City of York Local Plan SS9 (ST7):Parish Council Replies
City of York Local Plan SS9 (ST7):Parish Council Replies
We have submitted two sets of replies to the City of York Council concerning Policy SS9 in their proposed Local Plan. The first was written in 2018 on the publication of the Local Plan, prior to submission to the Secretary of State for Communities and Local Government in May 2018. The second was sent in July2021 following publication by the CYC of a series of modifications to meet the comments made by the inspectors and prepared following the Phase 1 hearing sessions in December 2019. The third was sent to the inspectors for their July 2022 examination.Policy SS9: Land east of Metcalfe Lane (ST7)
Although this area is not in Murton Parish, its development will affect it. We will restrict ourselves to three specific aspects:
- the environmental impact on the City
- the environmental impact on our Parish
- the impact on the Parish and neighbouring parishes by the increased traffic
Policy SS2: The Role of York’s Green Belt states that
‘The Green Belt’s prime purpose is that of preserving the setting and special character of York’.
Murton Parish Council welcomes this statement and we have considered Policy SS9 against this and Policy SS1.
- The environmental impact on the City.
Historic England points out that
‘The allocation of this area will harm a number of key elements identified in the Heritage Topic Paper Update as contributing to the special character and setting of York. The development of this area would reduce the gap between the A64 and the edge of the built-up area, in effect creating a new freestanding settlement within the ring road under 160 metres from edge of the existing built-up area. The Heritage Topic Paper Update identifies the relationship which York has to its surrounding settlements as being one of the elements which contribute to its special character and setting. A new settlement this close to the City would appear out of keeping with the current pattern of development around York and harm this element of York’s character. The impact of the development of this site upon SA Objective 14 should be amended to “serious harm”
The response notes that
‘The appraisal notes that mitigation in form of master planning is required.’
which is hardly reassuring.
We see little evidence that these statements will actually affect the development of the site. Rather we see them as wishful thinking to convince the Inspector that CYC has reacted properly.
- The environmental impact on Murton Parish
Murton Parish Council is also concerned about the impact on Murton itself. As Historic England points out
the development site would substantially reduce the gap between the edge of the built up area and the ring road. It would adversely affect views towards the City and its rural setting. Further reducing the gap between the edge of the city from Murton and erode the rural setting. It should be assessed as (--) as it would harm an element which contributes to special character and setting of York.
The CYC simply says that
Noted. The assessment of the proposed East of Metcalfe Lane allocation has concluded a minor/significant negative effect against Objectives 14 and 15 as informed by the HIA and discussions with CYC Officers.
In section 6.7, the Appraisal report says
Although the distances between Murton and York will be decreased by development on this site, the proposed boundaries are such that a reasonable gap between the ring road, Murton and York’s urban area will remain.
However, English Heritage/Historic England, in an Annex in the Pre Publication Local Plan stated:
6.7 Relationship of the historic city of York to the surrounding villages.
Impact (a) The development of this area would reduce the gap between the existing edge of the built-up area of the City from 1.6 km to 720 meters, which is quite a marked reduction - i.e. it could not be described as leaving a “reasonable gap” between Murton and the new eastern edge of the City.
Mitigation (a) In order to retain the relationship of the main built-up area of York with Murton, a substantial area of open countryside should be retained between any new housing and the village.
In reply, CYC writes that to
maintain that the development is located some distance from Murton and that the impact of development on this character element is minor as Murton and York will be separated by a strip of fields and the ring road (ref 3).
The site has scored a mix of minor and significant negative effects for this Objective 14 subject to the implementation of mitigation (ref 4).
Since then, there have been several changes to the plans. Nevertheless the separation between ST7 and the village remains at ca 750 metres, which English Heritage/Historic England does not regard, as we agree, as a ‘reasonable gap’.
The Parish Council therefore asked CYC to take more account of these criticisms of the present boundaries to ST7 and that they should be redrawn to avoid any unfortunate impact on views to the City and to ensure that the gap between ST7 and the village is increased significantly. Our request was studiously ignored and the number of houses on the site was increased.
- the impact on the Parish and neighbouring parishes by the increased traffic from ST7.
We write this with our recent questionnaire for the Murton Parish Neighbourhood Plan in mind. This was a detailed document to which 83% of households responded, of which 95% were concerned about the traffic through the Parish.
With ca 900 dwellings planned for ST 7, we expect there to be over 1500 more cars in the area. We note too that ‘vehicular access is planned from Stockton Lane to the north of the site and/or Murton Way to the south of the site with a small proportion of public transport potentially served off Bad Bargain Lane. Access between Stockton Lane and Murton Way will be limited to public transport and walking/cycling links only’.
We are conscious that there are statements that ‘high quality, frequent and accessible public transport services through the whole site will be sought enabling upwards of 15% trips to be undertaken using public transport’. It is the other 85% that concerns us. Although the impact on Murton will be secondary to the impact on neighbouring parishes, it will increase, providing further and severe strain on the village roads in the Parish, principally Murton Way and Murton Lane. This is of particular concern to us. In a Planning Inspectorate report in 2016, in which traffic was of major concern, the Inspector’s report is scathing about the figures for traffic in our area produced by the City of York. One example concerns Murton Way. He writes ‘Can the parties confirm the information given to the hearing that the traffic flows along Murton Way have not increased materially since 2003?’
Two years on and we do not have the answer and yet the Local Plan proposes a significant increase by allowing many dwellings access to Murton Way. Indeed, it is not even possible to comment further in any meaningful way as the precise access points are not indicated as the Plan simply says that they ‘will need to be assessed in more detail’. We also note the words of caution such as ‘Travel planning measures may reduce the motor vehicle trip generation but adequate transport links will need to be in place to make such measures effective’. Our village has 3 buses a day into York, none on Sundays so we await these plans with interest!
Again no account was taken of concern, simply an increase in the number of dwellings. So much for localism!
- Conclusion
We are conscious that there is a tension between SS1 and SS2 and that the CYC in interpreting SS7 has tried to balance the two. In doing so, it has to be mindful that the area for SS7 is large enough to ensure that the Garden village will attract funding to make the necessary infrastructure viable. However, we do not feel that the Plan has given nearly enough credit to the criticisms levelled by English Heritage/Historic England or by our Parish Council.
We urge CYC to proceed with further work on the feasibility of ST7, particularly on the two points we identify, before any final decision was made. We can see little evidence that our concerns have been considered.
Part 2 Comments sent to CYC in 2021
City of York Local Plan Proposed modifications and Evidence Base Consultation (May 2021)
Subsequent to the submissions reproduced above, the emerging Local Plan has been modified by the City of York Council to answer comments made by the independent Examiners. We noted that our comments on Policy SS9 Land East of Metcalfe Lane (ST7) were not answered and we have made a further submission. This is reproduced below:
ST7: Consequences of enhanced traffic on Murton Parish
Among the planning policies in the NPPF[1] which most concern Murton Parish are those relating to transport that:
• support ‘an appropriate mix of uses across an area, and within larger scale sites, to minimize the number and length of journeys needed for employment ; • ensure that there is ‘active involvement of local highways authorities, other transport infrastructure providers and operators and neighbouring councils, so that strategies and investments for supporting sustainable transport and development patterns are aligned’;
• ‘identify and protect, where there is robust evidence, sites and routes which could be critical in developing infrastructure to widen transport choice and realise opportunities for large scale development’;
• ‘provide for high quality walking and cycling networks and supporting facilities such as cycle parking (drawing on Local Cycling and Walking Infrastructure Plans)’
The village of Murton is in the centre of the Parish and is served by three roads, Murton Way (from Osbaldwick), Murton Lane (from the A166 York-Stamford Bridge Road) and Moor Lane (from Holtby, Stockton on the Forest and York). All three are narrow single carriageway roads with fast traffic.
Replies to six questionnaires used during the consultation period for the development of our Neighbourhood Plan indicate that the volume and speed of traffic is arguably the most contentious issue for residents. For example, 95% of the village resident response showed concern about speeding along Murton Way and 92% in the village itself. The free responses, where residents could add further comments to their answers, may be even more indicative of this concern. 51% cited traffic speed and 36% chose other traffic issues. Likewise, traffic dominated the concerns of residents of dwellings on the southern periphery of the Parish. For example, 80% of the residents in Tranby Avenue are highly concerned or concerned about speeding traffic and well over half the whole population in this area is concerned about speeding along the A1079 Hull Road.
While these specific concerns are outside the competence of the Neighbourhood Plan, the concerns are pertinent to development and thus the Local Plan. Although the Parish is not itself contributing significantly towards increasing the housing stock in York, the Parish abuts two significant developments, Land East of Metcalfe Lane (ca 845 dwellings) (ST7[2] and Land adjacent to Hull Road (ca 211 dwellings) (ST4). To give some perspective, the former has about six times the number of dwellings in the village and three times of that of the whole Parish, which will inevitably lead to increased traffic in the Parish. The development East of Metcalfe Lane will be the more significant, with vehicular access ‘planned from Stockton Lane to the north of the site and/or Murton Way to the south of the site with a small proportion of public transport potentially served off Bad Bargain Lane. Access between Stockton Lane and Murton Way will be limited to public transport and walking/cycling links only’.
There are statements that ‘high quality, frequent and accessible public transport services through the whole site will be sought enabling upwards of 15% trips to be undertaken using public transport’. It is the other 85% that concerns the Parish. Although it is likely that the impact on the Parish will be less than on neighbouring parishes, it will provide severe added strain on the village roads in the Parish, principally Murton Way and Murton Lane. In a Planning Inspectorate report in 2016, in which traffic was of major concern, the Inspector’s report notes that the data produced by the City of York Council on traffic flows along Murton Way are both sparse and old (dating back to 2003).’
It is not possible to comment further in any meaningful way as the precise access points from the proposed developments are not indicated, as the emerging City of York Local Plan simply says that they ‘will need to be assessed in more detail’. Further, it is noted that ‘Travel planning measures may reduce the motor vehicle trip generation but adequate transport links will need to be in place to make such measures effective’. This is against a background in which Murton village has only 3 buses a day into York, except for Sundays when there are none. If access were to be from Murton Way, substantial improvements would be needed to the road for the safety of cyclists and pedestrians and in the interests of local residents[3]. Its increased use will then have grave implications for the wider network of rural roads in the area.
The viability of the larger development (ST7) depends on a robust and independent[4] transport assessment in relation to this site. Indeed, the survey must address the potential impact on the wider network of rural roads on the east side of York before any decision about this site can be made. The problem crystallizes when the authors of the emerging City of York Local Plan write that ‘…level of improvement required, including the associated improvements/upgrades to junctions, carriageways and footpath widths etc.’[5] will be informed by a traffic assessment. With that, the rural vision for our Parish disappears.
The emerging Local Plan also recognises that Murton is on the National Cycle Network, Route 66, heavily used both by leisure cyclists and commuters although two of the three narrow rural roads to and from the village do not have footpaths and the third has a width that only allows walking in single file. At peak times there is a heavy and constant flow of traffic which conflicts with pedestrians, cyclists and horse riders and much of the road system is derestricted. ST7 is likely to contribute further to the problems that cyclists face in the Parish
[1] National Planning Policy Framework Ministry of Housing, Communications and Local Government. February 2019 Paragraph 104
[2] City of York Local Plan Pre-Publication Draft Regulation 19 Consultation, February 2018 Policy SS 9 p 243
[3] City of York Local Plan Annex 19 Site Selection Paper 147
[4] Please refer to Planning Inspectorate Report APP/C2741/W/15/3135274
[5] City of York Local Plan Pre-Publication Draft Regulation 19 Consultation February 2018 p47 para 3.49
Part 3. Submission for the July 2022 meeting
EXAMINATION INTO THE SOUNDNESS OF THE CITY OF YORK LOCAL PLAN