to allocate greenfield sites in Ripon set out in the Site Requirements.Further assessment of theseissues will be undertaken as partof the planning applicationprocess if required at this stage.

OtherThe sustainability appraisal recommendation has changeddespite the assessment results not changing/ the site waspreviously considered unsuitable It is recognised that new

development, both individual sitesand from the cumulative impactThe sustainability appraisal results are incorrectof several sites, will place extrapressure on existing infrastructureR5 is unstable - known to have existing gypsum holes. Risk of

subsidence. Also, the groundworks required to R5 could makethe whole of the Kings Mead area unstable. Future anticipatedhigh levels of rainfall - the impacts of this are unknown/a risk.

and may need new or improvedinfrastructure to support it. Thecouncil continues to work with theCounty Council, utility and otherinfrastructure/service providers to

Site unlikely to be deliverable make sure the infrastructureimplications of the allocated sitesare fully assessed and whereUse of the site is limited to its existing use as 'pasture' (Section 52

agreement dated 26th November 1984) necessary mitigation measuresare identified and put in place to

There is a Section 52 agreement between HBC and Dr Barnardos(the owners) that contains a retained covenant for the land use of R5to remain solely as pasture. As far as we are aware, nothing haschanged since this agreement was put in place in November 1984 sothis land should be retained as pasture.

address development impacts.Funding contributions fromdevelopers will be sought whereneeded to increase capacity toprovide local infrastructure.

The Ripon City Plan does notmake any allocations for housing.The Council's considers that tomeet the strategic developmentneeds of the district and toprovide certainty in the deliveryof housing there is a need forallocations to be made in Ripon.

It is possible for a restrictivecovenant under a Section 52Agreement to be discharged andis not a constraint to the allocationof the site.


The representations made regarding this site sought the following modifications to the Plan:Remove site from the Plan (Ripon Civic Society, Ripon City Council)

Amend site boundary to include land immediately to the north

Site Requirements





Noamendment.

The primary pedestrian/cycleaccess from the site will be ontoKings Mead (site requirement 4).

Requirement 5: Little Studley Road is single track, with numerousbends affecting visibility, is without pavements and without streetlighting. To provide a pedestrian access onto such a road, which willbe used by young families with push chairs and young children, isinherently unsound and should not even be proposed

A secondary pedestrian/cycleaccess onto Little Studley Roadis not unreasonable and the needfor any improvements to facilitatethis can be considered atplanning application stage.

Reconsider pedestrian routes to/from the site to avoid pedestrian useof Little Studley Road

Noamendment.

It is considered that this iscovered by the provisions of SiteRequirement 5.

Site requirements make no mention of the route (with public access)along the eastern side of the proposed development, which providesdirect access to the Ripon Rowel Walk. (NY LAF)

Table 12.23 Key Issues: R5 Land north of King's Mead, Ripon

R6: Land at Springfield Close Farm, Ripon



No amendment.Support noted. It should be noted that the yields for theallocated sites are indicative only and the final sitecapacity may vary (either up or down) once a finaldevelopment layout for the site is agreed through theplanning application process.

Support allocation of site but consider siteyield should be increased to 50-60 units.


No amendment.The Ripon City Plan does not make any allocations forhousing. The Council's considers that to meet thestrategic development needs of the district and to providecertainty in the delivery of housing in Ripon there is aneed for allocations to be made.

Greenfield site. The draft Ripon City Plan(Neighbourhood Plan) states that there isno need to allocate greenfield sites inRipon (Ripon Civic Society and Ripon CityCouncil)

Remove site from the plan

Table 12.24 Key Issues: R6 Land at Springfield Close Farm, Ripon

R8: Land at West Lane, Ripon

12.4 On the 25 June 2018, the Secretary of State for Housing, Communities and Local Governmentallowed an appeal and granted outline planning permission for the development of this site.



N/ANoted.Support allocation.Sustainable location on edge of Ripon, subject of pending appeal decision, realisticprospect of housing being developed within 5 years.


N/AOn the 25 June2018, theSecretary of

Fails the duty to co-operateno reference to approaching other LPAs to met Harrogate's housing need.

State forA large amount of development has already been granted in the local area. Housing,

CommunitiesPrevious applications to develop this site have been refused and Local

GovernmentLocal infrastructure cannot cope





Negative impact on local roads/traffic allowed anappeal andgranted outline

No suitable access.

planningNo or poor access to public transport permission for

the developmentof this site.Local schools are full

GPs are full

Poor access to local services

Risk of flooding

Poor drainage


Negative impact on local wildlife and biodiversityThe site is part of a wildlife corridor between Quarry Moor SSSI and the Hell WathNature Reserve

Negative impact on designated heritage assetsStudley Royal Park and Fountains Abbey World Heritage Site

Historic England: Based on available information do not concur that has beenadequately demonstrated that harm to historic environment is capable of mitigationto extent which is commensurate with conserving their significance.

Before allocating site there is need for evaluation, preferably including a ZTV, ofdegree to which development will impact upon views of Cathedral and key viewsfrom WHS.

If harm would result, Plan needs to clearly set out measures by which harm mightbe removed or reduced. If despite mitigation measures still likely to be harm, siteshould not be allocated unless clear public benefits of doing so and set out withinjustification for allocation. Undertake evaluation, preferably including a ZTV, ofdegree to which development will impact upon views of Cathedral and key viewsfrom WHS and amend Plan accordingly.

National Trust: Not demonstrated to any satisfactory degree how harm tosignificance of heritage asset can be mitigated. Sustainability Appraisal is not clearas to which heritage asset has been considered nor has the assessment beenupdated and revised in light of West Lane planning appeal Inquiry.

OtherThe draft Ripon City Plan (Neighbourhood Plan) states that there is no need toallocate greenfield sites in Ripon

number of smaller sites could be allocated that would deliver same yield as siteR8

It is understood that a decision is to be made by the Secretary of State into a'called-in' application for the development of 390 dwellings at this site. This is notjustification to include the site as an allocation in the Local Plan. Until such timeas planning permission has been granted, at which point this would become acommitted housing site and not a proposed allocation it should not be shown onthe Policies Map.


The representations made regarding this site sought the following modifications to the Plan:





Remove site from the PlanPrioritise brownfield sitesBetter reflect the Ripon City Plan

Site Requirements

N/AOn the 25 June2018, theSecretary of

Requirement 2 - should be amended to recognise that protecting views from Gillet Hilldoes not solely relate to views to the Cathedral. (National Trust)

State forAmend second bullet point to read: 'protecting the views to and from Gillet Hill, includingto Ripon Cathedral' Housing,

Communitiesand Local

Requirement 3 - reference should be made to the 'Tower', which is the listed buildingand also that it lies within the RPG and buffer zone to the WHS. (National Trust)

Governmentallowed anappeal and

Add reference to 'The Tower'. Amend second sentence to read: 'Development of thissite should protect views to and from this designated heritage asset lying within theWHSbuffer zone and RPG'

granted outlineplanningpermission forthe developmentof this site.

Requirement 5 - needs to be reference to reducing the visual impact of developmentfrom the WHS and importance of planting being secured in perpetuity in order to doso. (National Trust)

Add reference to reducing the visual impact of development from the WHS and securingplanting in perpetuity

Requirement 11 - should look for opportunities to enhance nearby routes (NationalTrust)

amend to read: '... Ripon Rowell Footpath providing public access into theWHS' (NationalTrust).

Table 12.25 Key Issues R8 Land at West Lane, Ripon

R24: Deverell Barracks, Ripon



N/ANoted.Support allocation and statement that site should be brought forward aspart of a comprehensive masterplan which should be prepared for this sitein combination with sites R25: Claro Barracks and R27: Laver Banks.(Defence Infrastructure Organisation (DIO)).

Table 12.26 Key Issues: R24 Deverell Barracks, Ripon

R27: Laver Banks, Clotherholme Road, Ripon



Noammendment

In selecting this site as an allocation, theCouncil considered that the site was not withinor affected the setting of the World heritage

Before allocating site there is need for evaluation of degreeto which development will impact upon the elements whichcontribute to the Outstanding Universal Value of the WHSand significance of other designated heritage assets in itsvicinity.

site. Consultants acting for the site promoterare preparing a masterplan for the threebarracks sites in consultation with the Council.this will include a further evaluation of the





If harmwould result, Plan needs to clearly set out measuresby which harm might be removed or reduced. If despitemitigation measures still likely to be harm, site should notbe allocated unless clear public benefits of doing so.(Historic England).

impacts on the historic environment. TheCouncil will continue to have dialogue withHistoric England on this matter

Undertake evaluation of degree to which development willimpact upon the elements which contribute to theOutstanding Universal Value of the WHS and significanceof other designated heritage assets in its vicinity and amendPlan accordingly.

Noamendment.

As a masterplan for the development of theRipon Barrack sites is at an early stage ofpreparation and subject to change, it would be

Support allocation but seek the defined boundary to beextended to include land to the south. Will enable the greeninfrastructure to be protected and enhanced as part of thecomprehensive masterplan. (Defence InfrastructureOrganisation (DIO)).

Amend site boundary to include land to the south ofallocated site. (Defence Infrastructure Organisation.

premature to amend the boundary. It shouldalso be noted Policy GS3 provides flexibility toenable sites adjoining development limits tocome forward.

Table 12.27 Key Issues: R27 Laver Banks, Clotherholme Road, Ripon



Boroughbridge SitesAmendmentto the Plan


Noamendment

There is an identified residual housing requirement to be delivered during the planperiod (as set out in Chapter 10 of the Local Plan and the Housing BackgroundPaper) and, through the Local Plan, there is a need to allocate land to ensure this

Concern at scale ofdevelopment inBoroughbridge

requirement is met. The council considers that this site can contribute to meetingthis need and the approach taken to the identification of this site is based onreasonable evidence.

Proposeddevelopment woulddouble population

As set out in the evidence base, many sites have been considered through the siteselection process. Sites have been allocated that are considered to offer the greatestsustainability benefits and considerations such as the scale of development, access,and impacts on highways landscape, ecology, heritage assets and flooding weretaken into account during the site assessment process.

Unsustainablepressure on localinfrastructure

One of the few'self-contained' markettowns left in the districtPotential adverse impacts of development of the site were considered through the

site assessment process. Where potential adverse impacts were identified, it isconsidered that these are not insurmountable and could potentially be mitigated,as set out in the Site Requirements. Further assessment of these issues will beundertaken as part of the planning application process if required at this stage.

It is recognised that new development, both individual sites and from the cumulativeimpact of several sites, will place extra pressure on existing infrastructure and mayneed new or improved infrastructure to support it. The council continues to workwith the County Council, utility and other infrastructure/service providers to makesure the infrastructure implications of the allocated sites are fully assessed andwhere necessary mitigation measures are identified and put in place to addressdevelopment impacts. Funding contributions from developers will be sought whereneeded to increase capacity to provide local infrastructure.

Table 12.28

B2: Land west of Leeming Lane, Langthorpe



N/ANoted.Support - no issues with site requirements and supportexpected delivery timing in housing trajectory




Risk of floodingthe Local Plan and the Housing

Poor drainage Background Paper) and, through theLocal Plan, there is a need to allocatePrevious applications to develop the site have been refused land to ensure this requirement is met.

Local infrastructure cannot cope The council considers that this site cancontribute to meeting this need and the

Negative impact on local roads approach taken to the identification ofthis site is based on reasonableevidence.Local schools are full

No access to shops or services As set out in the evidence base, manysites have been considered through thesite selection process. Sites have beenIssue with consultation

allocated that are considered to offerLoss of open spacethe greatest sustainability benefits andBelieve the village benefits from the amenity value of the

field (Langthorpe Parish Council) considerations such as the scale ofdevelopment, access, and impacts onhighways landscape, ecology, heritage





assets and flooding were taken intoaccount during the site assessmentprocess.

Other:Lack of employment

Access and egress from the site on to Leeming Lanewould be dangerous Potential adverse impacts of

development of the site wereconsidered through the site assessmentDevelopment of this site would seriously harm the

character of the village process. Where potential adverseimpacts were identified, it is consideredthat these are not insurmountable andcould potentially be mitigated, as setout in the Site Requirements. Furtherassessment of these issues will beundertaken as part of the planningapplication process if required at thisstage.

It is recognised that new development,both individual sites and from thecumulative impact of several sites, willplace extra pressure on existinginfrastructure and may need new orimproved infrastructure to support it.The council continues to work with theCounty Council, utility and otherinfrastructure/service providers to makesure the infrastructure implications ofthe allocated sites are fully assessedand where necessary mitigationmeasures are identified and put in placeto address development impacts.Funding contributions from developerswill be sought where needed toincrease capacity to provide localinfrastructure.



Effective drainage would need to be put in place to remove flood waters to the river Ure even when the river is flooded.

Site Requirements

No amendment.Following discussion Historic Englandhas withdrawn this objection in so faras it relates to line 2. They still wish to

Requirement 1 - as worded implies that it is acceptable, inprinciple, to harm the conservation area.

see the word investigating deleted fromAlso as worded only requires developers to 'investigate theprovision' of such a buffer. If this is necessary to ensuredevelopment takes place in a manner consistent withappropriate conservation of Conservation Area, it should be arequirement. (Historic England)

the 3rd line. It is consideredappropriate to require the open spacebuffer to be investigated as the natureand extent of it will be determined bythe nature of the scheme.

Amend to read: '.. development of the site should conservethose elements which contribute to the significance of thisdesignated heritage asset, including its setting; this shouldinclude the provision of an open space buffer....'





N/AFollowing discussion Historic Englandhas withdrawn this objection.

Requirement 3 - as worded implies that it is acceptable, inprinciple, to harm a building identified as making a positivecontribution to the character of the conservation area. (HistoricEngland)

Amend to read: '.. development of the site should conservethose elements which contribute to the significance of thisnon-designated heritage asset...'

Table 12.29 Key Issues: B2 Land west of Leeming Lane, Langthorpe

B4: Land north of Aldborough Gate, Boroughbridge



N/ASupport noted. It should be noted that theyields for the allocated sites are indicativeonly and the final site capacity may vary

Support allocation - but yield should be increased to 185dwellings to reflect pending planning application.

(either up or down) once a finaldevelopment layout for the site is agreedthrough the planning application process:this will be reflected in the housingtrajectory. However, as the planningapplication is still pending and may besubject to further amendment it would bepremature to amend the indicative yieldin the Plan at this stage.


Noamendment.

There is an identified residual housingrequirement to be delivered during theplan period (as set out in Chapter 10 of

The site is too big

A large amount of development has already bee granted inthe local area the Local Plan and the Housing

Existing permissions with allocations will effectivelydouble the size of the town

Background Paper) and, through the LocalPlan, there is a need to allocate land toensure this requirement is met. Thecouncil considers that this site can

No local need for additional housing contribute to meeting this need and theapproach taken to the identification of thissite is based on reasonable evidence.Negative Impact on local roads/ traffic

Aldborough Gate is congested and not safe forpedestrians As set out in the evidence base, many

sites have been considered through thesite selection process. Sites have beenAccess arrangements for traffic have not been

considered allocated that are considered to offer thegreatest sustainability benefits andconsiderations such as the scale of

Local schools are full development, access, and impacts onhighways landscape, ecology, heritage

Poor access to shops and services assets and flooding were taken intoaccount during the site assessmentprocess.Loss of agricultural land

No or poor access to public transportPotential adverse impacts of developmentof the site were considered through thesite assessment process. Where potential

New bus links needed

Local infrastructure cannot cope adverse impacts were identified, it isconsidered that these are not

Risk of flooding insurmountable and could potentially bemitigated, as set out in the SiteBoroughbridge already prone to floodingRequirements. Further assessment of





these issues will be undertaken as part ofthe planning application process ifrequired at this stage.

Negative impact on landscapeSettlement edge is changed to a hard border with roadrather than merging into countryside

It is recognised that new development,both individual sites and from thecumulative impact of several sites, will


Other place extra pressure on existingNo evidence that impact on climate change orincorporation of sustainable building practices have beentaken into account.

infrastructure and may need new orimproved infrastructure to support it. Thecouncil continues to work with the CountyCouncil, utility and otherinfrastructure/service providers to makeLack of employment.sure the infrastructure implications of theallocated sites are fully assessed and

In view of uncertainty regarding extent archaeology mightconstrain development of Site B22, northern part of site shouldnot be identified for housing until confirmed whether Site B22is likely to be developable (Historic England).

where necessary mitigation measures areidentified and put in place to addressdevelopment impacts. Fundingcontributions from developers will besought where needed to increase capacityto provide local infrastructure.Add requirement that northern 2.3ha would be reserved for

future educational use until such time has been confirmedwhether Site B22 is likely to be developed for its intendedpurpose

Work undertaken by developers promotingland in this area has shown that there isno nationally important archaeology in thearea. The education authority hasconfirmed that the extension land requiredfor the school would be utilised for playingpitches and not built development.


The representations made regarding this site sought the following modifications to the Plan:Remove site from PlanSignificantly reduce scale of siteImprove infrastructure before proposals are agreed

Table 12.30 Key Issues: B4 Land north of Aldborough Gate, Boroughbridge

B10: Old Hall Caravan Park, Langthorpe






Local infrastructure cannot copePlan and the Housing Background Paper) and,

Negative impact on local roads through the Local Plan, there is a need toallocate land to ensure this requirement is met.Poor access to public transport The council considers that this site can

Local schools are full contribute to meeting this need and theapproach taken to the identification of this siteis based on reasonable evidence.Poor access to shops and services.

Issue with consultation As set out in the evidence base, many siteshave been considered through the siteselection process. Sites have been allocatedOther:

Lack of employment. that are considered to offer the greatestsustainability benefits and considerations suchas the scale of development, access, and





impacts on highways landscape, ecology,heritage assets and flooding were taken intoaccount during the site assessment process.

Potential adverse impacts of development ofthe site were considered through the siteassessment process.Where potential adverseimpacts were identified, it is considered thatthese are not insurmountable and couldpotentially be mitigated, as set out in the SiteRequirements. Further assessment of theseissues will be undertaken as part of theplanning application process if required at thisstage.

It is recognised that new development, bothindividual sites and from the cumulative impactof several sites, will place extra pressure onexisting infrastructure and may need new orimproved infrastructure to support it. Thecouncil continues to work with the CountyCouncil, utility and other infrastructure/serviceproviders to make sure the infrastructureimplications of the allocated sites are fullyassessed and where necessary mitigationmeasures are identified and put in place toaddress development impacts. Fundingcontributions from developers will be soughtwhere needed to increase capacity to providelocal infrastructure.



Site Requirement

No amendment.The advice of the Highway Authority is that itis unlikely the existing access can beupgraded to an adoptable standard.

Requirement 6 - existing access point to CaravanPark can accommodate level of developmentproposed

Amend site requirement 6 to enable separateaccess to be achieved using current access pointon Skelton Road.

Table 12.31 Key Issues: B10 Old Hall Caravan Park, Langthorpe

B11: Land at the Bungalow, Boroughbridge






Negative impact on local roadsPlan and the Housing Background Paper) and,

Poor access to public transport through the Local Plan, there is a need toallocate land to ensure this requirement is met.Local infrastructure cannot cope The council considers that this site can





Local schools are full contribute to meeting this need and theapproach taken to the identification of this siteis based on reasonable evidence.Poor access to shops and services

Issue with consultation As set out in the evidence base, many siteshave been considered through the site selectionprocess. Sites have been allocated that are

Other:Lack of employment considered to offer the greatest sustainability

benefits and considerations such as the scaleof development, access, and impacts onhighways landscape, ecology, heritage assetsand flooding were taken into account during thesite assessment process.

Potential adverse impacts of development ofthe site were considered through the siteassessment process. Where potential adverseimpacts were identified, it is considered thatthese are not insurmountable and couldpotentially be mitigated, as set out in the SiteRequirements. Further assessment of theseissues will be undertaken as part of the planningapplication process if required at this stage.




Table 12.32 Key Issues: B11 Land at the Bungalow, Boroughbridge

B12: Land at Stump Cross, Boroughbridge



N/ANoted.Support allocationSubject of pending outline planning application, no technicalimpediments to delivery.



The site is disproportionate to the size of the town(Boroughbridge TownCouncil, Marton-cum-Grafton PC)

A large amount of development has already been granted in the local area delivered during the planperiod (as set out in

No local need for additional housing (Boroughbridge Town Council)





No or poor access to shops and services Chapter 10 of the LocalPlan and the HousingBackground Paper) and,Negative impact on the landscapethrough the Local Plan,

Local infrastructure cannot cope (Boroughbridge Town Council there is a need to allocateland to ensure this

Marton-cum-Grafton PC) requirement is met. Thecouncil considers that thissite can contribute to

Negative impact on local roads/ traffic (Marton-cum-Grafton PC) meeting this need and the

No access to public transport approach taken to theidentification of this site isbased on reasonableevidence.


GP's are fullAs set out in the evidencebase, many sites havebeen considered through

Poor drainage

Site is a greenfield site the site selection process.Sites have been allocatedLoss of agricultural land that are considered to

Impact on heritage assets offer the greatestsustainability benefits andconsiderations such asSite likely to contain significant amount of archaeological remains with high

probability that many of these remains will be of national importance.Disagree with conclusion of 2016 Built and Natural Environment Site

the scale of development,access, and impacts onhighways landscape,Assessment that impact of development on site upon historic environmentecology, heritage assetsdid not need evaluating. Before allocating site there is need for evaluationand flooding were takeninto account during thesite assessment process.

of impact loss of site and future development might have upon elementswhich contribute to significance of heritage assets in the vicinity. If harmwould result, Plan needs to clearly set out measures by which harm mightbe removed or reduced. If despite mitigation measures still likely to beharm, site should not be allocated unless clear public benefits that outweighthe harm. (Historic England)

Potential adverse impactsof development of the sitewere considered throughthe site assessmentUndertake evaluation of impact loss of site and future development might

have upon elements which contribute to significance of heritage assets inthe vicinity and amend Plan accordingly

process. Where potentialadverse impacts wereidentified, it is consideredthat these are not

Issue with consultation (Boroughbridge Town Council) insurmountable and couldpotentially be mitigated,

Other: as set out in the SiteRequirements. FurtherWill change character and form of Boroughbridge to a linear

development down towards A59 assessment of theseissues will be undertakenas part of the planningapplication process ifrequired at this stage.

Should be noted site accommodates several office based businesseswhich will need to be relocated as part of proposals.

Lack of employmentIt is recognised that newdevelopment, bothindividual sites and fromNoise pollution from A1(M)

the cumulative impact ofImpact on climate change and the extent of Boroughbridge as asustainable centre.

several sites, will placeextra pressure on existinginfrastructure and mayneed new or improvedinfrastructure to supportit. The council continuesto work with the CountyCouncil, utility and otherinfrastructure/serviceproviders to make surethe infrastructure





implications of theallocated sites are fullyassessed and wherenecessary mitigationmeasures are identifiedand put in place toaddress developmentimpacts. Fundingcontributions fromdevelopers will be soughtwhere needed to increasecapacity to provide localinfrastructure.

The promoter of the sitehas undertaken detailedarchaeologicalinvestigations whichindicate that there isunlikely to be nationallyimportant archaeology onthe site.



Significantly reduce the size of the site

Improve infrastructure before proposals are agreed

Should be zero carbon development incorporating latest building standards/contribute to improved public transportlinks/safe pedestrian and cycle access across Aldborough Gate

Table 12.33 Key Issues: B12 Land at Stump Cross, Boroughbridge

B18: Old Poultry Farm, Leeming Lane, Langthorpe



N/ANoted.Support




Local infrastructure cannot copePlan and the Housing Background Paper) and,

Negative impact on local roads through the Local Plan, there is a need toallocate land to ensure this requirement is met.Poor access to public transport The council considers that this site can

Poor access to shops and services contribute to meeting this need and theapproach taken to the identification of this siteis based on reasonable evidence.Local schools are full

Issue with consultation As set out in the evidence base, many siteshave been considered through the site selectionprocess. Sites have been allocated that areOther:





considered to offer the greatest sustainabilitybenefits and considerations such as the scaleof development, access, and impacts on

lack of employment

highways landscape, ecology, heritage assetsand flooding were taken into account during thesite assessment process.

Potential adverse impacts of development ofthe site were considered through the siteassessment process. Where potential adverseimpacts were identified, it is considered thatthese are not insurmountable and couldpotentially be mitigated, as set out in the SiteRequirements. Further assessment of theseissues will be undertaken as part of the planningapplication process if required at this stage.




Table 12.34 Key Issues: B18 Old Poultry Farm, Leeming Lane, Langthorpe

B21: Land at Aldborough Gate, Boroughbridge



N/ANoted.Support allocation:Logical extension to eastern Boroughbridge when considered with B4 andB22

setting of Conservation Area and Roman Town Scheduled Monumentpreserved through large area of public open space in north east portionof site

site could come forward in first 5 years of plan period


Noamendment.

There is an identifiedresidual housingrequirement to be

Coalescence (Marton-cum-Grafton PC)Loss of identity of Boroughbridge and Aldborough

delivered during theNo local need for additional housing (Boroughbridge Town Council). plan period (as set out





in Chapter 10 of theLocal Plan and theHousing Background

A large amount of development has already been granted in the local areaamount of allocations and existing permissions is disproportionate to sizeof Boroughbridge/ will effectively double the size of Boroughbridge(Marton-cum-Grafton PC). Paper) and, through the

Local Plan, there is aneed to allocate land to

Local infrastructure cannot cope (Marton-cum-Grafton PC, Boroughbridge TownCouncil).

ensure this requirementis met. The councilconsiders that this site

Negative impact on local roads/ traffic (Marton-cum-Grafton PC) can contribute toRoads already congested meeting this need and

the approach taken tothe identification of thissite is based onreasonable evidence.

Pedestrian and vehicle safety of Chapel Hill junction needs to beconsidered.

Poor access to public transport As set out in theevidence base, manysites have beenLocal schools are fullconsidered through the

Poor drainage site selection process.Drainage already a problem Sites have been

allocated that areconsidered to offer the

Flooding greatest sustainabilitybenefits and

Negative impact on landscape considerations such asthe scale ofLoss of agricultural landdevelopment, access,

The site is a greenfield site and impacts onhighways landscape,

Negative impact on wildlife and biodiversity ecology, heritageassets and floodingBats, sparrowhawks and owls nest in woods opposite the sitewere taken into accountduring the siteassessment process.

Loss of habitat of greenfield site.

Negative impact on conservation area (Marton-cum-Grafton PC, BoroughbridgeTown Council and Historic England).

Potential adverseimpacts of developmentof the site were

Negative impact on designated heritage asset considered through thesite assessmentAldborough Roman Site (Marton-cum-Grafton PC/

Boroughbridge Town Council)process. Wherepotential adverseimpacts were identified,it is considered thatSte contains significant amount of archaeological remains with high

probability that many of these remains will be of national importance.Disagree with conclusion of Conservation and Design Site Assessment

these are notinsurmountable andcould potentially bethat harm to historic environment is capable of mitigation. Unless can be

demonstrated substantial public benefits which would outweigh this harm,allocation should be deleted. (Historic England)

mitigated, as set out inthe Site Requirements.Further assessment ofthese issues will be

Issue with consultation (Boroughbridge Town Council). undertaken as part ofthe planning applicationprocess if required atthis stage.

HBC have disregarded responses to previous consultation on this site.

Other:It is recognised thatnew development, bothindividual sites and

Lack of employment

Cumulative impact of this site and others will double the size of the town from the cumulativeimpact of several sites,

Impact upon the character of the village will place extrapressure on existing





infrastructure and mayneed new or improvedinfrastructure to supportit. The councilcontinues to work withthe County Council,utility and otherinfrastructure/serviceproviders to make surethe infrastructureimplications of theallocated sites are fullyassessed and wherenecessary mitigationmeasures are identifiedand put in place toaddress developmentimpacts. Fundingcontributions fromdevelopers will besought where neededto increase capacity toprovide localinfrastructure.

The promoter of siteswithin this area hasundertaken moredetailed archaeologyinvestigations that hasrevealed that there isunlikely to be nationallyimportant archaeologyon the site.

Modification sought

The representations made regarding this site sought the following modifications to the Plan:Remove site from the PlanDistribute housing equally across the District

Table 12.35 Key Issues: B21 Land at Aldborough Gate, Boroughbridge

Masham Site

M8: Land north of Swinton Road, Masham




No amendment.There is an identified residual housing requirementto be delivered during the plan period (as set out inChapter 10 of the Local Plan and the Housing

Local infrastructure cannot copeSewerage: The sewage works continuesto have problems- tankers are used tocarry waste away from the works Background Paper) and, through the Local Plan,

there is a need to allocate land to ensure thisrequirement is met. The council considers that this

Negative impact on local roads/traffic site can contribute to meeting this need and theapproach taken to the identification of this site isbased on reasonable evidence.





As set out in the evidence base, many sites havebeen considered through the site selection process.Sites have been allocated that are considered to

This is a rural area with poor publictransport where inhabitants have to owna car. Developing the site will lead to anincrease in traffic offer the greatest sustainability benefits and

considerations such as the scale of development,access, and impacts on highways landscape,ecology, heritage assets and flooding were takeninto account during the site assessment process.


Risk of floodingPotential adverse impacts of development of thesite were considered through the site assessmentprocess. Where potential adverse impacts wereidentified, it is considered that these are notinsurmountable and could potentially be mitigated,as set out in the Site Requirements. Furtherassessment of these issues will be undertaken aspart of the planning application process if requiredat this stage.

It is recognised that new development, bothindividual sites and from the cumulative impact ofseveral sites, will place extra pressure on existinginfrastructure and may need new or improvedinfrastructure to support it. The council continuesto work with the County Council, utility and otherinfrastructure/service providers to make sure theinfrastructure implications of the allocated sites arefully assessed and where necessary mitigationmeasures are identified and put in place to addressdevelopment impacts. Funding contributions fromdevelopers will be sought where needed to increasecapacity to provide local infrastructure.


The representations made regarding this site sought the following modifications to the Plan:The field should be retained as a soakaway to ensure slow drainage to local rivers

Table 12.36 Key Issues: M8 Land north of Swinton Road, Masham

M13: Land at Thorpe Road, Masham






Negative impact on conservation areaPlan and the Housing Background Paper)

Other: and, through the Local Plan, there is a needRecent planning application on part of siteM13 refused (in part) due to proximity toanimal feed mill suggesting must beconsiderable doubt as to acceptability ofdevelopment on site.

to allocate land to ensure this requirementis met. The council considers that this sitecan contribute to meeting this need and theapproach taken to the identification of thissite is based on reasonable evidence.





As set out in the evidence base, many siteshave been considered through the siteselection process. Sites have been allocated

Proximity of development to Mill likely to giverise to noise complaints from future occupierswith potential to impact on operation ofbusiness. that are considered to offer the greatest

sustainability benefits and considerationssuch as the scale of development, access,Site boundary should be amended to exclude

southern part of site and include land to theeast (as included in planningapplication 16/404659/OUTMAJ)

and impacts on highways landscape,ecology, heritage assets and flooding weretaken into account during the siteassessment process.

Potential adverse impacts of developmentof the site were considered through the siteassessment process. Where potentialadverse impacts were identified, it isconsidered that these are notinsurmountable and could potentially bemitigated, as set out in the SiteRequirements. Further assessment of theseissues will be undertaken as part of theplanning application process if required atthis stage.

It is recognised that new development, bothindividual sites and from the cumulativeimpact of several sites, will place extrapressure on existing infrastructure and mayneed new or improved infrastructure tosupport it. The council continues to work withthe County Council, utility and otherinfrastructure/service providers to make surethe infrastructure implications of theallocated sites are fully assessed and wherenecessary mitigationmeasures are identifiedand put in place to address developmentimpacts. Funding contributions fromdevelopers will be sought where needed toincrease capacity to provide localinfrastructure.

The outline planning application referred towas recommended for approval with acondition that would require the submissionof any reserved matters application to beaccompanied by a Noise Mitigation Schemethat demonstrated on a plot by plot basishow certain sound levels would be achieved.An appeal against the refusal of thisapplication is currently ongoing.


The representations made regarding this site sought the following modifications to the Plan:Delete allocation

Site Requirements

N/AFollowing discussion Historic England haswithdrawn this objection.

Requirement 2 - as worded implies that it isacceptable, in principle, to harm the conservationarea and listed building. (Historic England)





amend to read: '.. development of the site shouldconserve those elements which contribute to thesignificance of these designated heritage assets,including their setting.'

Amend SiteRequirement 9 to read:'.... if diverted routes

Agree that the suggested amendmentshould be made.

Requirement 9 – on other sites requirementsregarding footpaths use phrase ‘enhance andprotect’, which is equally applicable in this case.Seeking to “downgrade” the status of these two through the site arefootpaths – with links to the Ripon Rowell Walk –undermines the soundness of the proposal for thissite (NY LAF).

necessary, theseshould deliver a goodlevel of protect andenhance therecreational andamenity value of therights of way'

Table 12.37 Key Issues: M13 Land at Thorpe Road, Masham

Pateley Bridge Site

P1: Land south of Ashfield Court (smaller site), Pateley Bridge



N/ASupport noted. It should be noted that the yields for theallocated sites are indicative only and the final site capacitymay vary (either up or down) once a final developmentlayout for the site is agreed through the planningapplication process.

Support - but potential yield should beamended to minimum of 84 dwellings.

Site Requirements

No amendment.Given the relationship of the sites to each other it isconsidered that a comprehensive development to enablea consistent and integrated approach to design acrossthe three sites is appropriate.

Allow P1, P5 and P10 to be developedseparately by preparing site requirementsfor each site or adding a note in thesummary to state that each site can bydeveloped separately.

Table 12.38 Key Issues: P1 land south of Ashfield Court, Pateley Bridge

P5: Grassfield Court, Pateley Bridge



Site Requirements

No amendment.Given the relationship of the sites to each otherit is considered that a comprehensive developmentto enable a consistent and integrated approach todesign across the three sites is appropriate.

Allow P1, P5 and P10 to be developedseparately by preparing site requirements foreach site or adding a note in the summary tostate that each site can by developedseparately.

Table 12.39 Key Issues: P5 Grassfield Court, Pateley Bridge

P7: Former Highways Depot, Pateley Bridge


Site Requirements




N/AFollowing discussion HistoricEngland has withdrawn thisobjection.

Requirement 2 - as worded implies that it is acceptable,in principle, to harm the conservation area (HistoricEngland)

Amend to read: '.. development of the site shouldconserve those elements which contribute to thesignificance of this designated heritage asset and seekto enhance its setting.'

Amend Site Requirement 8 toread: '... of the site shouldprotect and enhance therecreational and amenity valueof ....'

Agree that the suggestedamendment should be made.

Requirement 8 – on other sites requirements regardingfootpaths use phrase ‘enhance and protect’, which isequally applicable in this case (NYLAF)

Table 12.40 Key Issues: P7 Former Highways Depot, Pateley Bridge

P10: Grassfield House, Pateley Bridge



Site Requirements

No amendment.Given the relationship of the sites to each otherit is considered that a comprehensive developmentto enable a consistent and integrated approach todesign across the three sites is appropriate.

Allow P1, P5 and P10 to be developedseparately by preparing site requirements foreach site or adding a note in the summary tostate that each site can by developedseparately.

Table 12.41 Key Issues: P10 Grassfield House, Pateley Bridge

Birstwith Sites

BW9: Land to the south of Clint Bank, Birstwith

12.5 Since the Publication Local Plan was published for consultation, the Council have grantedoutline planning permission for the erection of up to 14 dwellings. The decision notice wasissued on the 17 July 2018.


N/ANoted.Support allocation - subject of pending outline planningapplication

Table 12.42 Key Issues: BW9 Land to the south of Clint Bank, Birstwith

BW10: Land south of Wreaks Road (smaller site), Birstwith



No amendment.Support for allocation noted. It isacknowledged that a larger site area has beenpromoted to the Local Plan for development,

Support allocation but should be extended to includeall of the available surplus operational land.

however, the southern part of the promotedsite has been excluded to minimise the impactof development on the landscape.







A large amount of development has already beengranted within the local area

Negative impact on local roads/ traffic Plan and the Housing Background Paper) and,On-street parking is already an issue from thevillage green to the mill making the road toonarrow and dangerous. Development willexacerbate this.

through the Local Plan, there is a need toallocate land to ensure this requirement is met.The council considers that this site cancontribute to meeting this need and theapproach taken to the identification of this siteis based on reasonable evidence.

Poor access to public transportAs set out in the evidence base, many siteshave been considered through the siteselection process. Sites have been allocated


GPs/ dentists are full that are considered to offer the greatestPoor drainage sustainability benefits and considerations such

as the scale of development, access, andThe site is in the AONB impacts on highways landscape, ecology,

heritage assets and flooding were taken intoaccount during the site assessment process.Negative impact on designated heritage assets

Other Potential adverse impacts of development ofthe site were considered through the siteassessment process. Where potential adverse

Lack of employment

impacts were identified, it is considered thatLoss of amenity space used for Annual Show.these are not insurmountable and couldpotentially be mitigated, as set out in the SiteNegative impact on post office and school

buildings. Requirements. Further assessment of theseissues will be undertaken as part of theplanning application process if required at thisstage.




Table 12.43 Key Issues: BW10 Land south of Wreaks Road, Birstwith



Bishop Monkton Sites

BM2: Former allotments off Knaresborough Road, Bishop Monkton



No amendment.Support noted. It should be noted that theyields for the allocated sites are indicativeonly and the final site capacity may vary

Support allocation of the site but site yield shouldbe increased to minimum of 50 dellings

(either up or down) once a final developmentlayout for the site is agreed through theplanning application process.



The site is too big

No local need for additional housingPlan and the Housing Background Paper)

Local infrastructure cannot cope and, through the Local Plan, there is a needto allocate land to ensure this requirement isNegative impact on local roads/traffic met. The council considers that this site can

No or poor access to shops and services contribute to meeting this need and theapproach taken to the identification of thissite is based on reasonable evidence.Poor drainage

Issue with consultation As set out in the evidence base, many siteshave been considered through the siteselection process. Sites have been allocatedNegative impact on the local communitythat are considered to offer the greatest

Other sustainability benefits and considerationsThe proposed allocations would increasehousing stock in the village by 33%.

such as the scale of development, access,and impacts on highways landscape, ecology,heritage assets and flooding were taken intoaccount during the site assessment process.Negative impact on the character of the village

(very high density development)Potential adverse impacts of development ofthe site were considered through the siteassessment process. Where potential

The type of housing planned does not accordwith the needs identified in the parish plan(affordable housing for young families andbungalows for the elderly)

adverse impacts were identified, it isconsidered that these are not insurmountableand could potentially be mitigated, as set outin the Site Requirements. Further assessmentof these issues will be undertaken as part ofthe planning application process if requiredat this stage.

It is recognised that new development, bothindividual sites and from the cumulativeimpact of several sites, will place extrapressure on existing infrastructure and mayneed new or improved infrastructure tosupport it. The council continues to work withthe County Council, utility and otherinfrastructure/service providers to make surethe infrastructure implications of the allocatedsites are fully assessed and where necessarymitigation measures are identified and put inplace to address development impacts.Funding contributions from developers willbe sought where needed to increase capacityto provide local infrastructure.






The representations made regarding this site sought the following modifications to the Plan:Reduce size of siteStipulate a housing mix that responds to needs of the villageImplement suitable safety improvements at dangerous cross roads

Table 12.44 Key Issues: BM2 Former allotments off Knaresborough Road, Bishop Monkton

BM3: Land at Church Farm, Bishop Monkton



N/ANoted.Support allocation of site



The site is too big

No local need for additional housing(as set out in Chapter 10 of the

Local infrastructure cannot cope Local Plan and the HousingBackground Paper) and, throughNegative impact on local roads/traffic the Local Plan, there is a need to

No or poor access to shops and services allocate land to ensure thisrequirement is met. The council

Risk of flooding considers that this site cancontribute to meeting this need

Poor drainage and the approach taken to theidentification of this site is basedon reasonable evidence.Negative impact on listed building

Negative impact on the local community As set out in the evidence base,many sites have been consideredthrough the site selection

Other:Negative impact on the local economy through the lossof a well-used and viable caravan park business (lossof employment and loss of support for other localbusinesses).

process. Sites have beenallocated that are considered tooffer the greatest sustainabilitybenefits and considerations suchas the scale of development,

Site description incorrectly lists the existing use asagricultural.

access, and impacts on highwayslandscape, ecology, heritageassets and flooding were takeninto account during the siteassessment process.

The proposed allocations would increase housing stockin the village by 33%.


Negative impact on the character of the village (veryhigh density development)

assessment process. WhereThe type of housing planned does not accord with theneeds identified in the parish plan (affordable housingfor young families and bungalows for the elderly)

potential adverse impacts wereidentified, it is considered thatthese are not insurmountable andcould potentially be mitigated, asset out in the Site Requirements.Further assessment of theseissues will be undertaken as partof the planning applicationprocess if required at this stage.

It is recognised that newdevelopment, both individualsites and from the cumulativeimpact of several sites, will placeextra pressure on existing





infrastructure andmay need newor improved infrastructure tosupport it. The council continuesto work with the County Council,utility and otherinfrastructure/service providersto make sure the infrastructureimplications of the allocated sitesare fully assessed and wherenecessary mitigation measuresare identified and put in place toaddress development impacts.Funding contributions fromdevelopers will be sought whereneeded to increase capacity toprovide local infrastructure.


The representations made regarding this site sought the following modifications to the Plan:Reduce the size of the site

Stipulate a housing mix that responds to needs of the village

Implement suitable safety improvements at the dangerous cross roads

Site Requirements


Requirement 2 - as worded implies that it is acceptable, inprinciple, to harm this listed building (Historic England)

Amend to read: '.. development of the site should conservethose elements which contribute to the significance of thisdesignated heritage asset, and should seek opportunities...'

Amend SiteRequirement 8 to read:'.. to the adjacent public

Agree that the suggestedamendment should be made.

Requirement 8 – the adjacent footpath is the Ripon RowelWalk and its importance should be recognized so as toreinforce the need for the pedestrian link (NY LAF).

footpath (the RiponRowel Walk) in order toaccess....'

Table 12.45 Key Issues: BM3 Land at Church Farm, Bishop Monkton

BM4: Land at Knaresborough Road, Bishop Monkton



No amendment.Support noted. It should be noted that theyields for the allocated sites are indicativeonly and the final site capacity may vary

Support allocation of the site but site yield shouldbe increased to minimum of 50 dellings

(either up or down) once a final developmentlayout for the site is agreed through theplanning application process.



The site is too big

No local need for additional housingPlan and the Housing Background Paper)





Local infrastructure cannot cope and, through the Local Plan, there is a needto allocate land to ensure this requirement ismet. The council considers that this site canNegative impact on local roads/trafficcontribute to meeting this need and theapproach taken to the identification of thissite is based on reasonable evidence.


Poor drainage

Negative impact on the local community As set out in the evidence base, many siteshave been considered through the siteselection process. Sites have been allocatedIssue with consultationthat are considered to offer the greatest

Other sustainability benefits and considerationssuch as the scale of development, access,Negative impact on the character of the village

(very high density development) and impacts on highways landscape, ecology,heritage assets and flooding were taken intoaccount during the site assessment process.The proposed allocations would increase

housing stock in the village by 33%.Potential adverse impacts of development ofthe site were considered through the siteassessment process. Where potential

The type of housing planned does not accordwith the needs identified in the parish plan(affordable housing for young families andbungalows for the elderly)

adverse impacts were identified, it isconsidered that these are not insurmountableand could potentially be mitigated, as set outin the Site Requirements. Further assessmentof these issues will be undertaken as part ofthe planning application process if requiredat this stage.

It is recognised that new development, bothindividual sites and from the cumulativeimpact of several sites, will place extrapressure on existing infrastructure and mayneed new or improved infrastructure tosupport it. The council continues to work withthe County Council, utility and otherinfrastructure/service providers to make surethe infrastructure implications of the allocatedsites are fully assessed and where necessarymitigation measures are identified and put inplace to address development impacts.Funding contributions from developers willbe sought where needed to increase capacityto provide local infrastructure.


The representations made regarding this site sought the following modifications to the Plan:Reduce the size of the site

Stipulate a housing mix that responds to needs of the village

Implement suitable safety improvements at the dangerous cross roads

Table 12.46 Key Issues: BM4 Land at Knaresborough Road, Bishop Monkton



Burton Leonard Site

BL9: Alfred Hymas site, Burton Leonard


12.7 Respondents include Burton Leonard Parish Council, whose response was accompaniedby a petition signed by 143 residents.



N/ANoted.Support (respondents include Burton Leonard Parish Council and YorkshireWildlife Trust)


N/ASince the PublicationLocal Plan waspublished for

Loss of employment landPotential implications of the loss of employment land not explored

consultation, the CouncilNo reference to any marketing of the site to demonstrate that continuedemployment use would not be viable, contrary to saved Local Plan policyE2 and emerging Local Plan policy EC1

have resolved to grantplanning permission forthe development of thissite subject to thecompletion of a Section106 Agreement.

The council's economic development team have objected to a currentapplication for housing on the site (17/00525/fulmaj) as the site could meetthe needs of other local businesses

Evidence Base/OtherInconsistencies in the application of the council's methodology for identifyinghousing allocations

No commentary to explain why the site is identified as suitable for allocationwhen it was previously recommended not to allocate

No explanation why the site is considered preferable to alternative sites inthe village

Site Requirements

N/ASince the PublicationLocal Plan waspublished for

Requirement 2 - as worded only requires prospective developers to 'investigatethe retention' of buildings that contribute to character of conservation area and'consider' use of locally distinctive materials. If measures necessary to ensuredevelopment takes place in manner consistent with appropriate conservation ofconservation area, should be requirement of any development. (Historic England)

consultation, the Councilhave resolved to grantplanning permission forthe development of thisAmend first bullet point to read - 'Retain the buildings...'

Amend second bullet point to read - 'The use of locally distinctive materials'site subject to thecompletion of a Section106 Agreement.

Requirement 3 - as worded implies that it is acceptable, in principle, to harm thislisted building. (Historic England)

Amend as follows: '.. development of the site should conserve those elementswhich contribute to the significance of this designated heritage asset, and shouldseek opportunities ...'





Requirement 7 - the Conservation and Design Site Assessment recommendednone of the traditional buildings along Copgrove Road should be demolished. Ifmeasure is necessary to ensure development takes place in manner consistentwith appropriate conservation of Conservation Area, should be requirement ofdevelopment. (Historic England)

Amend to read: 'Provide vehicle, cycle and pedestrian access in a manner whichretains the traditional buildings along Copgrove Road; extend ...'

Table 12.47 Key Issues

Dacre Banks Site

DB5: Land to the west of Dacre Banks (smaller site)



No amendmentAn assessment was made of the land tothe north as part of a wider site andsignificant landscape impacts andtopography concerns were identified sothe site boundary was reduced..

Support

Site should be extended to include land to the north asprovides additional access to Cabin Lane.



The site is too big (respondents include Natural England)

Negative impact on the landscape (respondents includeNatural England) the Local Plan and the Housing

Background Paper) and, through the LocalThe site is in the Nidderdale Area of Outstanding NaturalBeauty (respondents include Natural England)

Plan, there is a need to allocate land toensure this requirement is met. Thecouncil considers that this site canNegative impact on local roads and traffic contribute to meeting this need and theapproach taken to the identification of thissite is based on reasonable evidence.

Impact on Listed BuildingsGrade II listed Summerbridge Bridge

As set out in the evidence base, manysites have been considered through thesite selection process. Sites have been

Affordable housingUnlikely to deliver affordable housing due to theexpense of building houses which fit the characterof the AONB

allocated that are considered to offer thegreatest sustainability benefits andconsiderations such as the scale ofdevelopment, access, and impacts on

Other: highways landscape, ecology, heritageassets and flooding were taken intoaccount during the site assessmentprocess.

Site will significantly change the form of thevillage (Natural England)

Cumulative impacts of sites in the village has notbeen considered and is likely to significantly harmthe village and wider AONB

Potential adverse impacts of developmentof the site were considered through thesite assessment process. Where potentialadverse impacts were identified, it is

Narrow and dangerous access to the site. considered that these are notinsurmountable and could potentially bemitigated, as set out in the SiteRequirements. Further assessment ofthese issues will be undertaken as part ofthe planning application process if requiredat this stage.





It is recognised that new development,both individual sites and from thecumulative impact of several sites, willplace extra pressure on existinginfrastructure and may need new orimproved infrastructure to support it. Thecouncil continues to work with the CountyCouncil, utility and otherinfrastructure/service providers to makesure the infrastructure implications of theallocated sites are fully assessed andwhere necessary mitigation measures areidentified and put in place to addressdevelopment impacts. Fundingcontributions from developers will besought where needed to increase capacityto provide local infrastructure.



Update evidence base for the transport and economic policies affecting this site (and other rural areas)

Provide only genuinely affordable housing in the village

Site Requirements

No amendment.It is considered that the requirement asdrafted adequately identifies where accessto the public rights of way network fromthe site can be made.

Requirement 10 - importance of this access not indicatedclearly enough. Within a very short distance are two majorwalking routes (The Nidderdale Way and The Six DalesTrail). Access to these two routes (and to others aroundthe village) could be further improved by requiring accessto the Rights of Way network at both the northern andsouthern edges of the proposed site (NY LAF)

No amendment.The site specific requirements seek toreduce to an acceptable level the impactof development.

Add site requirement for housing to be concentrated tothe east and south of the site and only green infrastructureand mitigation features to be incorporated to the westernportion of the site. (Natural England)

Table 12.48 Key Issues: Land to the west of Dacre Banks

Darley Sites

DR1: Land at Stumps Lane





Amend SiteRequirement 6 toadd: Landscapeand Visual ImpactAssessment.

There is an identified residualhousing requirement to bedelivered during the plan period(as set out in Chapter 10 of theLocal Plan and the HousingBackground Paper) and,through the Local Plan, there

Tests of soundness:Not positively prepared.

Conflicts with the approach to AONB in NPPF

The site is too big





A large amount of development has already been granted in thelocal area

is a need to allocate land toensure this requirement is met.The council considers that this

No local need for additional housing site can contribute to meetingthis need and the approach

Local infrastructure cannot cope taken to the identification of thissite is based on reasonableevidence.

School is full, no local doctors surgery

Negative impact on local roads/ traffic As set out in the evidencebase, many sites have beenconsidered through the siteNo or poor access to public transport

No or poor access to shops and services selection process. Sites havebeen allocated that areNot sufficient space for a footpath on western verge of Stumps

Lane. considered to offer the greatestsustainability benefits andconsiderations such as the

Risk of flooding scale of development, access,and impacts on highways

Poor drainage landscape, ecology, heritageassets and flooding were takeninto account during the siteassessment process.


The site is in the Nidderdale AONBPotential adverse impacts ofdevelopment of the site wereconsidered through the site

Negative impact on the local communityHomes to the north of the site would be overlooked by newdevelopment. assessment process. Where

potential adverse impacts wereidentified, it is considered that

Negative impact on local wildlife and biodiversity these are not insurmountableand could potentially beOther mitigated, as set out in the Site

Dry stone wall to north is in parlous state. Requirements. As this site iswithin the Nidderdale AONB

Conflicts with Village Design Statement (2002): protectinglinear nature of village, protecting 'through views'.

the site requirement sectionhas been amended to add therequirement for a Landscape

No access to employment. and visual impact assessmentwhen a planning application issubmitted. Further assessmentNegative impact on tourism within the AONBof these issues will beundertaken as part of theplanning application process ifrequired at this stage.

It is recognised that newdevelopment, both individualsites and from the cumulativeimpact of several sites, willplace extra pressure onexisting infrastructure and mayneed new or improvedinfrastructure to support it. Thecouncil continues to work withthe County Council, utility andother infrastructure/serviceproviders to make sure theinfrastructure implications ofthe allocated sites are fullyassessed andwhere necessarymitigation measures areidentified and put in place toaddress development impacts.Funding contributions from





developers will be soughtwhere needed to increasecapacity to provide localinfrastructure.


The representations made regarding this site sought the following modifications to the Plan:Remove site from the plan

Allocate a different site/allocate new settlement

Prioritise brownfield sites

Table 12.49 Key Issues: DR1 Land at Stumps Lane

DR14: Land at Sheepcote Lane (combined site), Darley



Reasons do not support site allocation

Noamendment.


Test of soundness:Allocating this site is not the most appropriate strategy when consideringalternatives.

delivered during the planperiod (as set out inNot justified due to over provision of housing.Chapter 10 of the LocalPlan and the HousingNot deliverable due to objections from Local Highways Authority.Background Paper) and,through the Local Plan,Inconsistent with approach to AONB in NPPF. there is a need to allocateland to ensure thisrequirement is met. TheIssue with consultation council considers that this

The site is too big - not in proportion with rest of the village (Natural England) site can contribute tomeeting this need and theapproach taken to theReduce the size of this allocation and allow housing only along the line of the

existing settlement to the north and east with southern, western and centralsections of the site utilised only for green infrastructure, mitigation andcompensation.

identification of this site isbased on reasonableevidence.

As set out in the evidencebase, many sites havebeen considered through

A large amount of development has already been granted in the local area

The site is outside the current development limit the site selection process.Sites have been allocated

No local need for additional housing that are considered tooffer the greatest

Affordable housing sustainability benefits andconsiderations such asLocal infrastructure cannot cope the scale of development,

Negative impact on local roads/traffic access, and impacts onhighways landscape,Objections from Local Highway Authority to planning application on part

of this site. ecology, heritage assetsand flooding were takeninto account during thesite assessment process.Questions over the accuracy of survey work undertaken.

Concerns regarding site access.





Potential adverse impactsof development of the sitewere considered through


Risk of floodingthe site assessment

Poor drainage process. Where potentialadverse impacts wereNegative impact on the landscape identified, it is considered

Development would be visible from other side of valley and from PRoWnetwork (Natural England).

that these are notinsurmountable and couldpotentially be mitigated,as set out in the SiteThe site is a greenfield site Requirements. Further

Loss of open space assessment of theseissues will be undertaken

Site is in the Nidderdale AONB as part of the planningapplication process ifrequired at this stage.

Contrary to AONB Management Plan

Significant adverse impacts on AONB (Natural England)It is recognised that newdevelopment, bothindividual sites and fromNegative impact on the local communitythe cumulative impact ofAmenity of adjacent farm steads compromised. several sites, will placeextra pressure on existing

Loss of tranquility along Sheepcote Lane. infrastructure and mayneed new or improvedinfrastructure to supportNegative impact on local wildlife and biodiversity it. The council continues

Negative impact on designated heritage assets to work with the CountyCouncil, utility and other

Other infrastructure/serviceproviders to make sureWill change linear form of village to nucleated form (Natural England)the infrastructureimplications of theContrary to Village Design Statement: loss of views.allocated sites are fullyassessed and where

Negative impact on heritage trail (walking route along Sheepcote Lane,Walker Lane and Main Street).

necessary mitigationmeasures are identifiedand put in place to

Lack of employment in the area. address developmentimpacts. Funding

Disagree with sustainability appraisal assessment that the site is withinwalking distance of secondary school - secondary school is in Pateleybridge.

contributions fromdevelopers will be soughtwhere needed to increasecapacity to provide localinfrastructure.Proposed site conflicts with village design statement

Number of houses is not in line with the plans growth strategy/the villagesposition within the hierarchy.


The representations made regarding this site sought the following modifications to the Plan:Remove site from planAllocate a different site/allocate new settlementPrioritise brownfield sites

Site Requirements





Noamendment.

The site requirements arebased on comments fromthe Highway Authority and

Requirements 8 and 9 - to be more effective requirementss 8 and 9 should beamended to refer to vehicular, pedestrian and cycle access also beingtaken from Meadow Lane.

as such they areconsidered to beappropriately worded.

Amend Requirement 8 to read: "Provide vehicle, cycle and pedestrian accessfrom Sheepcote Lane and Meadow Lane; localised highway widening may berequired"

Amend Requirement 9 by deletion of words: "this should include fullyinvestigating the provision of pedestrian and cycle access to Meadow Lane"

Table 12.50 Key Issues: DR14 Land at Sheepcote Lane, Darley

Dishforth Site

DF4: Land north east of Thornfield Avenue, Dishforth



N/ANoted.Support - part of site has reserved matters approvaland pending full application on remainder

Site Requirements

No amendment.As a link to the bridleway would involve landoutwith the allocated site it is considered thatit would be inappropriate for the siterequirement to go further than it does.

Requirement 5 – bridleway gives safe crossing ofthe A168 and access to this bridleway from the siteshould be a requirement not an “investigation” (NYLAF).

Table 12.51 Key Issues: DF4 Land north east of Thornfield Avenue, Dishforth

Goldsborough Sites

GB2: Land at Low Farm, Goldsborough


Move site from allocations tocommitments, delete the siterequirements and add the following to

The site now has the benefit of full planningpermission for 5 dwellings and will be shownas a commitment. The site requirements will

Add a new criterion to read 'Anynew buildings should be very lowin number and be of ahigh-quality, locally distinctivedesign'

the site box 'site to be developed inaccordance with planning permission17/0443/FUL'

be replaced with the text 'site to be developedin accordance with planning permission17/0443/FUL'

Table 12.52

GB4: Land adjacent to cricket ground, Goldsborough



N/ANoted.Support


Noamendment.

There is an identified residualhousing requirement to bedelivered during the plan period

Tests of soundness

Land ownership issues





(as set out in Chapter 10 of theLocal Plan and the HousingBackground Paper) and, through

Access to the site may require third party land

The site is outside the current development limit the Local Plan, there is a need toallocate land to ensure this

No local need for additional housing requirement is met. The councilNo evidence of a significant housing requirement inGoldsborough

considers that this site cancontribute to meeting this needand the approach taken to theidentification of this site is basedon reasonable evidence.

The sites in the plan will lead to an over-supply of housing in thewider Knaresborough area

As set out in the evidence base,many sites have been consideredthrough the site selection

Local infrastructure cannot copeExisting sewage system is at capacity

process. Sites have beenallocated that are considered to

Negative impact on local roads/traffic offer the greatest sustainabilitybenefits and considerations such

Local schools are full as the scale of development,There is no land for expansion access, and impacts on highways

landscape, ecology, heritageassets and flooding were takeninto account during the siteassessment process.

Risk of flooding

Poor drainagePotential adverse impacts ofdevelopment of the site wereconsidered through the site


Loss of agricultural landassessment process. Where

The site is in the Green Belt potential adverse impacts wereidentified, it is considered that

Negative impact on local wildlife and biodiversity these are not insurmountable andcould potentially be mitigated, as

Negative impact on the conservation area set out in the Site Requirements.Further assessment of these

Negative impact on a listed building issues will be undertaken as partof the planning applicationprocess if required at this stage.Other

Contrary to existing local planning policies (Goldsborough is agroup C village) It is recognised that new

development, both individual sitesand from the cumulative impactNegative impact on local distinctiveness (including: by virtue of

being contrary to the established grain of the settlement,incongruous modern development)

of several sites, will place extrapressure on existing infrastructureand may need new or improvedinfrastructure to support it. TheMay set a precedent for further development of the fields beyond

the site council continues to work with theCounty Council, utility and otherinfrastructure/service providersDevelopment could give rise to the public being prevented from

accessing part of the site (proposed as part of the currentplanning application)

to make sure the infrastructureimplications of the allocated sitesare fully assessed and wherenecessary mitigation measuresWill destroy the character of the cricket groundare identified and put in place toaddress development impacts.New properties could be damaged by ball strikes from the cricket

ground Funding contributions fromdevelopers will be sought whereneeded to increase capacity toprovide local infrastructure.

Potential for dispute between cricket club and new residentsover noise from the cricket ground

It should be noted that this site isnot in the Green Belt.Unsafe vehicle and pedestrian access to the site







Site Requirements

Noamendment.

The wording of this requirementis consistent with that used forsimilar requirements in respect of

Requirement 8 – on other sites requirements regarding footpaths usephrase ‘enhance and protect’, which is equally applicable in this case(NY LAF)

other allocated housing sites.Requirement 9, which refers toAmend requirement 8 to use the phrase ‘enhance and protect’ in

relation to footpaths. the public footpath that crossesthe site uses the phrase 'protectand enhance'.

N/ANoted.The proposed site requirements reflect the recommendations set outin the Conservation and Design Site Assessment (Historic England)

Table 12.53 Key Issues: GB4 Land adjacent to cricket ground, Goldsborough

Green Hammerton

GH2: Land at New Lane, Green Hammerton




No amendmentThere is an identified residualhousing requirement to bedelivered during the plan period

The site is too big

A large amount of development has already been granted in thelocal area (as set out in Chapter 10 of the

Local Plan and the HousingNo local need for additional housing Background Paper) and, through

the Local Plan, there is a needPrevious applications to develop the site have been refused to allocate land to ensure thisLocal infrastructure cannot cope requirement is met. The council

considers that this site canNegative impact on local roads/ traffic contribute to meeting this need

and the approach taken to theidentification of this site is basedon reasonable evidence.

Poor access to public transport

Local schools are fullAs set out in the evidence base,many sites have beenconsidered through the site

GP surgery is full

Risk of floodingselection process. Sites have

Loss of agricultural land been allocated that areconsidered to offer the greatest

Negative impact on community sustainability benefits andconsiderations such as the scale

Negative impact on wildlife of development, access, andimpacts on highways landscape,

Negative impact on Green Hammerton conservation area ecology, heritage assets andflooding were taken into accountduring the site assessmentprocess.


OtherNegative impact on historic village






Cumulative impact with GH9, KH11 and new settlement hasnot been considered

assessment process. WhereNo local employmentpotential adverse impacts wereidentified, it is considered thatNo mains gasthese are not insurmountableand could potentially beLoss of hedgerowsmitigated, as set out in the SiteRequirements. Furtherassessment of these issues willbe undertaken as part of theplanning application process ifrequired at this stage.

It is recognised that newdevelopment, both individualsites and from the cumulativeimpact of several sites, will placeextra pressure on existinginfrastructure andmay need newor improved infrastructure tosupport it. The council continuesto work with the County Council,utility and otherinfrastructure/service providersto make sure the infrastructureimplications of the allocated sitesare fully assessed and wherenecessary mitigation measuresare identified and put in place toaddress development impacts.Funding contributions fromdevelopers will be sought whereneeded to increase capacity toprovide local infrastructure.



Table 12.54 Key Issues: GH2 Land at New Lane, Green Hammerton

GH9: Land west of B6265 and north of A59, Green Hammerton



N/ANoted.Support allocation - deliverable within first 5 years of planperiod.



A large amount of development has already been grantedpermission in the local area

The site is outside the current development limit (as set out in Chapter 10 of theLocal Plan and the Housing

No local need for additional housing Background Paper) and, throughthe Local Plan, there is a needLocal infrastructure cannot cope to allocate land to ensure this





Negative impact on local roads/ traffic requirement is met. The councilconsiders that this site cancontribute to meeting this needPoor access to public transportand the approach taken to theidentification of this site is basedon reasonable evidence.



Negative impact on local community As set out in the evidence base,many sites have beenconsidered through the siteNegative impact on conservation areaselection process. Sites have

Issue with consultation been allocated that areconsidered to offer the greatest

Other sustainability benefits andSite is separated from village by busy road/ poorly relatedto village form.

considerations such as the scaleof development, access, andimpacts on highways landscape,

No local jobs. ecology, heritage assets andflooding were taken into accountduring the site assessmentprocess.

Will impact on setting of historical villages

Cumulative impact of all development within the local areashould be considered. Potential adverse impacts of

development of the site wereconsidered through the siteNo mains gasassessment process. Wherepotential adverse impacts wereWould form ribbon development and therefore contrary to

Draft Policy GS3F. identified, it is considered thatthese are not insurmountableand could potentially be

The significance of locally available rail transport isoverstated. There is little parking available at either Cattalor Hammerton; trains are infrequent; fares are tooexpensive to provide a viable commuter route for themajority of people.

mitigated, as set out in the SiteRequirements. Furtherassessment of these issues willbe undertaken as part of theplanning application process ifrequired at this stage.

It is recognised that newdevelopment, both individualsites and from the cumulativeimpact of several sites, will placeextra pressure on existinginfrastructure andmay need newor improved infrastructure tosupport it. The council continuesto work with the County Council,utility and otherinfrastructure/service providersto make sure the infrastructureimplications of the allocatedsites are fully assessed andwhere necessary mitigationmeasures are identified and putin place to address developmentimpacts. Funding contributionsfrom developers will be soughtwhere needed to increasecapacity to provide localinfrastructure.







Prioritise brownfield sitesFocus development where the infrastructure is already in placeUndertake a green belt review to consider housing allocations closer to existing centres of population

Table 12.55 Key Issues: GH9 Land west of B6265 and north of A59, Green Hammerton

Hampsthwaite Site

HM7: Land off Brookfield Garth, Hampsthwaite

12.8 Respondents include the Hampsthwaite Action Group (HAG) which was formed to representthose people in the village of Hampsthwaite opposed to parts of the Local Plan andunsustainable housing growth. The representation submitted by HAG is supported by 392people from the Hampsthwaite local community and the submission includes additionaldocumentation relating to the SEA Directive Alternatives/Cumulative Impacts, EconomicSustainability, Housing Growth, HEDNA, Drainage, Primary School, Heritage and Landscapeand Infrastructure Delivery Plan. The table below provides a summary of the Key Issues thatrelate to HM7.

12.9 During the Publication Local Plan consultation however, the Council have granted outlineplanning permission for the erection of up to 39 dwellings on this site. The decision noticewas issued on the 20th February 2018..


HBCResponse

Key Issue


Noamendment.

During thePublicationLocal Plan

Tests of SoundnessThe SEA Directive reasonable alternatives requirements were not applied properlyleading to the inclusion of Hampsthwaite in the Harrogate to Pateley Bridge publictransport corridor as a settlement for housing growth. consultation,

the Councilhave grantedThe SEA Directive cumulative impact requirements were not applied properly and

as a result evidence demonstrating the cumulative impacts of multiple housing sitesin Hampsthwaite was not considered in the evidence base.

outlineplanningpermission forthe erection ofHM7 assessed against other Publication Draft Local Plan policy shows a number

of inconsistences in approach and an assessment using the draft policy demonstratesHM7 would not be able to deliver sustainable development.

up to 39dwellings onthis site. Thedecision noticeThe council failed to take into account key evidence and is unable to justify HM7 as

a deliverable or sustainable choice when Hampsthwaite’s infrastructure andenvironmental capacity is considered.

was issued onthe 20thFebruary2018..

Hampsthwaite Action Group has assessed the HM7 site allocation against a rangeof Publication Draft Local Plan policies and that assessment demonstrates housingdevelopment at HM7 is in conflict with the aims of key policies and is not sustainabledevelopment. For this reason, the Publication Draft Local Plan is not sound.

Hampsthwaite Action Group has looked at the evidence raised by consultees andadded further evidence to demonstrate the council has failed to consider infrastructurecapacity evidence and HM7 cannot deliver sustainable development. For this reason,the Publication Draft Local Plan is not sound.

Negative impact on local roads and traffic





HBCResponse

Key Issue

Local school is full

Negative impact on landscape character

Local Infrastructure cannot copeIn the council's original sustainability appraisal of the growth strategy options, locatinghousing growth in rural village locations was given a low score because of the lackof infrastructure and the potential difficulties of building new housing at a scale whichcould address infrastructure requirements. Nothing has changed in the interveningthree years to justify ignoring those original findings, so any evidence demonstratinginfrastructure capacity has been, or is nearly, reached in Hampsthwaite should betaken very seriously.

Sewerage overflow is a nuisance and health hazard. It has been a regular event inproperties at the lower end of the village and sewerage build up in the pipes hasresulted in outflows in the ‘Feast Field’ where children play. There have also beenserious flooding issues during construction of HM1.

With regard to foul sewage outfall the existing system is overloaded in times ofheavy rainfall, the existing storm water overflows are outdated and do not deal withstorm water conditions in a satisfactory way. In heavy rainfall they cause pollutionto the local watercourses and ultimately the River Nidd. The existing foul pumpingstation in St Thomas A Beckett Walk is not fit for purpose and no further housingshould be added to it until it has been fully upgraded.

FloodingThere is a very high risk that if further housing is built in Hampsthwaite flooding riskswill increase at the lower end of the village. It should be noted that part of siteallocation HM7 lies within Flood Zone 2 and this area flooded as recently as 2000.Housing development at HM7 would require an expensive new surface water sewerto the River Nidd.

OtherCumulatively with other sites in Hampsthwaite, the development of HM7 will notimprove the economic, social and environmental conditions in the area.

There has been no cumulative impact study and therefore no understanding ofcumulative infrastructure requirements or if delivery is possible.


The representations made regarding this site sought the following modifications to the Plan:Remove site from the plan.

Ensure SEA Directive requirements have been met and re-consult as appropriate.

Table 12.56 Key Issues: HM7 Land off Brookfield Garth, Hampsthwaite

HM9: Land to the north of Meadow Close, Hampsthwaite

12.10 Respondents include the Hampsthwaite Action Group (HAG) which was formed to representthose people in the village of Hampsthwaite opposed to parts of the Local Plan andunsustainable housing growth. The representation submitted by HAG is supported by 392people from the Hampsthwaite local community and the submission includes additionaldocumentation relating to the SEA Directive Alternatives/Cumulative Impacts, EconomicSustainability, Housing Growth, HEDNA, Drainage, Primary School, Heritage and Landscapeand Infrastructure Delivery Plan. The table below provides a summary of the Key Issues thatrelate to HM9.





N/ANotedSupport


Noamendment


Legal complianceLocal Plan engagement not undertaken in accordance with SCI

delivered during theSustainability Appraisal failed to consider cumulative impact of developmentor fully assess impact on heritage assets plan period (as set

out in Chapter 10 ofthe Local Plan andHampsthwaite Action Group are concerned the council did not properly

consider housing growth reasonable alternatives following receipt of theHEDNA report (in accordance with the SEA Directive) and the local

the HousingBackground Paper)and, through thecommunity in Hampsthwaite did not get an opportunity to comment on those

reasonable alternatives. For these reasons, the Publication Draft Local Planis neither legally compliant or sound.

Local Plan, there is aneed to allocate landto ensure thisrequirement is met.Paragraph 1.10 of the Non-Technical Summary goes on to state: “The

cumulative impacts of draft allocations have been identified on a settlementbasis for Harrogate, Knaresborough, Ripon and Boroughbridge andcumulatively for the local plan as a whole.”

The council considersthat this site cancontribute to meetingthis need and theapproach taken to theAlthough the council states that its sustainability appraisal incorporates the

SEA Directive it does not address certain cumulative effects as required bythe SEA Directive, particularly the cumulative effects of multiple housing site

identification of thissite is based onreasonable evidence.allocations on communities such as Hampsthwaite. Significantly, the

cumulative impacts described by the council were not undertaken on a As set out in theevidence base, manysites have been

settlement basis – the sustainability appraisals were undertaken on a siteby site – individual - basis and then listed in the document by settlement.The council’s statement in paragraph 1.10 is misleading and wrong. HAG is considered throughconcerned that the SEA Directive has not been fully complied with becausecumulative impacts of multiple site allocations at the Primary Service Village(PSV) level are not considered.

the site selectionprocess. Sites havebeen allocated thatare considered tooffer the greatestTests of soundness sustainability benefits

The SEA Directive reasonable alternatives requirements were not appliedproperly leading to the inclusion of Hampsthwaite in the Harrogate to PateleyBridge rural public transport corridor as a settlement for housing growth.

and considerationssuch as the scale ofdevelopment, access,and impacts on

The SEADirective cumulative impact requirements were not applied properlyand as a result evidence demonstrating the cumulative impacts of multiplehousing sites in Hampsthwaite was not considered in the evidence base.

highways landscape,ecology, heritageassets and floodingwere taken into

The approach to selecting the growth options set out in the Local Plandocument differs from the information provided in the sustainability appraisaldocument – suggesting that the Local Plan preferred option for its growthstrategy was not informed by the sustainability appraisal (incorporating theSEA Directive requirements on alternatives).

account during thesite assessmentprocess.

Potential adverseimpacts ofdevelopment of theThere was a flawed consultation process on the housing need objectives,

alternatives and the need for additional sites which, if done properly wouldhave informed the council why HM9 is not required

site were consideredthrough the siteassessment process.Where potentialHM9 assessed against other Publication Draft Local Plan policy shows a

number of inconsistences in approach and an assessment using the draftpolicy demonstrates HM9 would not be able to deliver sustainabledevelopment.

adverse impacts wereidentified, it isconsidered that theseare notinsurmountable andThe council failed to take into account key evidence and is unable to justify

HM9 as a deliverable or sustainable choice when Hampsthwaite’sinfrastructure and environmental capacity is considered.

could potentially bemitigated, as set outin the SiteRequirements.





Further assessmentof these issues will beundertaken as part of

The consultation process on the evidence base for housing numbers did notprovide for consultees to formally review housing numbers at the HEDNApublication stage. There was no formal opportunity given by the council for

the planningapplication process ifrequired at this stage.

consultees to make proper comment on alternatives for dealing with thehousing numbers set out in the HEDNA report. As such, the basis for theadditional sites consultation was presented as a fait accompli and was flawed.

It is recognised thatnew development,both individual sites

The reasonable alternatives of what housing numbers would be required tomeet different economic objectives were not considered at a robust politicallevel in July 2017.

and from thecumulative impact ofThere is no evidence to support the Hampsthwaite allocations HM7 and HM9

(together with the other recent housing developments) could be supportedby existing infrastructure capacity. Neither is there an Infrastructure DeliveryPlan which sets out how infrastructure can be improved to deliver sustainabledevelopment in the village.

several sites, willplace extra pressureon existinginfrastructure andmay need new orimproved

Issues with the evidence base infrastructure tosupport it. The

No local need for additional housing council continues towork with the County

Local infrastructure cannot cope Council, utility andother

Local schools are full infrastructure/serviceproviders to makeGP's/dentists are full sure the infrastructure

Poor drainage implications of theallocated sites areProblems associated with drainage and sewerage overflows in the village

of Hampsthwaite had existed before HM1 was built. The Parish Council andcommunity raised this problem with the council and Yorkshire Water many

fully assessed andwhere necessarymitigation measurestimes. Each new house which is built adds to the problem and over time theare identified and putinfrastructure itself requires constant repairs. Sewerage overflow is a nuisancein place to addressand health hazard. It has been a regular event in properties at the lower enddevelopment impacts.of the village and sewerage build up in the pipes has resulted in outflows in

the ‘Feast Field’ where children play. There have also been serious floodingissues during construction of HM1.

Funding contributionsfrom developers willbe sought whereneeded to increasecapacity to providelocal infrastructure.

Negative impact on the landscapeAONB JAC highlighted previously potentially adverse impact of developmenton land close to AONB. Site assessment has not truly assessed site inrelation to AONB impacts, glossing over potential for mitigation The SA has been

updated and includesa strengthenedassessment ofcumulative impacts.

Negative impact on the conservation areaHistoric England's grounds of objection have not been afforded sufficientweight The Harrogate

District Local PlanSubmission DraftAdditional traffic through historic core of village (to access A59) will add

further harm to character and value as heritage asset August 2018 ,SustainabilityAppraisal Vol.1/Vol.2

Negative impact on designated heritage assets

Development of site would be inconsistent with conservation of heritage assets asrequired by national policy guidance. Do not consider that this harm is capable ofeffective mitigation by measures suggested in Conservation and Design SiteAssessment. (Historic England)

updated followingPublication DraftConsultation will beincluded in theExamination Library

The InfrastructureCapacity Study (ICS)reports have been

Large amount of development has already been granted in local area

Risk of Flooding available alongsidethe Local Plan at





each stage ofconsultation. AtPublication Local

Flooding problems in Hampsthwaite will be dramatically increased by the cumulativeimpact of new housing developments at committed sites, sites with planningapplications and site allocations at HM7 and HM9.

Plan stage the latestICS and Draft

The site is in the Nidderdale Area of Outstanding Natural Beauty Infrastructureurbanising effect on a village located just 200 metres from the boundary ofthe Nidderdale AONB and the cumulative impact on the setting of the locallandscape designation

Delivery Plan werepublished assupportingdocuments.

OtherEncourage more dispersed and unsustainable pattern of development

Identification of Hampsthwaite as Primary Service Village and subsequentscale of growth cannot be justified

Housing growth of the scale proposed will cumulatively have an adverseeffect on the local village economy. New housing will primarily attract newcommuters who will work outside of Hampsthwaite. The nearest employmentland supply is Harrogate East or Knaresborough which will involve a largenumber of car journeys to work. A number of businesses identify the scaleof housing development as a negative to growth which could undermine theirdevelopment plans. They cite traffic congestion, building competition, andimpact on landscape as being major obstacles to their plans.


The representations made regarding this site sought the following modifications to the Plan:Delete allocation (respondents include Historic England) and amend development boundary to exclude site

Deal with the failure to comply with the SEA Directive by undertaking cumulative assessments of the housing siteallocations affecting individual communities.

Site Requirements

Amend SiteRequirement 8to read:

Agree that areference should bemade as suggested.

Requirement 8 – The Nidderdale Way runs along Elton Lane and the importanceof this route should be acknowledged (NYLAF).

'Extend theexistingpedestrianfootway alongElton Lane,which is partof theNidderdaleWay.'

Table 12.57 Key Issues: HM9 Land to the north of Meadow Close, Hampsthwaite

Killinghall

KL2: Land adjoining Grainbeck Manor, Killinghall



Site Requirements




Amend Site Requirement 4 to read:'Retain the protected trees along thenorthern site boundary and in thenorth-east of the site .....'

Agree that as the TPO was notconfirmed the amendment suggestedby the respondent should be made.

Requirement 4 - no protected trees alongnorthern site boundary. Although an initialTPO was made this was not confirmed.

Delete reference to protected trees onnorthern side boundary

Amend Site Requirement 5 to read:'Provide vehicle, cycle andpedestrian access from Grainbeck

The layout for the committed schemeto the north of Site KL2 may providean alternative option for accessing the

Requirement 5 - option of accessing landfrom KL1 should also be considered as anadditional viable option.

Lane or adjacent residentialdevelopment to the north; apedestrian footway ..... '

site and the suitability or otherwise ofthis could be determined at planningapplication stage.

Amend text to state: "... access fromGrainbeck Lane or adjacent residentialdevelopment to the north;..."

Table 12.58 Key Issues: KL2 Land adjoining Grainbeck Manor, Killinghall

KL6: Land at Manor Farm, Killinghall

12.11 Since the Publication Local Plan was published for consultation, the Council have grantedoutline planning permission for the erection of up to 50 dwellings and school car park on thissite. The decision notice was issued on the 28 June 2018.




Site Requirements

N/ASince the Publication Local Plan was publishedfor consultation, the Council have granted outlineplanning permission for the erection of up to 50dwellings and school car park on this site. Thedecision notice was issued on the 28 June 2018.

Requirement 7 - should state that the footway beextended to ensure safe access to the two footpathsoff Crag Lane – thus providing safe access to the widerRights of Way network (NY LAF).

Amend to state that the footway be extended to ensuresafe access to the two footpaths off Crag Lane.

Table 12.59 Key Issues: KL6 Land a Manor Farm, Killinghall

Kirk Hammerton

KH11: Land at Station Road, Kirk Hammerton





A large amount of development has already been grantedin the local area

The site is outside the current development limit. the Local Plan and the HousingBackground Paper) and, through the

Negative impact on locals roads/ traffic Local Plan, there is a need to allocateland to ensure this requirement is met.Poor access to public transport The council considers that this site can

Poor access to shops and services contribute to meeting this need and the






Risk of flooding


Other: As set out in the evidence base, manysites have been considered through thesite selection process. Sites have been

Site will not achieve potential yield as developablearea of site will be reduced by stand off distancebetween built form and railway line and retention oftree belt along southern boundary.

allocated that are considered to offer thegreatest sustainability benefits andconsiderations such as the scale ofdevelopment, access, and impacts onCost of mitigating noise will make the site non-viable

with a lower yield. highways landscape, ecology, heritageassets and flooding were taken intoaccount during the site assessmentprocess.

Kirk Hammerton should be reclassified as a smallervillage as it is not a sustainable location for adevelopment of this size.

Potential adverse impacts ofdevelopment of the site were consideredthrough the site assessment process.Where potential adverse impacts wereidentified, it is considered that these arenot insurmountable and could potentiallybe mitigated, as set out in the SiteRequirements. Further assessment ofthese issues will be undertaken as partof the planning application process ifrequired at this stage.

It is recognised that new development,both individual sites and from thecumulative impact of several sites, willplace extra pressure on existinginfrastructure and may need new orimproved infrastructure to support it. Thecouncil continues to work with the CountyCouncil, utility and otherinfrastructure/service providers to makesure the infrastructure implications of theallocated sites are fully assessed andwhere necessary mitigation measuresare identified and put in place to addressdevelopment impacts. Fundingcontributions from developers will besought where needed to increasecapacity to provide local infrastructure.

The Council's approach to theclassification of settlements in thehierarchy is based on the availability ofcommunity facilities, key public servicesand retail, service and leisure businessesin a settlement, as set out in theSettlement Hierarchy Background Paper(2016).

The Council's facilities researchconcluded that Kirk Hammerton has therange of facilities and services to beclassed as a Secondary Service Village.







Remove site from the Plan

Replace with alternative promoted site in Kirk Hammerton

Table 12.60 Key Issues: KH11 Land at Station Road, Kirk Hammerton

Kirkby Malzeard Sites

KM1: Wensleydale Dairy Products Limited, Kirkby Malzeard




No amendment.Comments noted. However,no sites have been promotedin Kirkby Malzeard foremployment.

Site benefits from being brownfield and in part of village where not likelyto create traffic problems but will involve loss of employment land (KirkbyMalzeard, Laverton and Dallowgill Parish Council)


The representations made regarding this site sought the following modifications to the Plan:Allocate employment land in the village to replace the site being lost to housing development

Site Requirements

N/AFollowing discussion HistoricEngland havewithdrawn theseobjections.

Requirement 2 - as worded implies that it is acceptable, in principle,to harm the Scheduled Monument. Given poor condition of ScheduledMonument and fact significance will be harmed by development to someextent, one of means of offsetting harm would be to put in placemechanism for ensuring development of site also brings about moresustainable future for Mowbray Castle. (Historic England)

Amend to read: '.. development of the site should conserve thoseelements which contribute to the significance of this designated heritageasset, and should seek opportunities to enhance the significance of thisdesignated heritage asset. Development proposals will be required toimprove the immediate setting of Mowbray Castle and contribute towardssecuring a more sustainable future for the monument.'

Requirement 3 - as worded implies that it is acceptable, in principle,to harm this non-designated heritage asset. (Historic England)

Amend to read: '.. development of the site should conserve thoseelements which contribute to the significance of this non-designatedheritage asset, and should seek opportunities to enhance....'

Requirement 4 - as worded implies that it is acceptable, in principle,to harm this listed building. (Historic England)

Amend to read: '.. development of the site should conserve thoseelements which contribute to the significance of these designated heritageassets, including their setting.'

Requirement 5 - as worded implies that it is acceptable, in principle,to harm these designated heritage assets. (Historic England)





Amend to read: '.. development of the site should conserve thoseelements which contribute to the significance of these heritage assets,and should seek opportunities to enhance....

No amendment.NYCCs public rights of wayonline maps shows a publicfootpath crossing the sitefrontage.

Requirement 11 – footpath is not recorded on the definitive map andstatus of this path needs to be determined (NY LAF).

No amendmentIt is for the applicant tochoose a competentconsultant and for the

Requirement 12 - Amend 4th bullet to read: "Heritage statementincluding an archaeological evaluation of the site by a consultant whoalso understands eighteenth century designed developments (HistoricEngland) planning authority to satisfy

itself that the assessment isappropriate.

Table 12.61 Key Issues: KM1 Wensleydale Dairy Products Limited, Kirkby Malzeard

KM4: Land south of Richmond Garth, Kirkby Malzeard



N/ASupport noted.Support allocation but consider site should beshown as coming forward in years 0-5 of the Plan.

The Local Plan housing trajectory showsexpected delivery from 2021/22: this isconsidered reasonable given that the currentoutline planning application for this site (and KM5)is still the subject of negotiation and has yet tobe determined.


No amendment.There is an identified residual housingrequirement to be delivered during the plan period(as set out in Chapter 10 of the Local Plan and


No or poor access to shops and servicesthe Housing Background Paper) and, through the

Risk of flooding Local Plan, there is a need to allocate land toensure this requirement is met. The councilPoor drainage considers that this site can contribute to meeting

Loss of agricultural land this need and the approach taken to theidentification of this site is based on reasonableevidence.The site is a greenfield site

The site is in the Nidderdale Area of OutstandingNatural Beauty (AONB)

As set out in the evidence base, many sites havebeen considered through the site selectionprocess. Sites have been allocated that areAn application for development opposite

the site was recently refused due to theimpact on the AONB

considered to offer the greatest sustainabilitybenefits and considerations such as the scale ofdevelopment, access, and impacts on highwayslandscape, ecology, heritage assets and floodingwere taken into account during the siteassessment process.

Other:Development will destroy the linear natureof the village

Potential adverse impacts of development of thesite were considered through the site assessmentprocess. Where potential adverse impacts wereidentified, it is considered that these are notinsurmountable and could potentially bemitigated, as set out in the Site Requirements.





Further assessment of these issues will beundertaken as part of the planning applicationprocess if required at this stage.

It is recognised that new development, bothindividual sites and from the cumulative impactof several sites, will place extra pressure onexisting infrastructure and may need new orimproved infrastructure to support it. The councilcontinues to work with the County Council, utilityand other infrastructure/service providers to makesure the infrastructure implications of theallocated sites are fully assessed and wherenecessary mitigation measures are identified andput in place to address development impacts.Funding contributions from developers will besought where needed to increase capacity toprovide local infrastructure.



Update evidence base including infrastructure capacity study/carry out detailed traffic study and incorporate findings

Table 12.62 Key Issues: KM4 Land south of Richmond Garth, Kirkby Malzeard

KM5: Land east of Richmond Garth, Kirkby Malzeard






No or poor access to shops and servicesthe Local Plan and the Housing

Risk of flooding Background Paper) and, through the LocalPlan, there is a need to allocate land toPoor drainage ensure this requirement is met. The

Loss of agricultural land council considers that this site cancontribute to meeting this need and theapproach taken to the identification of thissite is based on reasonable evidence.


The site is in the Nidderdale Area of OutstandingNatural Beauty (AONB) As set out in the evidence base, many

sites have been considered through thesite selection process. Sites have been

An application for development opposite the sitewas recently refused due to the impact on theAONB allocated that are considered to offer the

greatest sustainability benefits andconsiderations such as the scale of

Other: development, access, and impacts onhighways landscape, ecology, heritageDevelopment will destroy the linear nature of

the village assets and flooding were taken intoaccount during the site assessmentprocess.Increase in air pollution resulting from additional

trafficPotential adverse impacts of developmentof the site were considered through thesite assessment process. Where potential





adverse impacts were identified, it isconsidered that these are notinsurmountable and could potentially bemitigated, as set out in the SiteRequirements. Further assessment ofthese issues will be undertaken as part ofthe planning application process ifrequired at this stage.

It is recognised that new development,both individual sites and from thecumulative impact of several sites, willplace extra pressure on existinginfrastructure and may need new orimproved infrastructure to support it. Thecouncil continues to work with the CountyCouncil, utility and otherinfrastructure/service providers to makesure the infrastructure implications of theallocated sites are fully assessed andwhere necessary mitigation measures areidentified and put in place to addressdevelopment impacts. Fundingcontributions from developers will besought where needed to increase capacityto provide local infrastructure.


The representations made regarding this site sought the following modifications to the Plan:Remove site from PlanUpdate evidence base including infrastructure capacity study/carry out detailed traffic study and incorporate findings

Table 12.63 Key Issues: KM5 Land east of Richmond Garth, Kirkby Malzeard

Markington Site

MK8: Land to the south of High Mill Farm, Markington


N/ASupport noted.Support allocation.Site MK9 (phase 1) has planning permission for 25 dwellingsand enables phase 2 to come forward on MK8 without anyrestrictions.

However, site area should be extended to include area tosouth. Part of this area would be used for public openspace/ecology enhancement.

No amendmentFollowing discussionHistoric England havewithdrawn theirobjection

Impact on Designated Heritage Assets (Historic England)

Before allocating site there is need for evaluation of impact loss ofsite and future development might have upon elements whichcontribute to significance of nearby Scheduled Monuments. If harmwould result, Plan needs to clearly set out measures by which harmmight be removed or reduced. If despite mitigation measures stilllikely to be harm, site should not be allocated unless clear publicbenefits that outweigh harm.




Undertake evaluation of impact loss of site and future developmentmight have upon elements which contribute to significanceof ScheduledMonuments in the vicinity and amend Plan accordingly.

Site Requirements

Amend Site Requirement5 to read: ' ..... in order toprovide convenient access

Agree that thesuggested referenceshould be made.

Requirement 5 - adjacent footpath gives direct access to animportant route (The Ripon Rowel Walk). Soundness of proposalwould be increased by strengthening the requirements toacknowledge this route (NY LAF). to the countryside and the

wider public rights of waynetwork, including TheRipon Rowel Walk.'

Table 12.64 Key Issues: MK8 Land to the south of High Mill Farm, Markington

Marton cum Grafton Sites

MG7: Land north of Braimber Lane (smaller site), Marton cum Grafton



N/ANoted.Support - within built up area of village andclose to range of local services and facilities

Site Requirements

No amendment.Noted.Site requirements reflect recommendations ofConservation and Design Site Assessment(Historic England).

No amendment.Keeping the eastern part of the site free fromdevelopment addressed representations made byHistoric England that development was likely to harmelements which contribute to the significance of theConservation Area.

Requirement 1 - does not take into accountcurrent condition of pond or consider alternativesolutions which would result in an improvementin biodiversity currently provided by pond.

Delete requirement.The pond also has ecological value and during thecourse of considering the current planning applicationfor the site it has been established that a smallpopulation of Great Crested Newts (GCN) are presentin the pond.

Whilst it may be possible to provide a mitigation strategyto deal with the GCN, retaining the site requirement isconsidered appropriate in order to mitigate the harm tothe heritage asset.

No amendment.This requirement, as worded, is necessary to ensurethat harm to the character of the area and setting of theconservation area is mitigated.

Requirement 2 - too prescriptive.

Reword to refer to southern part of Marton cumGrafton

No amendment.The site contributes to the rural setting of theconservation area and these views across the site areidentified in the Conservation Area Appraisal as key

Requirement 3 - inappropriate to seek toenhance a view which is not readily available,primarily obtained by motorists or are transient

views, linking the village with the countryside. It isimportant that the introduction of development in thisSimplify to read "as far as practical the road

side verge should be retained and considerationshould be given to enhancing views along themain road"

location mitigates the harm to the setting of theconservation area by maintaining views throughdevelopment design and layout.





Amend SiteRequirement 8to deletereference to aTravel Plan.

Reference to a Travel Plan was included in light ofcomments from the Highway Authority at an earlierstage of plan making. It is noted that in theirconsideration of the current planning application fordevelopment of the site the Highway Authority has notrequested the submission of a Travel Plan.

Requirement 8 - 12 residential properties willnot generate significant amounts of movementsand requirement for Travel Plan is notproportionate to scale of development. Ifappropriate and justified, more appropriate tocondition requirement for such a document.

Delete reference to requiring Travel Plan

Table 12.65 Key Issues: MG7 Land north of Braimber Lane, Marton cum Grafton

MG8: Yew Tree Farm, (smaller site), Marton cum Grafton



No amendment.The indicative site yield has beenreduced to reflect the sites sensitivities.The site specific requirements seek to

Impact on Designated Heritage Assets (Historic England)

Site is significant to rural character of village and conservationarea and development would be against existing grain, harmfulto character of area and setting of nearby heritage assets.Maybe some opportunity to convert traditional farmsteadbuildings.

reduce to an acceptable level harm thatwould be caused to the significance ofthe conservation area.

Reduce extent of site to exclude open area identified asimportant open space in conservation area appraisal and makeclear development would be restricted to conversion oftraditional farm buildings.

Table 12.66 Key Issues: MG8 Yew Tree Farm, Marton cum Grafton



North Stainley Sites



Noamendment.

There is an identified residual housing requirement to be delivered duringthe plan period (as set out in Chapter 10 of the Local Plan and the HousingBackground Paper) and, through the Local Plan, there is a need to allocate

Concern at scale ofDevelopment at North Stainley

Test of soundnessland to ensure this requirement is met. The council considers that this sitecan contribute to meeting this need and the approach taken to theidentification of this site is based on reasonable evidence.


Disproportionate numbersof housing proposed As set out in the evidence base, many sites have been considered through

the site selection process. Sites have been allocated that are consideredto offer the greatest sustainability benefits and considerations such as theA large amount of

development has alreadybeen granted in the localarea

scale of development, access, and impacts on highways landscape,ecology, heritage assets and flooding were taken into account during thesite assessment process.

Potential adverse impacts of development of the site were consideredthrough the site assessment process. Where potential adverse impactswere identified, it is considered that these are not insurmountable and

No local need foradditional housing

could potentially be mitigated, as set out in the Site Requirements. Furtherassessment of these issues will be undertaken as part of the planningapplication process if required at this stage.

Affordable housing

Local infrastructurecannot cope It is recognised that new development, both individual sites and from the

cumulative impact of several sites, will place extra pressure on existinginfrastructure and may need new or improved infrastructure to support it.Negative impact on local

roads/traffic The council continues to work with the County Council, utility and otherinfrastructure/service providers to make sure the infrastructure implicationsof the allocated sites are fully assessed and where necessary mitigationLandscape impactmeasures are identified and put in place to address development impacts.Funding contributions from developers will be sought where needed toincrease capacity to provide local infrastructure.

Table 12.67

NS3: Land to west of Cockpit Green, North Stainley


N/ANoted.Support


No amendment.This site together with site NS6provides a scale of development overthe plan period that is appropriate toa Secondary Service Village.

Other:The landowner for sites NS2, 4 and 5 haswritten to villagers asking them to requestthat all of their sites are included withinthe plan. Unless all of their sites are in

Whilst the landowners have promotedseveral sites for development throughthe Local Plan process, their

the plan the sums do not add up - neitherhousing or new school will be built unlessthe landowner is given permission for allsites. No requirement for a new school representations do not suggest that

this site cannot be developed ordelivered independently of the othersites being promoted.

A significant amount of time and planninghas been invested in determining theoptimum outcome out of the minimumsites at North Stainley. Many respondentsfeel this site should come forward as partof a wider vision for the village whichincludes facilities including a new primaryschool.




Cumulative impact of this site along withothers

Deliverability of the site which appearsdependent on others in the village comingforward.


The representations made regarding this site sought the following modifications to the Plan:In order for the Local Plan to become 'sound' the Borough Council should obtain binding assurances from the landownerthat he has the capability to develop site NS3 and the interdependent NS7 without requiring the inclusion of furthersites in the Plan.

Site Requirements

No amendment.Noted.Site requirements reflect recommendations ofConservation and Design Site Assessment(Historic England).

Amend Site Requirement 10 toread: 'Provide pedestrian andcycle links within the site and

The suggested amendment isconsidered to be reasonable andwould be consistent with the approachtaken in respect of other sites.

Requirement 10 – should be requirement toensure direct pedestrian access to rights of waynetwork by gaining an access to the adjacentfootpath (at the top northerly corner of the site).(NY LAF)

from the site in order to provideconvenient routes to facilitieswithin the village and the publicrights of way network to accessnearby countryside. In additionprovide a pedestrian link to thepublic footpath adjacent to thenorthern site boundary in orderto provide convenient access tothe countryside and widerpublic rights of way network.'

No amendment.It is considered that this would beoverly prescriptive and would bemoreappropriately considered as part ofthe development of a site layout.

Requirement 11 – should be required to creategreen corridor not just consider it. (NY LAF)

Table 12.68 Key Issues: NS3 Land to west of Cockpit Green, North Stainley

NS6: Land south of A6108 (smaller site), North Stainley



N/ANoted.Support



Test of soundness

No local need for additional housingChapter 10 of the Local Plan and

Local infrastructure cannot cope the Housing Background Paper)and, through the Local Plan, thereNegative impact on local roads and traffic is a need to allocate land to ensure

No or poor access to public transport this requirement is met. The councilconsiders that this site can

No or poor access to shops and services contribute to meeting this need andthe approach taken to theidentification of this site is based onreasonable evidence.

Landscape impact





Other: As set out in the evidence base,many sites have been consideredthrough the site selection process.The heritage asset referred to in site requirements is not an

important site Sites have been allocated that areconsidered to offer the greatestsustainability benefits andIn contrast to sites NS3, NS4 and NS5 there has been no

consultation with the villagers regarding the developmentof this site NS6.

considerations such as the scale ofdevelopment, access, and impactson highways landscape, ecology,heritage assets and flooding weretaken into account during the siteassessment process.

There would be particular concern how the houses wouldfit in to the aesthetics of the village.

Difficulties with access - site borders a very busy road andaccess will therefore be dangerous Potential adverse impacts of

development of the site wereconsidered through the siteThe recent closure of permissive footpaths and access to

the adjoining land historically used by village residents isdirectly at odds with what is now suggested in terms of cycleand walking routes into and out of the site.

assessment process. Wherepotential adverse impacts wereidentified, it is considered that theseare not insurmountable and couldpotentially be mitigated, as set out

Cumulative effect of this site with others in the village willresult in disproportionate amounts of development

in the Site Requirements. Furtherassessment of these issues will beundertaken as part of the planningapplication process if required atthis stage.

It is recognised that newdevelopment, both individual sitesand from the cumulative impact ofseveral sites, will place extrapressure on existing infrastructureand may need new or improvedinfrastructure to support it. Thecouncil continues to work with theCounty Council, utility and otherinfrastructure/service providers tomake sure the infrastructureimplications of the allocated sitesare fully assessed and wherenecessary mitigation measures areidentified and put in place toaddress development impacts.Funding contributions fromdevelopers will be sought whereneeded to increase capacity toprovide local infrastructure.


The representations made regarding this site sought the following modifications to the Plan:Remove the site from the Plan

Table 12.69 Key Issues: NS6 Land south of A6108, North Stainley



Pannal Sites

PN17: Land adjoining Spring Lane Farm, Pannal

12.12 Respondents include the Save Spring Lane SLA Defence Group which comprises over 250residents. This representation is endorsed by Pannal and Burnbridge Parish Council whohave also submitted a collective response with support from residents. Independent landscapeand traffic assessments on the site have also been submitted.



N/ANoted.Support:subject of pending outline planning application for 52 dwellings

can meet site requirements and development proposed seeks toaddress issues

timescale set out in housing trajectory considered realistic andachievable



Issue with the consultation

Legal compliancedelivered during the

Issues with Evidence Base plan period (as set outHEDNA in Chapter 10 of the

Local Plan and theThe plan does not deal with infrastructure- the infrastructure plan isnot available. Infrastructure policies should be developed alongsidethe Local Plan

Housing BackgroundPaper) and, throughthe Local Plan, there isa need to allocate landto ensure thisThe need for improved water supply and sewerage has not been

identified/ addressed requirement is met.The council considersthat this site canInadequate assessment of infrastructure needs, particularly traffic

and education contribute to meetingthis need and theapproach taken to the

The site is too big identification of this siteis based on reasonableevidence.A large amount of development has already been granted in the local area

The site is outside the current development limit As set out in theevidence base, manysites have beenNo local need for additional housing

Local infrastructure cannot cope considered through thesite selection process.

Negative impact on local roads/traffic Sites have beenallocated that are

No or poor access to public transport considered to offer thegreatest sustainabilityThe proposed upgrade of the Leeds-Harrogate-York rail line is now

unlikely to go ahead benefits andconsiderations such asthe scale of

No or poor access to shops and services development, access,and impacts on

Local schools are full highways landscape,ecology, heritage

GPs/dentists are full assets and floodingwere taken intoaccount during the siteassessment process.

The site is in the Green Belt





Loss of open space/sports pitches Potential adverseimpacts ofdevelopment of the siteNegative impact on the local community

It is vital for Pannal to preserve its physical identity/ retain physicalseparation from Harrogate if it is to continue as a separate and distinctcommunity

were consideredthrough the siteassessment process.Where potentialadverse impacts werePannal will no longer be a villageidentified, it isconsidered that theseLoss of amenity that the open fields currently provideare not insurmountableand could potentially

Loss of agricultural land be mitigated, as set outin the Site

Negative impact on the landscape Requirements. Furtherassessment of these

Coalescence issues will beundertaken as part of

The site is in a designated special landscape area (SLA) the planningapplication process ifrequired at this stage.

Unacceptable cumulative impact of allocating multiple sites in theCrimple Valley

It is recognised thatnew development, bothindividual sites and


Risk of flooding from the cumulativeThe site is in the Nidderdale Area of Outstanding Natural Beauty (AONB) impact of several sites,

will place extraNegative impact on local wildlife and biodiversity pressure on existing

infrastructure and mayLoss of protected historic hedgerowneed new or improvedinfrastructure to

Negative impact on the conservation area support it. The councilcontinues to work withThe site is identified in the conservation area appraisal as having 'long

views over rolling farmland' the County Council,utility and otherinfrastructure/service

Impact on Designated Heritage Assets providers to make surethe infrastructureDevelopment of site would be inconsistent with conservation of

heritage assets as required by national policy guidance. Agree withconclusion of Conservation and Design Site Assessment that harmis not capable of effective mitigation (Historic England)

implications of theallocated sites are fullyassessed and wherenecessary mitigationmeasures are identified

Loss of employment land and put in place toaddress development

Other: impacts. Fundingcontributions fromIt is vital for Pannal to preserve its physical identity/ retain physical

separation from Harrogate if it is to continue as a separate and distinctcommunity

developers will besought where neededto increase capacity toprovide localinfrastructure.

Pannal will no longer be a village

Inclusion of the site is a late addition to the plan It should be noted thatthe site is not in theGreen Belt or theNidderdale AONB.

Need housing that is affordable for young families and first time buyersnot more executive developments

The plan acknowledges the need for minimising greenhouse gasemissions yet designates sites for development that will increasetraffic and pollution

No provision to ensure that the housing mix delivered will match theneeds identified in the HEDNA





Negative impact on non-designated heritage assets (Spring LaneFarm, Pannal Methodist Church)

Negative impact on local distintiveness

The site cannot accommodate 72 houses

The council should have reviewed Green Belt boundaries/ removedland from the Green Belt and allocated this land ahead of site PN17

Provision of affordable homes not appropriate on this site

Other available sites in Pannal that are more sustainable


The representations made regarding this site sought the following modifications to the Plan:Remove the site from the plan (Respondents include Historic England).

Allocate a different site/more than one new settlement

Amend site boundary/reduce site area to 30% of the proposed

Prioritise brownfield sites

Reduce the number of houses in the plan

Ensure committed sites with planning permission are delivered before allocating new sites

Focus development where the infrastructure is already in place

Include policy to prevent development in Special Landscape Areas

Update evidence base including carrying out detailed traffic studies/include full details of all improvements requiredand costings in Infrastructure Delivery Plan

Carry out SA/SEA study of cumulative effects of allocations in Pannal


PN19: Land to the west of Leeds Road, Pannal

12.13 Respondents include Pannal and Burnbridge Parish Council who have also submitted acollective response with support from residents.





Legal compliance

Issues with Evidence Basedelivered during the plan

The site is too big period (as set out inChapter 10 of the LocalA large amount of development has already been granted in the area Plan and the Housing

A disproportionate level of growth is being planned in Pannal Background Paper) and,through the Local Plan,there is a need to





No local need for additional housing allocate land to ensurethis requirement is met.The council considersThe site is outside the current development limitthat this site can

No or poor access to public transport contribute to meeting thisneed and the approachLocal infrastructure cannot cope taken to the identificationof this site is based onreasonable evidence.


No or poor access to shops and servicesAs set out in theevidence base, manysites have been


GPs/Dentists are full considered through thesite selection process.

Risk of flooding Sites have beenallocated that arePoor drainageconsidered to offer the

Negative impact on the landscape greatest sustainabilitybenefits and

The site is in a designated special landscape area (SLA) considerations such asthe scale of

The site is in the Green Belt development, access,and impacts on

Loss of public open space/sports pitches highways landscape,ecology, heritage assets

The site is a greenfield site and flooding were taken

Negative impact on the local community into account during thesite assessmentprocess.Negatively affect the character and amenity of the Harrogate

Ringway footpath

Potential adverseimpacts of developmentof the site were

It is vital for Pannal to preserve its physical identity/ retain physicalseparation from Harrogate if it is to continue as a separate anddistinct community considered through the

site assessmentprocess.Where potentialPannal will no longer be a villageadverse impacts wereidentified, it isLoss of amenity that the open fields currently provideconsidered that theseare not insurmountable

Negative impact on local wildlife and biodiversity and could potentially beNegatively affect a strategic green infrastructure corridor mitigated, as set out in

the Site Requirements.Further assessment ofWill lead to loss of trees (including those that may be aged or veteran

or ancient woodland) these issues will beundertaken as part of theplanning applicationprocess if required at thisstage.

Loss of habitat for birds, newts, fish, butterflies

Will negatively affect the health and wellbeing of existing residents

It is recognised that newdevelopment, bothindividual sites and from

Negative impact on the conservation area (Pannal)

Negative impact on Designated Heritage Assets the cumulative impact ofseveral sites, will placeextra pressure onSt Roberts Churchexisting infrastructureand may need new orViews of and from the Crimple Viaductimproved infrastructureto support it. The council





Development of site would be inconsistent with conservation of heritageassets as required by national policy guidance. Agree with conclusion ofConservation and Design Site Assessment that harm is not capable ofeffective mitigation (Historic England)

continues to work withthe County Council,utility and otherinfrastructure/serviceproviders to make surethe infrastructure

Issue with consultation implications of theallocated sites are fully

Other assessed and whereNegative impact on public rights of way necessary mitigation

measures are identifiedReasonable alternatives have not been considered. These wouldinclude: consideration of a new settlement; consideration of and put in place tobrownfield sites; consideration of a Green Belt boundary review so address developmentthat nearby land currently in Green Belt could be allocated instead;former gas works site in Harrogate

impacts. Fundingcontributions fromdevelopers will beNegative impact on local distintiveness, including: linear development

not in keeping with the core shape and form of the settlement sought where needed toincrease capacity toprovide localinfrastructure.

Housing numbers included in the plan are not deliverable: largeamount of unimplemented permissions, already a shortfall in delivery,lack of funding, short supply of labour, lack of infrastructure plan,developers will land bank to maximise profit

It should be noted thatthis site is not in theGreen Belt.

The site is not deliverable due to the high costs of developing thisparticular site: dealing with flood risk, provision for wildlife, provisionof infrastructure, access, school provision, affordable housingThe plan acknowledges the need for minimising greenhouse gasemissions yet designates sites for development that will increasetraffic and pollutionThe plan does not meet the government's guideline that applicantsshould carryout pre-application community involvement and considerthe content of relevant plans, assessments and appraisalsAllocation of the site would be contrary to draft policy GS3:Development Limits of the Local PlanNo provision to ensure that the housing mix delivered will match theneeds identified in the HEDNAA disproportionate level of growth is planned for PannalAs the landowner of the site the council stand to benefit from theirdecision to allocate for developmentOther available sites in Pannal that are more sustainable


The representations made regarding this site sought the following modifications to the Plan:Remove the site from the plan (Respondents include Historic England)

Reduce site area so that the site does not extend beyond the (roughly) northern boundary of the Crimple ValleyGarden Centre

Reduce site area to 30% of that currently proposed

Allocate different site/more than one new settlement

Review Green Belt to south of Pannal

Prioritise brownfield sites and bringing back into use empty properties

Reduce number of houses in Plan

Update the evidence base including undertaking detailed traffic studies, a landscape and visual impact assessment

Carry out SA/SEA study of cumulative impacts of allocations in Pannal

Ensure sites with existing permission are fully built before allocating new sites





Include policy to prevent development in Special Landscape Areas

Site Requirements

No amendment.There will remain anarea of open landbetween Harrogate andPannal.

Requirement 2 - cannot be achieved as development of the site willremove the open land between the settlements

Table 12.71 Key Issues: PN19 Land to the west of Leeds Road, Pannal

Sharow Site

SH1: Land at New Road, Sharow




No amendmentIn selecting this site it was consideredthat development is unlikely to affectany elements which contribute to the

Historic England: Based on available information do notconcur that has been adequately demonstrated that harmto historic environment is capable of mitigation to extent

significance of a heritagewhich is commensurate with conserving their significance.asset. Visually the site is well containedBefore allocating site there is need for evaluation,by landform, hedges and existingpreferably including a ZTV, of degree to whichdevelopment. The Council willcontinue to have dialogue with HistoricEngland.

development will impact upon views of Cathedral and keyviews from WHS. If harm would result, Plan needs toclearly set out measures by which harmmight be removedor reduced. If despite mitigation measures still likely to beharm, site should not be allocated unless clear publicbenefits of doing so and set out within justification forallocation.

Undertake evaluation, preferably including a ZTV, ofdegree to which development will impact upon views ofCathedral and key views from WHS and amend Planaccordingly.

Site Requirements

Amend SiteRequirement 5 toread:

The suggested amendment would beconsistent with the wording of similarsite requirements in respect of otherallocations.

Requirement 5 – should be required to provide this notjust investigate provision (NY LAF).

'Provide Investigateproviding pedestrianand cycle access toBack Lane.'

Table 12.72 Key Issues: SH1 Land at New Road, Sharow

Spofforth Sites

SP4: Land at Castle Farm, Spofforth







No amendment.There is an identified residual housingrequirement to be delivered during theplan period (as set out in Chapter 10

A large amount of development has already beengranted in the local area

Negative impact on local roads/ traffic. of the Local Plan and the HousingBackground Paper) and, through the

Local schools are full Local Plan, there is a need to allocateland to ensure this requirement is met.GPs/dentists are full The council considers that this site can

Negative impact on the landscape and characterof the village

contribute to meeting this need andthe approach taken to the identificationof this site is based on reasonableevidence.

As set out in the evidence base, manysites have been considered throughthe site selection process. Sites havebeen allocated that are considered tooffer the greatest sustainabilitybenefits and considerations such asthe scale of development, access, andimpacts on highways landscape,ecology, heritage assets and floodingwere taken into account during the siteassessment process.

Potential adverse impacts ofdevelopment of the site wereconsidered through the siteassessment process.Where potentialadverse impacts were identified, it isconsidered that these are notinsurmountable and could potentiallybe mitigated, as set out in the SiteRequirements. Further assessment ofthese issues will be undertaken as partof the planning application process ifrequired at this stage.

It is recognised that new development,both individual sites and from thecumulative impact of several sites, willplace extra pressure on existinginfrastructure and may need new orimproved infrastructure to support it.The council continues to work with theCounty Council, utility and otherinfrastructure/service providers tomake sure the infrastructureimplications of the allocated sites arefully assessed and where necessarymitigation measures are identified andput in place to address developmentimpacts. Funding contributions fromdevelopers will be sought whereneeded to increase capacity to providelocal infrastructure.


The representations made regarding this site sought the following modifications to the Plan:Reduce indicative yield.

Reduce number of houses in the plan.




Site Requirements

N/AFollowing discussion Historic Englandhave withdrawn this objection.

Requirement 1 - as worded implies that it isacceptable, in principle, to harm the conservationarea. (Historic England)

Amend to read: '.. development of the site shouldconserve those elements which contribute to thesignificance of this designated heritage asset, andshould seek opportunities to enhance...'

N/AFollowing discussion Historic Englandhave withdrawn this objection.

Requirement 2 - as worded implies that it isacceptable, in principle, to harm the listedbuilding. (Historic England)


Amend Site Requirement 3to read: '... and outbuildings,including Beren Lodge,

Agree that the proposed wordingamendment would more clearlyexpress the importance of retaining

Requirement 3 - only requires prospectivedevelopers to 'assess' buildings for retention. Ifnecessary to ensure development takes place in

should be assessed forthese buildings. Reference to BerenLodge should, however, be deleted asreference to it was included in error.

manner consistent with appropriate conservationof conservation area, should be a requirement ofany development. (Historic England)

retention andincorporation retained andincorporated into thedevelopment. A robustAmend to read: '... including Beren Lodge should

be retained and incorporated into the development.A robust justification would need to be to justify theloss of any of these structures.'

justification of any proposeddemolition should beprovided would be neededto justify the loss of any ofthese structures.'

Amend Site Requirement 9to read: '... public footpathon the northern siteboundary and create apedestrian link to it.'

Agree that the suggested amendmentwould be a sensible.

Requirement 9 - soundness of the proposals wouldbe strengthened if there was a requirement toprovide a direct pedestrian access point to thisfootpath (NY LAF).

Table 12.73 Key Issues: SP4 Land at Castle Farm, Spofforth

SP6: Land at Massey Fold, Spofforth

12.14 The Council's Planning Committee considered an application for the development of part ofthis allocation at their meeting on the 3 July 2018. The Committee resolved to approve theapplication subject to the completion of a S106 Agreement and receipt of details and approvalof trial trenching works.




Noamendment

Site SP5 is identified as an important openspace in the Conservation Area and thereforedevelopment would have a significant impacton the conservation area and an adjacent listedbuilding.

Site boundary issues - the site should be extended toinclude land to west of Massey Garth or site SP5 restored

Noamendment

There is an identified residual housingrequirement to be delivered during the planperiod (as set out in Chapter 10 of the Local

Negative impact on local roads






Risk of flooding Plan and the Housing Background Paper) and,through the Local Plan, there is a need toallocate land to ensure this requirement is met.Negative impact on local wildlife and biodiversityThe council considers that this site can

Negative impact on the conservation area (HistoricEngland)

contribute to meeting this need and theapproach taken to the identification of this siteis based on reasonable evidence.Negative impact on a listed building (Historic England)

As set out in the evidence base, many siteshave been considered through the siteselection process. Sites have been allocatedthat are considered to offer the greatestsustainability benefits and considerations suchas the scale of development, access, andimpacts on highways landscape, ecology,heritage assets and flooding were taken intoaccount during the site assessment process.

Potential adverse impacts of development ofthe site were considered through the siteassessment process. Where potential adverseimpacts were identified, it is considered thatthese are not insurmountable and couldpotentially be mitigated, as set out in the SiteRequirements. Further assessment of theseissues will be undertaken as part of theplanning application process if required at thisstage.



The representations made regarding this site sought the following modifications to the Plan:Site should be deleted

Site Requirements

Noamendment

Unnecessary to state the phasing of thedevelopment within the site requirements. Theaim of the requirement is to ensure that thepedestrian and cycle links are provided whenthe site is developed.

Requirement 9 - should be amended to reflectdevelopment will come forward in two phases and directcycle and pedestrian link to High Street will be providedas part of second development phase.

Replace second sentence with: "The first phase ofdevelopment should provide pedestrian and cycle linksonto Harrogate Road and East Park Road which leadsdirectly to High Street. A further pedestrian and cycle linkonto High Street should be provided upon completion ofthe second phase of development"





Noamendment

The site requirement as worded is consistentwith Policy CC2 : Rivers and therefore achange to the site requirement to add an extra

Requirement 2 - River will be important wildlife corridorin an arable landscape. To be consistent with policy NE3and national policy so that there is no loss of biodiversity

buffer would not be appropriate. The siteand if possible biodiversity enhancement, and in order torequirements ask for a ecological appraisal tojoin up habitat, suggest a wider buffer to the river for

example 15-20metres similar to other housing in Spofforth.(Yorkshire Wildlife Trust)

be undertaken as part of the submission of aplanning application which would be expectedto include the site being adjacent to the river.

Amend to read: "The site layout should take account ofthe Environment Agency’s requirement for an 8 metreeasement buffer along the Crimple Beck by virtue of itsclassification as a Main River, but should also allow for anadditional 10 metres buffer to allow the river to act as awildlife corridor, which should be maintained as anundeveloped naturalised buffer and should not containany structures such as fencing or footpaths that couldincrease flood risk.”

Table 12.74 Key Issues: SP6 Land at Massey Fold, Spofforth

Staveley Site

SV1: Land between Minskip Road and Low Field Lane, Staveley

12.15 Respondents include the Staveley Resident's Action Group (SRAG) whose response wassubmitted with 203 signatures of support.





Tests of soundness:not appropriate strategy as does not followsettlement hierarchy in GS2.

Chapter 10 of the Local Plan and theHousing Background Paper) and,

The site is too big through the Local Plan, there is aneed to allocate land to ensure this

No local need for additional housing requirement is met. The councilconsiders that this site can contribute

Negative impact on local roads and traffic to meeting this need and theapproach taken to the identificationof this site is based on reasonableevidence.

Poor access to public transport

Impact on local schools

Poor access to shops and services As set out in the evidence base,many sites have been consideredthrough the site selection process.Risk of floodingSites have been allocated that are

Poor drainage considered to offer the greatestsustainability benefits and

Negative impact on landscape considerations such as the scale ofdevelopment, access, and impactsLoss of open space on highways landscape, ecology,

Negative impact on local wildlife and biodiversity(Respondents include North Yorkshire WildlifeTrust)

heritage assets and flooding weretaken into account during the siteassessment process.

Negative impact on conservation area






Other:Owner of land between Low Field Lane andSV1 not willing to provide access.

assessment process. Wherepotential adverse impacts wereidentified, it is considered that theseare not insurmountable and couldNo justification for size of area deemed

developable. potentially be mitigated, as set outin the Site Requirements. Furtherassessment of these issues will beConsult Yorkshire Wildlife Trust on impacts

of this allocation (Natural England) undertaken as part of the planningapplication process if required at thisstage.

It is recognised that newdevelopment, both individual sitesand from the cumulative impact ofseveral sites, will place extrapressure on existing infrastructureand may need new or improvedinfrastructure to support it. Thecouncil continues to work with theCounty Council, utility and otherinfrastructure/service providers tomake sure the infrastructureimplications of the allocated sites arefully assessed and where necessarymitigation measures are identifiedand put in place to addressdevelopment impacts. Fundingcontributions from developers will besought where needed to increasecapacity to provide localinfrastructure.



Allocate quantum of housing into higher order settlement.

Reduce the scale of site/ number of dwellings (North Yorkshire Wildlife Trust).

Increase developable area to allow 105 dwellings.

Site Requirements

No amendment.The site requirement establishesthe principle that green infrastructureshould be provided to mitigate for

Requirement 2 - provide areas of greeninfrastructure to mitigate potential for increasedrecreational pressure at nearby Nature Reserve.(North Yorkshire Wildlife Trust) potential increased recreational

pressure on the Nature Reserve.However, it is considered that the“Provide 2ha of green infrastructure specifically

designed to mitigate the potential for increasedrecreational pressure on the nearby Staveley NatureReserve”.

quantum of that provision should beconsidered at planning applicationstage and in the context of aproposed development layout.

Amend Site Requirement 8 toread: 'Provide pedestrian andcycle links within the

An amendment is proposed to SiteRequirement 8 to clarify how thisaccess will be achieved.

Requirements 7 to 9 - suggestion owner of partof track linking site to Low Field Lane will not allowaccess to be made

site. Provide pedestrian andcycle access from Low Field




Lane (track) and to connectwith the public right of wayand Low Field Lane in orderto provide a convenientconnection with the publicfootpath along the track anda convenient route to facilitiesin the centre of the village.'

Table 12.75 Key Issues: SV1 Land between Minskip Road and Low Field Lane, Staveley

Summerbridge Sites

SB1: Clough House Farm, Summerbridge



No amendmentThere is an identified residual housingrequirement to be delivered during theplan period (as set out in Chapter 10 of

Negative Impact on Designated HeritageAssets (Historic England).

Conservation and Design Assessmentidentified that loss of this area and subsequentdevelopment would likely harm significanceof heritage assets which could not mitigated.

the Local Plan and the HousingBackground Paper) and, through the LocalPlan, there is a need to allocate land toensure this requirement is met. Thecouncil considers that this site cancontribute to meeting this need and theapproach taken to the identification of thissite is based on reasonable evidence.

Impact on the AONB (Natural England)Strong potential for significant adverse impactson AONB. Allocation could expand the formof the settlement too far up the hill and makeit more visible.

As set out in the evidence base, manysites have been considered through thesite selection process. Sites have beenallocated that are considered to offer the

Negative impact on the landscape greatest sustainability benefits andconsiderations such as the scale of

Negative impact on local roads/traffic development, access, and impacts onhighways landscape, ecology, heritage

Other: assets and flooding were taken intoaccount during the site assessmentprocess.

Combined housing commitments andallocations within the villages ofSummerbridge and Dacre Banks is excessiveand is likely to result in a significant anddetrimental impact to the villages and thewider AONB.

Potential adverse impacts of developmentof the site were considered through thesite assessment process. Where potentialadverse impacts were identified, it isconsidered that these are notinsurmountable and could potentially bemitigated, as set out in the SiteRequirements. Further assessment ofthese issues will be undertaken as part ofthe planning application process ifrequired at this stage.

It is recognised that new development,both individual sites and from thecumulative impact of several sites, willplace extra pressure on existinginfrastructure and may need new orimproved infrastructure to support it. Thecouncil continues to work with the CountyCouncil, utility and otherinfrastructure/service providers to makesure the infrastructure implications of the




allocated sites are fully assessed andwhere necessary mitigation measures areidentified and put in place to addressdevelopment impacts. Fundingcontributions from developers will besought where needed to increase capacityto provide local infrastructure. Thedevelopable areaof the site has beenreduced.


The representations made regarding this site sought the following modifications to the Plan:Delete site or reduce site area to no more than eastern part of field to south of 'Shalom' on B6165 (Historic England).Mitigation should ensure that this part of the village remains linear and compensatory measures should be incorporated.Local vernacular and density of development should be taken into consideration as site requirement (Natural England).Reduce the number of housing allocations in Summerbridge and Dacre Banks.Evidence base for the transport and economic policies affecting rural areas is weak and should be addressed.

Table 12.76 Key Issues: SB1 Clough House Farm, Summerbridge

SB5: Land at Braisty Woods, Summerbridge





Impact on AONB(Natural England)Significant impacts on Nidderdale AONB.Allocation not in proportion to rest of villageand is very visible from other side of valley Plan and the Housing Background Paper) and,

through the Local Plan, there is a need to(Dacre Banks) and public right of waynetwork. Allocation would significantlychange the form of the village.

allocate land to ensure this requirement is met.The council considers that this site cancontribute to meeting this need and theapproach taken to the identification of this siteis based on reasonable evidence.Other:

Combined housing commitments andallocations within the villages ofSummerbridge and Dacre Banks is

As set out in the evidence base, many siteshave been considered through the siteselection process. Sites have been allocatedexcessive and is likely to result in a

significant and detrimental impact to thevillages and the wider AONB.

that are considered to offer the greatestsustainability benefits and considerations suchas the scale of development, access, andimpacts on highways landscape, ecology,heritage assets and flooding were taken intoaccount during the site assessment process.


Negative impact on the landscapePotential adverse impacts of development ofthe site were considered through the siteassessment process.Where potential adverseimpacts were identified, it is considered thatthese are not insurmountable and couldpotentially be mitigated, as set out in the SiteRequirements. Further assessment of theseissues will be undertaken as part of theplanning application process if required at thisstage.

It is recognised that new development, bothindividual sites and from the cumulative impactof several sites, will place extra pressure onexisting infrastructure and may need new or





improved infrastructure to support it. Thecouncil continues to work with the CountyCouncil, utility and other infrastructure/serviceproviders to make sure the infrastructureimplications of the allocated sites are fullyassessed and where necessary mitigationmeasures are identified and put in place toaddress development impacts. Fundingcontributions from developers will be soughtwhere needed to increase capacity to providelocal infrastructure.


The representations made regarding this site sought the following modifications to the Plan:Development should be concentrated to the south of the site and that necessary mitigation and compensation measuresshould be a requirement (Natural England).Evidence base for the transport and economic policies affecting rural areas is weak and should be addressedReduce the number of housing allocations in Summerbridge and Dacre Banks

Table 12.77 Key Issues: SB5 Land at Braisty Woods, Summerbridge

Tockwith Site

TW3: Church Farm, Tockwith



N/ANoted.Support allocation:sustainable location

transport assessment confirms would be no significant impacton local highway network




The site is too big(as set out in Chapter 10 of the

A large amount of development has already been granted in thelocal area

Local Plan and the HousingBackground Paper) and, throughthe Local Plan, there is a needThe site is outside the current development limit to allocate land to ensure this

No local need for additional housing requirement is met. The councilconsiders that this site can

Previous applications to develop the site have been refused contribute to meeting this needand the approach taken to theidentification of this site is basedon reasonable evidence.


Negative impact on local roads/trafficAs set out in the evidence base,many sites have beenconsidered through the site


Local schools are fullselection process. Sites have

No or poor access to shops and services been allocated that areconsidered to offer the greatest

Risk of Flooding sustainability benefits andconsiderations such as the scale

Poor drainage of development, access, and





impacts on highways landscape,ecology, heritage assets andflooding were taken into accountduring the site assessmentprocess.


Site is a greenfield site

Negative impact on the local community

Negative impact on local wildlife and biodiversityPotential adverse impacts ofdevelopment of the site wereconsidered through the site


Negative impact on a listed building assessment process. Wherepotential adverse impacts were

Other identified, it is considered thatthese are not insurmountablebetter alternativesand could potentially bemitigated, as set out in the SiteLack of employment. Marston Moor Business Park should be

extended to accommodate additional employment for proposedhousing.

Requirements. Furtherassessment of these issues willbe undertaken as part of theplanning application process ifrequired at this stage.

HBCs requirement is in excess of the governments indicativefigure of 395

It is recognised that newdevelopment, both individualsites and from the cumulativeimpact of several sites, will placeextra pressure on existinginfrastructure andmay need newor improved infrastructure tosupport it. The council continuesto work with the County Council,utility and otherinfrastructure/service providersto make sure the infrastructureimplications of the allocatedsites are fully assessed andwhere necessary mitigationmeasures are identified and putin place to address developmentimpacts. Funding contributionsfrom developers will be soughtwhere needed to increasecapacity to provide localinfrastructure.

N/AHistoric England have nowconfirmed that they no longerconsider development of this

Negative impact on designated heritage assets

Before allocating site there is need for evaluation of impact loss ofsite and future development might have upon elements whichcontribute to significance of the Registered Battlefield. If harm would

area is likely to harm thesignificance of the RegisteredBattlefield and have withdrawntheir objection.

result, Plan needs to clearly set out measures by which harm mightbe removed or reduced. If despite mitigation measures still likely tobe harm, site should not be allocated unless there are clear publicbenefits to do so. (Historic England)

Undertake evaluation of impact loss of site and future developmentmight have upon elements which contribute to significance of theRegistered Battlefield and amend Plan accordingly







Remove site from planSite would be suitable for a development of about 10 houses adjacent to and incorporating the current farm buildings.This would have minimal impact on the conservation area and involve less stress on the currently overloadedinfrastructure

Table 12.78 Key Issues: TW3 Church Farm, Tockwith

Commitments - Housing



N/ANotedK21 and K22: Natural England notes allocations K37, K32, K21,K22, K23, K24, K31, EC1g and K25 lie in close proximity toHay-a-Park Site of Special Scientific Interest (SSSI). NaturalEngland is concerned about the potential for damage to the notifiedfeatures of the SSSI as a result of increased recreationaldisturbance. We broadly welcome the requirements for mitigationand compensation, as set out in the site requirements, particularlyin relation to mitigating across the sites.

No AmendmentSite requirements have notbeen included for the site asthey are not required becauseit has full planning permissiongranted.

DB3: Natural England notes there is an extant planningpermission on this allocation but advise that requirements are setout in the plan in order to inform decision making should furtherpermissions be sought on this site during the lifetime of the plan.This should set out the requirements for landscape assessment,mitigation and if necessary compensation in relation to impactson Nidderdale AONB.

Move Site GB2 fromthe Allocations to theCommitments tablein DM1

This site now has planningpermission for housing.

GB2 - fails test of soundeness

No amendmentThe site is a commitment nota housing allocation.

H3: Negative impact on roads/traffic; the area is at risk of flooding;the site is a green field site


DM2: Employment Allocations

Policy DM2: Employment Allocations



Noamendment.

The HEDNA assessment recommended that the site wasunlikely to attract commercial interest, due to accessibility,and should not be identified as an allocation for

Land north of Marston Business Park (TW2)should be re-instated as an employmentallocation:

employment uses. The council has allocated sufficientMarston Business Park identified as keyemployment site in Local Plan employment sites to meet the employment requirement

and an additional buffer to provide flexibility and choice ofsites over the plan period, and as such does not considerthe allocation of this site is needed.

site previously recognised as potentialallocation

removal of allocation based on flawedevidence in HEDNA and site not robustlyassessed





Noamendment.

The council has allocated sufficient employment sites tomeet the employment requirements and an additional bufferto provide flexibility and choice of sites over the plan period,

Land at Racecourse Approach, Wetherby (siteOC4) should be allocated for employment:

benefits as location for key employmentsite allocation not recognised and as such does not consider the allocation of this site

which does not compare as favourably to other sitesassessed and identified as allocations is needed.development could generate economic

and sustainability benefits for notableproportion of district

Noamendment.


NS4 should be allocated because it is anintegral element of North Stainley Estatessustainable development proposals for thevillage. and as such does not consider the allocation of this site

which does not compare as favourably to other sitesassessed and identified as allocations is needed.

Noamendment.


Land north of Allerton Park should be allocated(in whole or part) as an employment site:

Sustainable location with good transportlinks to J47 and J48 of the A1(M) and as such does not consider the allocation of this site

which does not compare as favourably to other sitesassessed and identified as allocations is needed.Potential to take advantage of close

proximity to Allerton Waste RecoveryPark

Noamendment.

The council has allocated sufficient employment sites tomeet the employment requirement sand an additional bufferto provide flexibility and choice of sites over the plan period,

Land at south west of J50 A1(M) (site OC1)should be allocated:

Should encourage employmentopportunities along the A1(M) and as such does not consider the allocation of this site

which does not compare as favourably to other sitesassessed and identified as allocations is needed.

NoAmendment


Land at Grey Thorn Lane, Hopperton (site HP6)should be allocated:

excellent strategic position for a proposednew rail halt with road frontage onto GreyThorn Lane and next to the A168 and theA1(M)

and as such does not consider the allocation of this sitewhich does not compare as favourably to other sitesassessed and identified as allocations is needed.

would provide commuters with alternativemode of transport improving congestion

improve economic viability for additionalservices in locality

Noamendment.


Land at Jubilee Mill, Copgrove (site CP1) shouldbe allocated:

SHELAA acknowledges site hasemployment development potential and as such does not consider the allocation of this site

which does not compare as favourably to other sitesassessed and identified as allocations is needed.Development will support services and

facilities in village

Site should be allocated to allowexpansion of existing business inaccordance with Policy EC2

Noamendment.


Land at Aldborough Gate, Minskip (site MS4)should be allocated:





and as such does not consider the allocation of this sitewhich does not compare as favourably to other sitesassessed and identified as allocations is needed.

sustainable location within the A1(M)corridor just off Junction 48 and in closeproximity to Boroughbridge

Noamendment.

By virtue of its previous use the site is classed as beingan employment site and, therefore, covered by Policy EC1.

Allocate Former Gas depot, Skipton Road asemployment land


Harrogate Site

H16: Playing fields, Harrogate College



N/ANotedSupport allocation

Noamendment.

There is an identified employmentrequirement to be delivered during theplan period (as set out in Chapter 3 of

Issue with Evidence Base

Remove site from planthe Local Plan and the Economy

Development of site H16 would prejudice potential futureexpansion of the College.

Background Paper) and, through theLocal Plan, there is a need to allocateland to ensure this requirement is met.Loss of playing fields - Harrogate has a dire shortage of playing

fields, for example Pannal Ash JFC has used pitches in GreenHammerton as a home venue at times.

The council considers that this site cancontribute to meeting this need and theapproach taken to the identification ofthis site is based on reasonableevidence.

H16 fields are often waterlogged and unplayable, but if someeffective drainage was installed, these would be great playingfields, as there would be loads of parking available withinHornbeam Park at the weekend when games are played. As set out in the evidence base, many

sites have been considered throughthe site selection process. Sites haveLegal requirement to consult Sport England prior to changing the

use of any playing fields – there is no mention that this has beendone.

been allocated that are considered tooffer the greatest sustainability benefitsand considerations such as the scale

Designate H16 for educational use of development, access, and impactson highways landscape, ecology,heritage assets and flooding weretaken into account during the siteassessment process.

Potential adverse impacts ofdevelopment of the site wereconsidered through the siteassessment process. Where potentialadverse impacts were identified, it isconsidered that these are notinsurmountable and could potentiallybe mitigated, as set out in the SiteRequirements. Further assessment ofthese issues will be undertaken as partof the planning application process ifrequired at this stage.

It is recognised that new development,both individual sites and from thecumulative impact of several sites, willplace extra pressure on existinginfrastructure and may need new orimproved infrastructure to support it.





The council continues to work with theCounty Council, utility and otherinfrastructure/service providers tomakesure the infrastructure implications ofthe allocated sites are fully assessedand where necessary mitigationmeasures are identified and put inplace to address development impacts.Funding contributions from developerswill be sought where needed toincrease capacity to provide localinfrastructure.

The impact of development on existingsporting provision is covered by PolicyHP6.

Site Requirements

Noamendment.

Noted.Site requirements reflect recommendations of Conservation andDesign Site Assessment (Historic England).

Table 12.81 Key Issues: H16 Playing fields, Harrogate College

H28: Land at Wetherby Road, Harrogate



No amendment.The HEDNA has assessed this site as being acommercially attractive location and as such theCouncil consider it appropriate that it is identified forB uses. Other uses would be considered on theirmerits against the criteria set out in the policy.

This site is a shop window for the YorkshireShowground and as a consequence the siteshould not be restricted to B1, B2 and B8 uses.

No amendment.The site specific requirements seek to reduce to anacceptable level harm that would be caused to thesignificance of the heritage assets.

Conservation and Design Assessment identifiedthat loss of this area and subsequent developmentwould likely harm significance of heritage assetswhich could not mitigated (Historic England).

Site should be deleted.

Table 12.82 Key Issues: H28 Land at Wetherby Road, Harrogate

Melmerby Sites

MB3: Land south of Barker Business Park, Melmerby


No amendment.NotedSupport

No amendment.Collectively sites MB3, MB6 and MB8allocate over 20 hectares (gross) ofemployment land for B1, B2 or B8 uses.

Current demand for employment land at BusinessPark outstrips allocations made and only serves toconstrain the potential rate of growth that might beachieved. This is considered to be reasonable and

the most appropriate time to considerwhether additional land is required wouldbe as part of a future Plan review.

Allocate additional employment landat Barker Business Park.




Site requirements

Add additional bulletpoint to Requirement 5'an archaeologicalevaluation'

Agree, an additional bullet will be added.High probability of archaeological remains in this area,which might potentially be of national importance.Plan should set out a requirement for anydevelopment proposal to be informed by appropriatearchaeological evaluation (Historic England).

Add additional bullet point to Requirement 5 'anarchaeological evaluation'

Table 12.83 Key Issues: MB3 Land south of Barker Business Park, Melmerby

MB6: Land at Melmerby Industrial Estate


Amend site reference to 'Land to thenorth of Barker Business Park'

Agree.Amend site reference to 'Land to the north of BarkerBusiness Park'.

Site Requirements

Add additional bullet point toRequirement 5 'an archaeologicalevaluation'

Agree, an additionalbullet will be added.

High probability of archaeological remains in this area,which might potentially be of national importance. Planshould set out a requirement for any developmentproposal to be informed by appropriate archaeologicalevaluation. Historic England)

Add additional bullet point 'an archaeological evaluation'

Table 12.84 Key Issues: MB6 :Land at Melmerby Industrial Estate

MB8: Land west of Barker Business Park (larger site), Melmerby



Amend criteria 8 toinclude an additionalbullet to read:

A site requirement for this siterequires that a 'HeritageAssessment including impact on

Negative Impact on Designated Heritage Assets

Before allocating site there is need for evaluation of impactloss of site and future development might have uponelements which contribute to significance of the Historic "Archaeological

assessment includingimpact on the scheduledmonument at NortonConyers"

the Historic Park and Garden atNorton Conyers. this can beamended to include arequirement for anacrchaeological assessment andrefer to the ScheduledMonument.

Park and Garden at Norton Coyners and nearby ScheduledMonument. If harm would result, Plan needs to clearly setout measures by which harmmight be removed or reducedand that any proposal be informed by an appropriatearchaeological evaluation. If despite mitigation measuresstill likely to be harm, site should not be allocated unlessthere are clear public benefits to do so. (Historic England)

Undertake evaluation of impact loss of site and futuredevelopment might have upon elements which contributeto significance of the heritage assets and amend the Planaccordingly

Table 12.85 Key Issues: MB8 Land west of Barker Business Park, Melmerby



Pannal Site

PN18: Employment site south of Almsford Bridge, Pannal




Noamendment.

There is an identifiedemploymentrequirement to be

Legal compliancefailure to apply the SEA Directive

delivered during theabsence of SEA study at village level - legal requirement to consider thecumulative impacts plan period (as set

out in Chapter 3 ofthe Local Plan andinsufficient due diligence or process has been applied in allocating this sitethe EconomyBackground Paper)site was allocated at very short notice and, through theLocal Plan, there is a

Does not accord with the York, North Yorkshire and East Riding StrategicEconomic Plan (SEP), which identifies the A1(M)/A19 corridor as the focusof employment growth

need to allocate landto ensure thisrequirement is met.The council considersthat this site can

Issues with Evidence Base - Housing and Economic Development NeedsAssessment (HEDNA)

contribute to meetingthis need and the

Forecasted requirements are exaggerated due to using high-end assumptions(e.g. growth forecasts), and there has not been enough consideration of theimpact of brexit

approach taken to theidentification of thissite is based onreasonable evidence.

no justification in terms of requirement and supply; the degree ofover-allocation is excessive As set out in the

evidence base, manysites have beenrequirement for employment is uplifted twice for flexibility which is double

counting considered throughthe site selectionprocess. Sites haveinconsistencies in the employment land calculations and tablesbeen allocated thatare considered totwo third increase in the minimum requirement and one third increase in

allocations since 2016 Draft Plan offer the greatestsustainability benefitsand considerationsThe council's economic aspirations are unrealistic (inc. delivering a higher

proportion of higher end jobs) such as the scale ofdevelopment, access,and impacts onSite is not identified in HEDNA as a potential employment site whilst other

sites not allocated are identified highways landscape,ecology, heritageassets and flooding

no recognition that high earning jobs require less space per employee thantraditional manufacturing and distribution; no recognition that by 2035 morepeople will be working from home and many jobs will have been automated

were taken intoaccount during thesite assessmentprocess.

Issues with Evidence Base - Other Potential adverseimpacts ofdevelopment of the

Impact of nor having a SIP in place

Infrastructure capacity study: adequate assessment of highway impacts hasnot taken place; traffic modelling understates traffic impact; cannot find theinfrastructure capacity study

site were consideredthrough the siteassessment process.Where potential

No evidence that HBC have properly considered all alternative sites includingthe Green Belt

adverse impacts wereidentified, it isconsidered that theseare notThe plan does not deal with infrastructure- the infrastructure plan is not

available. Infrastructure policies should be developed alongside the LocalPlan

insurmountable andcould potentially be





mitigated, as set outin the SiteRequirements.

Jacobs Traffic Report (Jan 2018) identifies that work is still underway todevelop solutions to traffic problems at A61/Pannal Bank junction/ This showsthat implications have not been adequately considered

Further assessmentof these issues will be

Site is too big undertaken as part ofthe planningapplication process ifrequired at this stage.

No local need for employment landThe approved application to redevelop the former Dunlopillo employment sitefor mixed-use rather than solely employment demonstrates a lack of demandfor employment premises in Pannal It is recognised that

new development,both individual sites

Previous applications to develop the site have been refused and from thecumulative impact of

Coalescence several sites, willWill close the gap between Pannal and Harrogate, which has social andenvironmental consequences - functions more like a Green Belt in that itsopenness has its own value

place extra pressureon existinginfrastructure andmay need new or

The council purchased the land to keep Pannal and Harrogate separate improvedinfrastructure tosupport it. The

Large amount of development has already been granted in the local area council continues towork with the County

The site is outside the current development limit Council, utility andotherLocal infrastructure cannot cope infrastructure/service

Negative impact on local roads/traffic providers to makesure the infrastructureroad safety concerns on highway network and junctions - A61, A658implications of theallocated sites areincreased traffic, delays and queuing on highway network particularly at peak

time fully assessed andwhere necessarymitigation measures

local highway network would not be able to accommodate extra traffic are identified and putin place to address

significant highway mitigation schemes would be required development impacts.Funding contributionsfrom developers will

No or poor access to public transport be sought whereDespite close proximity to rail station/bus services, there is low use of thesemethods by existing residents

needed to increasecapacity to providelocal infrastructure.

The proposed upgrade of the Leeds-Harrogate-York rail line is now unlikelyto go ahead It should be noted

that the site is notwithin the Green Belt.Insufficient car parking provision at Pannal railway station



No or poor access to to shops and services


Risk of floodingno consideration has been taken of the Crimple Valley flood plain or its impacton future or current properties

Allocation would not meet the sequential test

Poor drainage





Negative impact on the landscapeAllocation would not meet requirements of draft policy NE4: LandscapeCharacter

Allocation would not meet requirements of draft policy EC3: EmploymentDevelopment in the Countryside

Allocation would not meet requirements of existing Local Plan policy C9:Special Landscape Areas

Crimple Valley is a vista of real importance to Harrogate

Development will have a negative impact on the approach to Harrogateand undermine its appeal potential tourists

The site is in a designated special landscape area (SLA)The council's recent refusal of planning permission in an SLA was upheld onappeal

The plan allocates the site for development but retains it in the SLA

Social and environmental benefits of SLAs have not been considered

Site is a greenfield site

Site is in the Green Belt

Negative impact on the local communityNegatively affect the character and amenity of the Harrogate Ringway footpath

Pannal will lose its identity as a village

Loss of amenity that the open fields currently provide

Loss of open space/sports pitches

Negative impact on local wildlife and biodiversityLoss of trees and/or hedgerows, including protected trees and/or hedgerows

Negative impact on a listed building/ssetting of the Crimple Viaduct; views to and from the viaduct


Issue with ConsultationThe council has not taken account of residents representations and/or petitions

no consultation on the relaxation of the SLA policy

OtherReasonable alternatives have not been considered. These would includeconsideration of a Green Belt review

difficult to see how any argument about the commercial attractiveness of thissite could overcome very strong environmental and traffic objections

new business units not needed as vacant units in town centre





There are more suitable sites than those in Pannal

As the landowner of the site the council stand to benefit from their decisionto allocate for development

Allocation would not accord with draft policy EC3: Employment developmentin the countryside

Negative impact on local distinctiveness

Abnormally high costs of developing the site (flood works, access, highwayimprovements etc.) make the site unviable

Potential for pollution from employment activities

Development will not attract higher paid jobs and will therefore increasein-commuting of lower paid workers

Allocation of site is not required to meet HEDNA requirements

The plan acknowledges the need for minimising greenhouse gas emissionsyet designates sites for development that will increase traffic and pollution

The plan proposes a disproportionate level of growth in Pannal

Other available sites in Pannal that are more sustainable.

Spacey Houses Farm level crossing: any replacement footbridge is likely torequire my land, which I would object to due to increased over-looking


The representations made regarding this site sought the following modifications to the Plan:Remove site from the PlanAllocate a different site/expand existing employment areas/use vacant employment areasReduce amount of employment land requiredUpdate evidence base including reviewing economic projections, undertaking traffic modelling, carrying out SEAcumulative assessment of allocations, landscape and flood risk assessmentsPrioritise brownfield sitesFocus development where infrastructure is in placeReduce site area by 30%Amend site boundary to exclude 3.2ha close to the southern edge of the site (Mercedes garage)

Site Requirements

Noamendment.

Noted. Any changeto the status of thepublic right of way

Requirement 10: The protection and enhancement of this path is important withinan employment area. This is a designated footpath and without the necessary andlegal changes should not be inadvertently changed into a cycle route.

would be required tofollow the appropriatelegislativeprocedures.

Table 12.86 Key Issues: PN18 Employment site south of Almsford Bridge, Pannal



DM3: Mixed Use Allocations

Draft Policy DM3: Mixed Use Allocations



No amendment.The assessment of this site in the HEDNAidentified that the estate has a high occupancy ratereflecting the commercial attractiveness of the site.It recommended that the site be retained inemployment use.

New York Mill, Summerbridge (site SB4) should beconsidered for mixed use including employment andhousing:

development would support village's servicesand facilities

development would supportrepair/maintenance of Victorian Mill buildings

should be seen in context of limiteddevelopment opportunities, principally due totopography, in Pateley Bridge

No amendmentThis area of land is located within Green Belt.The NPPF is clear that Green Belt boundariesshould only be altered in exceptional circumstances

Land to south of Pannal should be allocated forhousing, employment and necessary supportinginfrastructure:

and where it can be demonstrated that allno landscape designation and makes lesssignificant contribution to setting of Pannalthen proposed allocations

reasonable options have been fully examined. TheGreen Belt Background Paper 2018 sets out thereasons why the council had concluded that it doesnot need to undertake a Green Belt review in orderto meet the plan requirements in a way thatrepresents sustainable development.

sites perform, on the whole, better againstSustainability Appraisal criteria, then proposedallocations

significant exceptional circumstances to justifyallocation of Green Belt land

Amendment -AddK31:ManseFarm,Knaresboroughto Table 10.90

Agree, K31 : Manse Farm, Knaresborough shouldbe included in table 10.90

Manse Farm is identified as 'Committed Mixed Use'on the Knaresborough Policies Map but as this isnot reflected within Policy DM3 there is lack ofconsistency.

No amendmentThe council has allocated sufficient deliverableand developable housing and mixed use sites tomeet the housing requirement and an additional

Land at Ripon Bypass (site R16) should be allocated:Main settlements capable of delivering morehousing than plan preparing for

buffer to provide flexibility over the plan period and,as such, does not consider the allocation of thisAccessible locationsite, which does not compare as favourably to othersites assessed and identified as allocations, isneeded.

Strong potential to provide roadside services,a cottage hospital, nursing home/assistedliving and the possibility of a new school




Harrogate Sites

H37: Land at Station Parade, Harrogate



Noamendment.

Noted.Support

Noamendment.

There is an identified employment and housingrequirement to be delivered during the planperiod (as set out in Chapters 3 and 10 of the


Local Plan and the Housing and EconomyBackground Papers) and, through the Local Plan,there is a need to allocate land to ensure thisrequirement is met. The council considers thatthis site can contribute to meeting this need andthe approach taken to the identification of thissite is based on reasonable evidence.

Site Requirements

N/AFollowing discussion Historic England havewithdrawn these objections.

Requirement 2 - as worded implies that it isacceptable, in principle, to harm the conservationarea. (Historic England).


Requirement 3 - as worded implies that it is acceptable,in principle, to harm listed buildings. (Historic England).

Amend to read: '.. development of the site shouldconserve those elements which contribute to thesignificance of these designated heritage assets, andshould seek opportunities to enhance...' (HistoricEngland)

Table 12.88 Key Issues: H37 Land at Station Parade, Harrogate

H51: Land east of Lady Lane, Harrogate



N/ANotedSupport allocation.


No amendment.There is an identifiedhousing and employmentrequirement to be


Issue with consultationdelivered during the plan

A large amount of development has already been granted in the localarea

period (as set out inChapters 10 and 3 of theLocal Plan and theThe site is outside the current development limit Housing and Economy

Local infrastructure cannot cope Background Papers) and,through the Local Plan,

Negative impact on local roads/ traffic there is a need to allocateland to ensure this

No or poor access to public transport requirement is met. The





council considers that thissite can contribute tomeeting this need and the


Negative impact on the landscapeIndependently commissioned landscape Impact Assessmentsubmitted which indicates that the allocations would give rise to‘unacceptable’ adverse effects on the character and quality of

approach taken to theidentification of this site isbased on reasonableevidence.the Crimple Valley, properties along Lady Lane/ Whinney Lane

and the Special Landscape Area to the south and west ofHarrogate. As set out in the evidence

base, many sites havebeen considered throughAdverse landscape and visual effects on wider landscape could

be significantly reduced by amending site boundary. the site selection process.Sites have been allocatedthat are considered to offer

The site is in SLA the greatest sustainabilitybenefits and

Loss of public open space considerations such as thescale of development,

Impact on local community access, and impacts onhighways landscape,Negative impact on a listed building ecology, heritage assets

Impact on Designated Heritage Assets and flooding were takeninto account during the siteassessment process.Western half of site makes considerable contribution to setting of

designated and non-designated heritage assets and development likelyto harm elements which contribute to their significance. (HistoricEngland)

Potential adverse impactsof development of the sitewere considered throughthe site assessmentAmend allocated area to remove area that needs to remain undeveloped

to safeguard setting of designated and non-designated heritage assets process. Where potentialadverse impacts wereidentified, it is considered

Cumulative effects that these are notinsurmountable and couldWhen taken together with the committed developments at Crag

Lane and Bluecoat and the other local draft policy sites H46, H51,H49 and H36, this will result in an urban sprawl the size of a new

potentially be mitigated, asset out in the SiteRequirements. Furthersettlement but without the planning which would be required to

create the facilities and transport infrastructure needed for a viablecommunity

assessment of theseissues will be undertakenas part of the planningapplication process ifrequired at this stage.Other

no assessment of the impact on villages surrounding HarrogateIt is recognised that newdevelopment, bothindividual sites and fromA Strategic Environmental Assessment should have been

undertaken to examine the cumulative impact of multiple sites ina single area the cumulative impact of

several sites, will placeextra pressure on existinginfrastructure and mayAmend boundary of allocation so as to avoid development of the

prominent south facing slopes, maintain the rural setting of thefarmsteads and vernacular stone cottages on Lady Lane and thesouthern part of Whinney Lane.

need new or improvedinfrastructure to support it.The council continues towork with the County

The council need to produce an holistic development plan for the westof Harrogate

Council, utility and otherinfrastructure/serviceproviders to make sure theinfrastructure implicationsof the allocated sites arefully assessed and wherenecessary mitigationmeasures are identifiedand put in place to addressdevelopment impacts.Funding contributions from





developers will be soughtwhere needed to increasecapacity to provide localinfrastructure.

Masterplanning and siterequirements for this siteseek to address the needto minimise harm and toenhance the significanceof the designated andnon-designated heritageassets on the site. Thenature of any final schemewill help to determine theextent that any part of thesite should remain open toprotect assets.

The SustainabilityAppraisal has beenupdated to include astrengthened assessmentof cumulative impacts.

The Harrogate DistrictLocal Plan SubmissionDraft August 2018 ,Sustainability AppraisalVol.1/Vol.2 updatedfollowing Publication DraftConsultation will beincluded in theExamination Library

Site Requirements

No amendmentThe wording of this siterequirement is consistentwith all other allocationsand is consideredappropriate

Requirement 8 – given some loss of trees may be unavoidable, shouldprovide some flexibility.

Amend to add: ‘where loss of trees or hedgerows is unavoidable,replacement planting of native species should be provided’.

AmendRequirement10 to read "providevehicle, cycle and

Agree that access shouldbe available fromWhinneyLane.

Requirement 10 – question logic of singling out Lady Lane for vehicularaccess given more rural in character that Whinney Lane or BeckwithHead Road and which development masterplan proposes as mainaccess points. pedestrian access

from Lady Laneand/or WhinneyLane"

Amend to say that the main vehicular access for housing should befrom Whinney Lane and the main vehicular access for employmentshould be from Beckwith Head Road.

AmendRequirement 12 toread "The design

It is agreed that theamendment should bemade.

Requirement 12 – on other sites requirements regarding footpaths usephrase ‘enhance and protect’, which is equally applicable in this case(NY LAF)

and layout of thesite shouldprotect andenhance therecreational .......".

Table 12.89 Key Issues: H51 Land east of Lady Lane, Harrogate



H63: Dragon Road car park, Harrogate


No amendment.There is an identified housing and employmentrequirement to be delivered during the planperiod (as set out in Chapters 10 and 3 of the


Local Plan and the Housing and EconomyBackground Papers) and, through the LocalPlan, there is a need to allocate land to ensurethis requirement is met. The council considersthat this site can contribute to meeting this needand the approach taken to the identification ofthis site is based on reasonable evidence.

Site Requirements

N/AFollowing discussion Historic England havewithdrawn this objection.

Requirement 1 - as worded implies that it isacceptable, in principle, to harm theconservation area. (Historic England).

Amend to read: '.. development of the siteshould conserve those elements whichcontribute to the significance of thisdesignated heritage asset, including itssetting.'

Add the followingsentence to the end ofSite Requirement 4

Agree that the suggested amendment shouldbe made.

Requirement 4 - Given that a significantcycle route is recognised within the siterequirements, some provision for cyclestorage should be included for use whencyclists wish to stop and visit the town (LAF).

"Cycle storage should beprovided as part of anydevelopment proposal."

Table 12.90 Key Issues: H63 Dragon Road car park, Harrogate

Knaresborough Site

K17: Former Cattle Market, Knaresborough


Amend K17 site box asfollows: 'Proposed Use:Employment Commercialand residential'

While the site is still suitable for a mix of uses, the HEDNAstates that the site is commercially unattractive for B usesand should be considered for alternative uses. In light ofthis evidence it would be appropriate to change theproposed uses to commercial and residential, with theactual mix determined at planning application stage.

Requirement for employmentuse on the site will underminethe viability of the redevelopmentof the site.

Site Requirements

No amendmentThe site specific requirement is considered appropriate inorder to reduce to an acceptable level the impact ofdevelopment.

Requirement 1 - should bedeleted

No amendmentIt is considered appropriate to highlight those technicalreports that will be required to support any planningapplication.

Requirement 5 - should bedeleted

Table 12.91 Key Issues: K17 Former Cattle Market, Knaresborough



Ripon Site

R25: Claro Barracks, Ripon



No amendmentThe Council will be working with theDIO to prepare a Statement ofCommon Grounds for this site and

Regard should be had to evidence provided by HEDNA andsubmitted Market and Viability Assessment in respect of arealistic level of employment provision on Site R25 (DefenceInfrastructure Organisation (DIO)). the amount of housing and

employment land will form part ofthis.Transport Assessment undertaken demonstrates that a

reduction in employment development at Site R25 woulddramatically reduce peak hour movements through the CityCentre when compared to the existing allocation and wouldcontribute to meeting the aim of Draft Policy TI1 as outlinedin Paragraph 6.4, point 3.

Reduce the employment allocation to 2 hectares

No amendment.The provision of an appropriatelevel of sport and recreation facilitieswill be determined having regard to

Other:Master plan for R24, R25 and R27 should be includedin Local Plan.

Policies HP6 and HP7 and themasterplan for sites R24, R25 andR27.

Mixed use allocation does not take into accountshortfall in sports facilities for Ripon and existing sportsfacilities (both grounds and buildings) should beallocated as sport and recreation facilities (RiponSports Village)

Site Requirements

Amend Requirement8 to read "The designand layout of the site

Agree the site requirement shouldbe amended

Requirement 8 - This statement is inconsistent with othersite requirements, which require the design to "enhance andprotect" the rights of way (NY LAF)

should protect andenhance therecreational .......".

Amend site requirement 8 to require the design to "enhanceand protect" the rights of way

Table 12.92 Key Issues: R25 Claro Barracks, Ripon

DM4: Green Hammerton/Cattal Broad Location for Growth

Policy DM4: Green Hammerton/Cattal Broad Location for Growth


HBCResponse

Key Issue

No amendment.NotedResponses which support policy DM4 include the following reasons:There is demand for housing in the area.

New housing will benefit from existing rail transport.

Good access to Harrogate, York, Boroughbridge and Wetherby.

Detailed selection process with a sound rationale now clearly explained in thesupporting reports.




HBCResponse

Key Issue

Site will cause less congestion than alternatives to the west of the A1(M).

Green Hammerton offers the benefits of a community infrastructure and a senseof place.

No amendment.NotedWelcome decision to locate new settlement in Green Hammerton/Cattal area butregrettable Council has decided not to confirm boundaries previously proposed. Believesoundness of Plan would be reinforced by defining new settlement boundary now soeffectively defined when Local Plan is adopted.

No amendment.NotedAt present do not feel sufficient secondary aged pupils generated to make an all-throughschool in new settlement viable and would be helpful to enable growth of provision atexisting Boroughbridge High School. However, as trajectory indicates development willnot commence withing first five years of the Plan, will continue to monitor education needsand keep delivery in area under review (NYCC).

No amendment.NotedPolicy DM4 is fully supported in principle and detail except Local Plan should be clear asto the location and scale of this development by the identification of the allocation siteboundary as part of the policy. This approach would be consistent with paragraph 154 ofthe NPPF, which requires Local Plan policies to provide clear policies on what will or willnot be permitted and where. Council already has the necessary evidence base to identifythe site boundary and has previously identified one. The proposal for a defined siteboundary (along with details of phasing and land uses) to be established through a DPDis unnecessary and adds further complexity, uncertainty and delay to the process.

Table 12.93 Support for DM4



No amendment.The councilconsiders that a newsettlement has a role

The Publication Draft Local Plan is not legally compliantNot based on sound evidence.

to play in contributingThe preferred location is not the most appropriate strategy when consideredagainst other reasonable alternatives. to meeting the

identified residualhousing requirementDM4 lacks sufficient detail.to be delivered duringthe plan period and

The Publication Draft Local Plan does not meet the tests of soundness the approach taken toidentifying the broadFails to demonstrate how the site would meet the need for housing and

other development. location for growth isbased on reasonableevidence (including

Not based on sound evidence. the New SettlementBackground Paper

The preferred location is not the most appropriate strategy when consideredagainst other reasonable alternatives.

(November 2017) andthe SustainabilityAppraisal). However,

Concentrates housing in one area and therefore does not respond tohousing need across the whole District.

delivering the housingrequirement does notrely solely on a new

Deferring case for new settlement and selection of location to daughterDPD is unsound approach

settlement: 88% ofthe housing to bedelivered over theplan period are fromother sites identifiedin the Local Plan.

Land ownership issuesSite is in multiple ownership/ promoters do not control all the land

It is acknowledgedthat the considerationbetween alternative

New Farm is subject to 30 year covenant

Coalescence sites is finelybalanced and there





are few significantdifferences in theopportunities and

Merge Green Hammerton, Kirk Hammerton, Whixley and Cattal.

Contravenes Garden Village philosophy the settlement should beself-sustaining and independent constraints for each

site and theperformance of the

Local infrastructure cannot cope. sites when assessedagainst several of theNo mains gas.sustainabilityobjectives (as set outElectricity supply needs updating.in the SustainabilityAppraisal). However,Schools and doctors surgeries cannot cope. the GreenHammerton/Cattalarea provides forNegative impact on local roads/ traffic.significant long termA59 already overburdened. positive effects inrelation to the

Whixley junction on A59 already congested. sustainabilityobjectives transport(10), climate change

Poor access to public transport (11) and local needsLimited rail service. met locally (9) where

there is direct andLimited parking at stations. convenient access to

existing publicNetwork Rail not confident improvements can be made. transport services,

which can beenhanced.

The master planningprocess, which isinforming the

Increasing rail service not possible because of restricted access at theSkelton junction.

Bus service is extremely limited.

development of theNegative impact on landscape NewSettlement DPD

and defining detailedSite is on a prominent hill visible over a large distance.boundaries, providesthe opportunity to

Loss of agricultural land address key issuessuch as greenLoss of Grade 2 best and most versatile agricultural landinfrastructureprovision,

Negative impact on the local community environmentalimpact, open space,Loss of village primary schools replaced by large single school.and sustainabletransport in acoordinated andcomprehensive way.

The new settlement will be divided by the A59.

Negative impact on local wildlife and biodiversity. The majority of thelandowners within thebroad location are

Negative impact on the conservation area.Impact on Green Hammerton CA contrary to Green HammertonConservation Area Appraisal 2009 positively engaged in

the developmentprocess through twoImpact on Coney Garth Hill main developmentpromoters and NYCC

Impact on Kirk Hammerton CA have resolved to a avariation of therestrictive covenant

Negative impact on designated heritage assets. that applies to NewSetting of Kirk Hammerton medieval church. Farm; this is not a bar

on the identificationof the broad locationfor growth.





It is recognised thatdevelopment o a newsettlement will require

Issue with consultationBroad area of search provides insufficient detail for consultation to takeplace.

new or improvedinfrastructure to

Other support it. Thecouncil continues toSite is not immediately available.work with the CountyCouncil, utility andThere is no existing or proposed employment use within the site.otherinfrastructure/serviceLoss of revenue for Harrogate as people will travel to York to shop etc.providers to makesure the infrastructure

Land is subject to Chancel Repair Liability in regards to Church ofAscension, Whixley

implications of thebringing forward anew settlement are

Unlikely to be sufficient local employment opportunities generated to meetthe needs of the residents of the new settlement

fully assessed andwhere necessarymitigation measures

Object to principle of new settlement as strategy has not been consideredagainst merits or otherwise of reviewing Green Belt to accommodatedevelopment needs

are identified and putin place to addressdevelopment impacts.Funding contributions

No evidence the settlement is deliverable will be sought whereneeded to increasecapacity to providelocal infrastructure.

Not consistent with settlement hierarchy

The Flaxby site would be betterFlaxby site is owned outright and controlled by single promoter

Flaxby site s available.

Flaxby site is unused and semi-derelict and needs a new future.

Flaxby site is only short distance from the A1M.

Flaxby site has recently had a new roundabout built.

Congestion on A59 could be rectified by adding second lane betweenFlaxby roundabout and junction 47.

Flaxby Park have acquired option on Goldsborough platform and stationhouse.

Flaxby Park are proposing a 300 space Park and Ride.

Flaxby site has business park nearby

The Flaxby site already has gas, electric, water, telecoms and drainage.

Flaxby site will have less impact on landscape as the golf course sits in alow lying bowl.

The Flaxby site is well placed to serve Harrogate and Knaresborough.

Flaxby site has potential for cheaper energy from nearby incinerator.

Flaxby site will have less impact on conservation areas and importantheritage assets.

Flaxby site is better placed to mitigate impact on wildlife.





In agreement with comments made by Keep Green Hammerton Green andKeep Kirk Hammerton Green Action Groups

Process under which the location of the proposed settlement was selectedwas flawed and poorly evidenced.

Consultation has been poor with a lack of clarity over boundaries and siteselection.

Concern over Sustainability Appraisal process owing to a lack of a definedboundary.

The emphasis on the railway corridor is overstated. There is a lack ofevidence over whether improvements are possible and deliverable.

No analysis of costs relating to potential Highways Improvement works.

There is no evidence relating to providing employment opportunities.

Lack of a provision of a secondary school.

Loss of agricultural land.

Three distinct Conservation Areas (Green Hammerton, Kirk Hammertonand Whixley) will be harmed.

Other alternative strategies for meeting the required level of housing havenot been fully explored.

Evidence relating to the likely contributions from this option rather thanFlaxby is flawed due to the use of inappropriately low house valuations inFlaxby.

Site would only be partially deliverable within the Plan period and querywhether the affordable housing requirements would be viable.


The representations made regarding the broad location for growth sought the following modifications to the Plan:Remove site from the Plan

Define a precise boundary for the Green Hammerton/Cattal growth area

Update evidence base including:

Provide finer detail on housing stock, infrastructure provision and timing, health services and timing, school provisionand timing and housing mix requirements.

A simpler traffic modelling report which can be read by non-experts needs to be produced.

HBC should revisit the new settlement approach and apply a more robust, evidence based, transparent and quantitativeapproach to deciding the correct, most sustainable site.

Need to specify and assess the viability of improvements to the rail network before the plan is approved.




13 Sustainability Appraisal Publication Draft 2018 Key Issues



Noamendment.

The SA includes a standardised assessment rationalefor appraising sites for housing and employment against16 sustainability objectives. Objective 7 provides a scorerelated to capacity of the nearest primary school andidentifies where expansion is required.

3 Establishing a baseline para 3.25 The issuein regards to school capacity is not addressed inthe plan.

Noamendment.

None of the sites to the west of Harrogate have a redscore in relation to objective 10.This score has beenprovided by North Yorkshire County Council as the local

4 Appraisal of the draft Local Plan objectivesagainst SA para 4.11 The local plan does notmeet objective 10: 24% of the total plan provisionis proposed on the western fringe of Harrogatewith the poorest access to public transport.

highway authority. Traffic modelling work has looked atthe cumulative impacts of site allocations and mitigationmeasures have been identified to address transportand/or accessibility problems.

N/ANoted.7 Support for the Assessment of sites inBurton Leonard (Burton Leonard Parish Council(with signed support from 143 villagers)).

Amend SiteRequirement6 to add:

The SA assessment for each draft allocation identifiesKeymitigation requirements which have informed genericand site specific development requirements included for

7 Assessment of Draft Allocations: M8, M13,P1, P5, P7, P10, BW9, BW10, DB5, DR1, Dr14,KM4, KM5, SB1, SB5. (Natural England) This site

Landscapeeach draft allocation in chapter 10.0. In recognition ofmay have significant impacts on the Nidderdaleand VisualImpactAssessment.

the importance of the Nidderdale AONB , for sites M8,M13 ,P1 ,P5 ,P10, DB5, DR14 ,KM4 ,KM5, SB1 ,SB5there is a site requirement for a Landscape and Visual

AONB. We advise that the analysis shouldspecifically reference the AONB in order to clarifythe appropriate weighting given to the

Impact Assessment when a planning application isAONB. Considering the national importance ofsubmitted. For sites P7, BW9 and B10 a Landscapethe Nidderdale AONBwe consider that landscape

should be considered a keymitigation requirementfor this site.

Appraisal is required when a planning application issubmitted. Site requirements for DR1 have beenamended to add the need for a Landscape and visualimpact assessment when a planning application issubmitted.

AONB designation does not preclude development, butall proposals for development within or adjacent to theAONB will be expected to conserve and enhance itsspecial qualities in accordance with NPPF. Local PlanPolicy GS8: Nidderdale Area of Outstanding NaturalBeauty seeks to do this alongside other policies in theplan.

Noamendment.

Site requirements for sites with planning permission arenot included in the plan. However in relation to K21 thisis referenced as a related site to K23: Land north of Bar

7 Assessment of Draft Allocations (NaturalEngland) We note that allocations, such as DB3and K21, already have planning permission and

lane and east of Boroughbridge Road, K32: Land atare therefore excluded from the assessment. WeBoroughbridge Road and K37: Land at Boroughbridgeadvise that assessment should be provided forRoad. A site requirement for K23 requires considerationthese sites in order to inform planning decision

making should further permissions be sought onthese sites.

of the creation of a network of connected greeninfrastructure capable of providing mitigation againstincreased recreational disturbance on the nearby Haya Park Site of Special Scientific Interest (SSSI).

Noamendment.

Site Requirements for draft allocations K23 and K24require a Hay-a park SSSI impact assessment reportwhen a planning application is submitted. Also seecomments above.

7 Assessment of Draft Allocations table 7.25(Natural England) notes allocations K37, K32,K21, K22, K23, K24, K31, EC1g and K25 lie inclose proximity to Hay-a-Park Site of SpecialScientific Interest (SSSI). Natural England isconcerned about the potential for damage to the


Sustainability Appraisal Publication Draft 2018 Key Issues 13



The Council has updated the Sustainability Appraisal toaddress issues raised at the Publication DraftConsultation. The updated Sustainability Appraisal

notified features of the SSSI as a result ofincreased recreational disturbance and, in thecase of K24, direct hydrological and urban edge

includes a more detailed assessment of growthstrategies and the process involved, and hasstrengthened the assessment of cumulative effects.

effects. We broadly welcome the assessment,particularly the recognition of combined effectsand the need for joined up mitigation forrecreational disturbance. However we considerthat the analysis is clearer about the level of threat The Harrogate District Local Plan Submission Draft

August 2018 , Sustainability Appraisal Vol.1 and Vol.2updated following Publication Draft Consultation will beincluded in the Examination Library

to the SSSI posed by these proposals, we notefor instance that the analysis for K24 does notmention Hay-a-Park, and that the assessment ofalternatives and the wider sustainability imperativefor developing these sites in such close proximityto Hay-a-Park SSSI is clearly set out in the report.

Noamendment.

SA Objective 7: The assessment was made on currentcapacity and is therefore correct. However as part offuture development requirements the InfrastructureDevelopment Plan identifies a requirement for a newprimary school.

Table 7.67 Site KH11:SA Category 7: This score should bedowngraded as NYCC representationsshow that there will not be capacity in thelocal school.

SA Objective 9: The score for air quality is based onprofessional judgement provided by the Council'sEnvironmental Protection team. In Harrogate Districttransport related emissions are the largest source ofpoor air quality.

SA Category 9: It is likely that anydevelopment on this site will utilize oil firedheating and therefore the air quality scoremust be reduced for this site.

SA Category 10: There is no evidence tosuggest that a site of this size would presentany opportunity to enhance rail services. It

SA Objective 10: the site lies adjacent to the railway lineand station so it is not unreasonable to suggest that thesite offers the opportunity to enhance existing railservices. For example this could include enhancementsto station information or facilities.

is reasonable to assume that there will bea substantial increase in car ownership anduse if this site is developed for housing.

SA Objective 11: the score relates to distance to a busstop.

SA Category 11: There is a bus stop within400m with a 2 hourly daytime servicebetween York and Ripon. This is not agood quality bus service and as such shouldnot be assigned the highest score in theSA.

Noamendment.

The Harrogate District Transport Model has beendeveloped in accordance with wetag: the government'srecommended standards. The use this type of model

10 Cumulative impact of Local Plan para10.2 The impact on the highway network reliesupon the traffic modelling update. This trafficmodelling work is unacceptable as: was agreed with NYCC as the local highway authority.

Issues relating to residential streets and VCR will befurther considered at the planning application stage.Alternative growth strategies have been tested throughthe SA. The SA has been updated to include astrengthened assessment of growth options.The

the model constrains flows to 100% VCRand flows above that are assigned throughresidential streets

100% VCR is unacceptably high andinconsistent with NPPF Harrogate District Local Plan Submission Draft August

2018 , Sustainability Appraisal Vol.1/Vol.2 updatedfollowing Publication Draft Consultation will be includedin the Examination Library

no alternative scenarios have been testedand no consideration of uncertainty acrossrange of model parameters.

The model parameters used are considered to besuitable for assessment as part of the local plan.

Table 13.1 Key Issues : Sustainability Appraisal


13Sustainability Appraisal Publication Draft 2018 Key Issues

14 Habitat Regulations Assessment Publication Draft 2018 KeyIssues


No amendment.The sites listed within this section areonly those which have been designatedor given provisional designation as

European Sites para. 2.7 Hell Wath NatureReserve should be named and protected as part ofthe landscape area and walks linked to the majortourist and visitor destination Fountains Abbey andthe Deer Park.

Special Area of Conservation (ECHabitatDirective), Special Protection Area (ECBirds Directive) or under the RamsarConvention.

No amendment.Noted. A new iteration of the HRA(Submission draft August 2018) willinclude amendments to the conservationobjectives in line with NE website.

European sites Natural England recommend thatthe conservation objectives for European sites areset out in line with published conservation objectiveforms on NE website.

No amendment.Noted. A new iteration of the HRA (HRASubmission draft August 2018) willinclude amendments to the conservationobjectives for Humber Estuary SPA andSouth Pennine Moors SPA.

European sites Objectives for Humber EstuarySPA does not distinguish between breeding andnon-breeding birds. Advise that the South PennineMoors Phase 2 SPA and Peak District Moors (SouthPennine Moors Phase 1) SPA are distinguished(Natural England)

No amendment.Noted. A new iteration of the HRA (HRASubmission draft August 2018) willinclude amendments to the features ofinterest for South Pennine Moors SPA.

European sites -South PennineMoors SPA para2.46 Natural England advise that the review whichincluded short-eared owl has no legal status andtherefore is not an SPA species in its own right,however does form one of the assemblage species.

No amendment.Noted. A new iteration of the HRA (HRASubmission draft August 2018)will include more details on feedbackfrom Yorkshire Water.

Screening Process para 4.7 Natural Englandnotes para 4.7 which states that Feedback fromYorkshire Water has suggested that potentialproblems cannot be identified at this stage. NaturalEngland has no further data to suggest potentialproblems and are satisfied provided that HarrogateDistrict Council, as the competent authority,considers that sufficient evidence is available toensure the plan will not impact on Europeandesignated sites through the waste water treatmentnetwork or water extraction.

No amendment.Traffic modelling data has been sharedwith Craven District Council and sent toLeeds City Council. Work to understand

Screening of Growth Strategy table 5.3 NaturalEngland advise detailed findings of traffic modellingare made available to neighbouring local authorities

the impact of the draft Local Plan on airin order to aid their assessment. Ensure contributionquality is ongoing and dispersionof neighbouring plans and any relevant projectsmodelling work will be undertaken. Thisshould be carefully considered. Advise that shouldwork will not be completed beforethe total combined increase breach the significancesubmission of the Local Plan but theresults from this work will inform theexamination of the Local Plan.

thresholds than Appropriate Assessment will benecessary irrelevant of the small scale ofcontribution for the Plan.

No amendment.Each allocated site has been assessedfor their potential impact on nearbywatercourses and whether mitigation will

Screening of Draft Development Policies para.6.25Disagree with this paragraph as each site mustbe different and fully investigated.

be appropriate or effective. Draft PolicyCC1 will ensure windfall sites areassessed at the point of application.


Habitat Regulations Assessment Publication Draft 2018 Key Issues 14


Add the following siterequirement to allocatedsites within 2.5km of aSPA:

The assessment shows that the use ofthese sites by birds breeding within theSPA is unlikely. However, agree thatfurther surveys at project stage would bebeneficial to ensure mitigationmeasures can be secured if necessary.

Screening of Draft Allocations para 7.3 NaturalEngland advise you consider whether bird surveysare necessary at project stage to ensure mitigationmeasures can be secured. If so, these should beincluded in site requirements.

Provide appropriateevidence, to be agreedwith the Council, toascertain the use of thesite by qualifying speciesfrom the North PennineMoors SPA or SouthPennine Moors SPA andif necessary provideinformation to inform anAppropriate Assessmentidentifying suitablemitigation.

Add the followingwording to thejustification text for policy

Agree that site requirements which aremitigation for an impact on the NorthPennine Moors SAC should be framedas such within the draft Local Plan.

Screening of Draft Allocations para 7.5 -7.16 Natural England advise that it is madeclear that the site requirements for the allocationsidentified in paras 7.5 to 7.16 of the HRA are NE3 and to the sitenecessary in order to mitigate for the impact of theproposal on European designated habitats and

requirements for allallocated sites within 7kmof the North PennineMoors SAC/SPA:

furthermore that appropriate types of recreationalgreen space for mitigating for recreational pressuresshould be prioritised. For example circular dogwalking routes with dog waste bins. For more Where open space is

provided on site priorityshould be given, where

information we advise you consider the approachestaken for the Thames Basin Heaths SpecialProtection Area (SPA) in Bracknell Forest Counciland for Cannock Chase Special Area ofConservation (SAC) in Litchfield District Council.

appropriate, to types ofrecreational green spacewhich will mitigaterecreational pressure onEuropean designatedhabitats (for examplecircular dog walkingroutes with dog wastebins).

No amendment.The wording was one of four standardconclusions which the Senior LandDrainage Engineer could select to

Appendix 2 Draft Allocations Ripon table 2.3Disagree with comment re: effects of additionalsurface water discharge as any flow will not beadditional as no water currently flows into nearbywatercourses.

conclude his assessment and reflects theassessed level of impact rather than thedetails of the site.

Table 14.1 Key Issues : Habitat Regulations Assessment


14Habitat Regulations Assessment Publication Draft 2018 Key Issues

15 Equality Analysis Publication Draft 2018 key issues



Noamendment

See Response toPolicy HS10

Policy HP5 Para 2b the 'elimination of unlawful discrimination, harassment andvictimisation' and 'fostering good relation between different groups' are excludedas necessary considerations. This is a criterion which, by its failures and inaction,HBC has allowed to become an issue and should be addressed. The followingwording should be added:

The Local Plan will ensure:

1. Clear access to the ancient and public right of way along Cass lane,Knaresborough

2. Ensure that residents along the lane are aware of those rights and do notbehave, or allow others to behave, in ways which prevent access or its use

3. Enforce, or ensure the enforcement of,the prevention of unauthorisedcommercial use of sites along the lane

4. Ensure the right of way is actively protected, safeguarded and maintainedfor current and future generations by regularly assessing and ensuring noloss of facility is tolerated.

5. Ensure the right of way is developed to regain the use lost

Noamendment

See Response toPolicy HS10

The following issues have been raised with regard to the allocation of the Gypsyand Traveller sites

Development proposed in the plan has not been distributed across the districtwith regard to Gypsy and Traveller Sites with 83.3% of the whole District'sGypsy and Traveller sites are located in Knaresborough and all within anarea of 2.77 sq miles

The Draft Plan proposes to increase the number of pitches by150%. Concentration of sites could be regarded as ghettoising Gypsies andTravellers

No regard has been extended to the local settled population

As a result of planning and enforcement deficits there has developed a trendfor unplanned, ad-hoc growth

The proposal to grant these sites permanent planning permission, followingtheir failure to deliver sites and to enforce planning law in the past, is an easyroute for HBC to take to fulfil its responsibilities.

Unplanned development has resulted in a range of consequences and asituation in which HBC are failing three populations : both our settled andtravelling gypsy and traveller populations as well as the local settledpopulation.

Noamendment

The plan has beensubject to variouspublic consultationsand changes havebeen made to the planat each stage.

The plans fails to reflect the views and aspirations of the local community as outlinedin Para 1.7. The views of developers and those with a financial interest are listenedto.

Table 15.1 Key Issues : Equality Analysis


Equality Analysis Publication Draft 2018 key issues 15

Appendix 1 Housing Trajectory


N/AN/ANone Identified

Table 1.1 Key Issues : Housing Trajectory


1Housing Trajectory

Appendix 2 Strategic Infrastructure Delivery



N/AThe Draft Infrastructure Delivery Plan (Jan2018) was available to view on theconsultation portal and the council website

The Plan was not available on the Council’s website(date 6 February 2018) and consultees were not givenany opportunity to comment on the Study. This is poorplanning and contrary to advice on the preparation of aLocal Plan.

along with all other Publication Draft LocalPlan supporting evidence base documentsfrom the start of the consultation.

Many of the proposed sites, particularly rural settlementssuch as Hampsthwaite require new infrastructure if thereis to be disproportionate housing growth. If the councilhas not completed an Infrastructure Delivery Plan howcan it make decisions on whether a site allocation ormultiple sites in Hampsthwaite is appropriate?

The Infrastructure Delivery Plan should inform the LocalPlan and not be an add-on at the end of the process andHAG concludes the Publication Draft Local Plan is notsound.

(Hampsthwaite Action Group (HAG) with signed support from392 members of the local community).

Noamendment

The specific infrastructure requirementsfor individual sites or combinations of sitesare detailed in the Draft InfrastructureDelivery Plan.

Following questions unanswered in regard to Hampswaite:

What Infrastructure is required in Hampsthwaite to dealwith the cumulative impact of HM7, HM9 and the largecommitted site which was formerly HM1?

The SA has been updated to include astrengthened assessment of cumulativeimpacts.The Harrogate District Local Plan

More specifically, what considerations were maderegarding the need for improved public transport, sportand recreation, drainage and sewers, primary schooland shops provision in Hampsthwaite to support a 60%increase in housing?

Submission Draft August 2018 ,Sustainability Appraisal Vol.1/Vol.2updated following Publication DraftConsultation will be included in theExamination Library

(Hampsthwaite Action Group (HAG) with signed support from392 members of the local community).

Table 2.1 Key Issues : Strategic Infrastructure Delivery


Strategic Infrastructure Delivery 2

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