The following was submitted to Harrogate Borough Council on behalf of Kirk Hammerton Parish Council in response to HBC preferring Green Hammerton as a site for construction of the new town. It is being published here as an open letter.
Harrogate District Local Plan – Response to Consultation
Kirk Hammerton Parish Council wishes to make the following comments in response to the consultation carried out by Harrogate Borough Council on its latest proposals for the Local Plan. We appreciate that HBC prefers comments to be submitted in piecemeal fashion on separate matters, via its website, but we believe our response should be read as a whole. The flaws in the current proposals are best understood when taken in the round, not as separate, standalone, issues.
KHPC is aware of the views of the action groups representing Green and Kirk Hammerton residents and has seen their response to the consultation. We fully endorse all of their comments and agree with them. Please treat this response as repeating each and all of the points made. We would like to build on the action group’s excellent response and add some further thoughts of our own.
This response is focused entirely on the proposal for a new settlement. We have commented extensively in the past on proposals for individual development sites in Kirk Hammerton. Our position remains broadly as it has been for a number of years and the last few consultations on similar issues: we are aware of the need for new housing and are willing to consider and even support (as we did with the Agricon and Coidan Graphite sites) sensible and proportionate proposals for new developments in the village. Please feel free to come and discuss this with us in a constructive manner. The only pre-requisite must be to recognise that Kirk Hammerton is, and should remain, a village. Since the new settlement proposal aims to change this, we are limiting our response on this occasion to that document.
We begin with some general observations.
The consultation period runs from 14 July to 25 August. This is the school holiday season and is when most people in the UK, including parish councillors and other village residents, take their annual holiday. As a result, there has not been a single week during the consultation period when all KHPC councillors have been available to attend a Parish Council meeting to discuss the proposals and agree the terms of a response. Considering the importance of the latest proposals for the village, this is unsatisfactory and unreasonable. It was also entirely foreseeable by those responsible for setting the consultation period. Insufficient time has been allowed for consultation and the validity of the consultation process is therefore questionable.
Lack of Supporting Evidence
The main item in the latest consultation is the “New Settlement Report”. This document has been in preparation for many months and the Local Plan has been under development for years. The report recommends the first new settlement of any real size in Harrogate Borough for generations. The least those affected have a right to expect, after all this time, is to see compelling and detailed evidence to support the recommendation, for example reports, surveys, data analysis, etc. Instead there is almost nothing of substance to back up the report’s conclusions. The report itself is thin, relying on just 2-3 pages of bullet-point-style observations, some of which appear highly subjective.
Of course, this is a Local Plan for Harrogate Borough, but Harrogate is not an island. It borders other areas, which will be affected by any proposals for large new settlements, especially when the proposals include areas close to those borders. That is the case here with the Greater Hammerton, Maltkiln and Deighton development sites. There is no evidence in this report that HBC has made any attempt to seek the views of councils in York or Leeds, even though it is clear that residents in any Deighton development would look towards Wetherby and Leeds for work and local services and that substantial developments in Greater Hammerton or Maltkiln would affect York at least as much as anywhere in the Harrogate Borough. Either the proposals are flawed, because they have taken no account of the impact on neighbouring areas, or the consultation process is inadequate, because it fails to explain these issues to consultees.
Given that a considerable increase in local population would result from any development, we would also have expected to see evidence that local hospitals and emergency services, particularly in York, had been consulted. The Hammerton villages are not close to any emergency services providers and there is a potential concern that needs to be addressed before a 3,000 house development is approved.
Nor does the document seem to have addressed the wider commercial benefits to the Harrogate community of where any new town development is situated. If part of any proper planning strategy is to consider the economic interests of Harrogate as a whole (as it surely must be) it needs to take into account that building new settlements near the eastern boundary of the borough (Hammerton/Maltkiln) or the south (Deighton) is not likely to contribute much to the economics of the Harrogate area. People will go elsewhere to work and play and the economic benefits of the development will follow them.
Much is made in the document of the availability of railway stations in the Hammerton area (far too much – but please see later). It is worth pointing out that it’s 2 stops on that railway from Hammerton to York. It’s 4 stops to Harrogate and the last train back leaves an hour earlier than it does from York. Taxis from Harrogate cost a lot more. Where does that mean people are more likely to go and look for jobs/spend their money? In contrast, a development in Flaxby is within the Harrogate/Knaresborough sphere of influence and is much more likely to bring commercial benefits to the borough. The failure of the report to take this into account is a serious flaw.
We will comment on the detail of the report below, but first we highlight some specific issues which seem to have had a strong influence on the decision to recommend the Hammerton site, but which we think have been incorrectly evaluated in the report.
Sustainability/causing no harm to existing localities
As the report explains, national planning policy allows for the creation of substantial new settlements provided they are
- Sustainable; and
- Cause no adverse harm to the existing locality
These are fundamental principles. On a basic level, it is hard to understand how a report taking account of this could properly conclude that a development which creates a new town right next to two small villages, and proposes to re-locate a busy A road to within less than 100 yards of Kirk Hammerton, is preferable to a development at Flaxby or Deighton, where the existing built environment that might be affected is much smaller. There’s no need for detailed analysis – that just doesn’t make sense.
The Railway Line
The railway line, and the fact that there are existing stations in Cattal and Hammerton, seems to have been the biggest single factor in the recommendation for Greater Hammerton as the preferred site. This impression was confirmed by comments made by HBC Planning officers at the consultation event in Green Hammerton on 25 July (it was a knife-edge decision; the railway line was the main deciding factor).
The report notes that the Flaxby developer is willing to develop a station to support a new settlement there, perhaps even re-instating the abandoned station in Goldsborough. The costs of this could be shared with the development of the new employment site which has already been given the go-ahead. It is explained in the report that improvements to junction 47 of the A1(M) have already been commissioned. This would therefore seem to be an ideal opportunity finally to realise the vision of a park and ride station close to the A1(M), with obvious wider commercial benefits for Harrogate town centre.
Despite this, the report concludes that the Hammerton and Maltkiln sites are more sustainable, because of the stations at Cattal and Hammerton. This analysis is, however, seriously undermined by the proposals of the Greater Hammerton developer itself, which were on public display at the 25 July consultation event. So inadequate are the facilities at both stations that the developer’s plans envisage the building of a new station between the two existing sites, with proper car parking provision. It clearly believes that the existing infrastructure is not sustainable in the event of a development of the size proposed.
This does seriously undermine confidence in the planning recommendation which attaches such significance to the existing stations. Of course, they are better than nothing, but if the truth of it is that a new station will be required to support the new development, surely it makes more sense to locate it at Flaxby and combine it with the benefit of a Park and Ride with access to the A1(M), especially as there is already committed funding to pay for improvements to the junction.
The report also overestimates the ability of the railway line to support sustainable transport. It is admirable that HBC has a policy that places importance on the use of public transport and we support that, as far as it goes. However, at some point it must be acknowledged that, in the real world, people living outside big cities use their cars in preference to public transport. That will remain the case even after a development at Hammerton or Maltkiln, especially as the railway line, being single track, can only support a limited service. There is now a Park and Ride at Poppleton which is less than half the cost of using the train and with buses into York every 10 minutes, not once an hour. That’s what people are using now. It’s much easier and cheaper than going to York or Harrogate by train.
The report seems to attach significance to the possibility that the railway line might be upgraded to a two-track line, leading to greater frequency of trains. This is a flaw in the report, because there is simply no evidence to support the assertion that it might happen. The report states that a dual track line is part of the North Yorkshire County Council long term plan, but it does not explain where the money will ever come from to build it. It will not be NYCC’s decision whether a railway line is built, so it is wrong to take into consideration in a planning decision the fact that they might like to see it happen. Planning decisions cannot be based on wishful thinking.
Loss of agricultural land
The report states that a development at Flaxby would result in the highest proportion of high grade agricultural land being lost and this appears to have been a factor in recommending the Hammerton development.
KHPC does not have the capacity to take measurements, but simply from looking at the OS plan of each site in the consultation document, it seems hard to believe the assertion that 77% of the FX3 site is good quality agricultural land, considering that a large proportion of the land is described as “golf course” and other parts of it are woodland. It is true that the golf course development did not take place as planned, but since planning consent already exists to create a golf course, there is already a planning approval in place which means the land is lost for agricultural purposes. It is disingenuous to portray the FX3 development as causing this loss of agricultural land.
We would also query the assertion that the Hammerton development involves the loss of a lower proportion of agricultural land (said to be 67% in the report). It is true that a significant part of the Greater Hammerton development is on land cultivated by Johnsons of Whixley as a commercial nursery. Even if it is correct to describe this land as non-agricultural for planning purposes (our understanding is different, but we are not experts), the report notes that Johnsons will relocate their business to a nearby site, which the report suggests is also within the Harrogate Borough. It is hard to believe that Johnsons will relocate to land which is developed, or a brownfield site, so the result of their relocation is also likely to result in the loss of land elsewhere in the borough which is capable of being used for agriculture. This would put the effective percentage of agricultural land lost as a result of the Hammerton or Maltkiln developments at close to 100%. This should be taken into account in the assessment.
Location of A59
It is surprising that the report takes so little account of the inevitability of increased traffic on the A59, especially as this road is already close to capacity at the busiest times of the day. This is before the increase in traffic likely when the waste incinerator at Allerton begins operations and takes no account of current proposals for a sugar beet factory nearby and a further commercial plant at Hessay. This is a source of great concern to the Parish Council and KH residents generally, but is barely mentioned in the report. There is absolutely no evidence in the report of any attempt having been made to assess the ability of the A59, in particular, to absorb the likely traffic increases. It is unrealistic to assume that significant numbers will use public transport rather than the car.
The report also takes no account, when assessing sustainability and impact on existing settlements, of the proposal by the Greater Hammerton developer to re-route the A59 so that it skirts the new development to the south, running close to the railway line. At present the vast majority of Kirk Hammerton is situated several hundred yards from the A59 and the noise impact for most residents is minimal to non-existent. That would change very quickly if the A59 were re-routed as planned. As the report itself states, Kirk Hammerton would be located some 155m from the Greater Hammerton development. That means it would be even closer to the A59, once the road runs to the south of the new development. Traffic noise would be very noticeable in the centre of the village, including the conservation area, to say nothing of the noise and disturbance caused by the construction of a brand new road.
This was pointed out to the developer at the consultation event on 25 July. Their response was to state that the current plans can be changed and are not set in stone. While this is no doubt true, one of the factors noted in the report as favouring the Greater Hammerton development was that it would not be split in two by the main road (“…[re-aligning the A59] would allow for greater integration of movement within the development site…” – page 23 of the report). The road has to go somewhere, so either it is re-routed, or it stays where it is. Both solutions have distinct disadvantages, a factor which is not properly taken into account in the report’s recommendations. (Note that a third solution, such as re-routing the road to the north of Green Hammerton, would not be an option. Not only would costs be prohibitive, but the developers do not control that land.)
Employment for Residents of New Settlement
The report makes some attempt to address the issue of employment, but the conclusions drawn are illogical and do not reflect the very limited evidence presented.
The report rightly notes that consent has recently been given to create a large new employment area adjacent to the Flaxby site. It also notes that site FX3 is within easy reach of employment opportunities at Knaresborough, etc. It points out, again quite rightly, that the Deighton site is close to employment possibilities at Wetherby, with an excellent bus connection to Leeds city centre. Nothing is said in the report about employment opportunities close to the Hammerton and Maltkiln sites. That is also quite correct, because there are none at present and the plans on view at the 25 July consultation event did not mention any proposals to create them.
The obvious, and correct, conclusion to have drawn from this would have been that the Flaxby and Deighton sites offer far greater sustainability in terms of employment opportunities, being close to areas where employment is available and accessible without the need for a car. In contrast, the likely options available to the thousands of people living in a development at Hammerton or Maltkiln would all involve getting in the car and driving to work, probably using the A59 and travelling several miles at least.
It is surprising that no account was taken of this in the report’s findings and recommendations. Instead, there is a rather lame assertion that there would be a need for pedestrians walking to work at the new site at FX4 to cross the main road. Surely when we are talking about developments that require an entire A road to be re-routed for nearly 2 miles and for new railway stations to be built (with the huge associated costs), this is not an impossible problem to solve? The developer of the employment site could be expected to contribute to the costs. After all, the developers of FX3 and FX4 will have been saved some substantial costs by the construction, at a cost of £4m to the public purse, of a roundabout adjacent to their sites.
The report suggests that development of the Flaxby site would risk undermining the aspect from Allerton Park, which was carefully designed to afford enhanced views over surrounding landscape.
With great respect, the report does seem to be in danger of losing objectivity in its search for reasons why Flaxby is not the obvious site for any new settlement. It would indeed be sad if the heritage of Allerton Park were adversely affected, but has this not already happened with the construction of the A1(M) and especially the 100m-high tower of the adjacent incinerator site currently under construction? The sugar beet factory is not going to improve things. The view has already gone. Building some houses on the opposite side of the A1 is not going to affect it either way.
The very next paragraph of the report (top page 23) then goes on to suggest that the minerals which may (or may not) be located below the Flaxby site might be commercially valuable. It is not explained why the Flaxby minerals would be more valuable than those which also exist in each of the other development sites, but the suggestion that the site should not be developed in case it is needed for a sand and gravel quarry does make the previous paragraph, which expresses concerns about the visual impact of a housing development on Allerton Park, hard to take seriously.
The report’s assessment that the Flaxby site is at least as likely to have heritage implications for any housing development as Hammerton or Maltkiln does not seem to be based on any clear evidence. Considering that Kirk Hammerton has a Saxon church and that Green Hammerton lies on the site of an old Roman Road (York to Aldborough, which does not pass the FX3 site) the reverse seems much more likely.
The New Settlement Report
We comment below on specific paragraphs of the report, but without repeating comments already made above.
- Principle of a new settlement and proposed growth strategy
The report refers to the wider assessment of suitable development sites undertaken as part of the Local plan development and notes that many of the sustainable sites were located in existing settlements where there is best accessibility to jobs and services (and there is available infrastructure). It then goes on to acknowledge that there are sustainability issues with each of the potential new settlement sites. However, the suggestion is that not enough new housing can be delivered using conventional planning assessments. That in itself does not surprise us, having seen the very restrictive way in which planning principles tend to be interpreted by the planning authority when developments are proposed in our village, but it doesn’t have to be that way.
We repeat the comment in our response to the previous consultation: we are far from convinced of the case for a new settlement. No concrete evidence has been produced that substantial amounts of new housing cannot be delivered by adopting slightly less restrictive planning assessments to a large number of smaller sites in both urban and village locations.
As we have explained previously, Kirk Hammerton has supported development proposals over the past few years which will lead to an increase of more than 25% of homes in the village. Green Hammerton has seen similar, if not even larger, increases. There is scope for even more development in KH (sustainable and with the support of local residents) if HBC planners adopt a more constructive approach and show a willingness to engage with the local community. If a similar attitude is applied in other locations we can deliver a very large amount of additional housing across the borough without the need to concrete over large areas of farm land, either in Hammerton or Flaxby. It will require a more pro-active approach from HBC planning than we have seen in the past, but it is surely worth the effort.
The report states that previous consultations indicated a degree of support for the idea of a new settlement. We are sceptical about this. HBC should be wary of drawing far-reaching conclusions from the expressions of support for new settlement proposals that appeared in responses to the previous consultation. If you look closely, it will become apparent that many of the postings supporting the Hammerton settlement were from those living in the Flaxby area (it was the mirror image with the posts supporting Flaxby – some of these were no doubt from Hammerton). This does not lead to the conclusion that there is widespread support for the principle of the new settlement idea.
The report refers to additional housing sites and makes the point that “there is a limit to which existing settlements should grow during the plan period if their character…is to be retained…”
We completely agree, but how does this lead HBC to recommend a development that would have precisely the opposite effect on the villages of Kirk and Green Hammerton? A consistent and informed application of this principle would lead to a recommendation that FX3 is the preferred development site.
The report assesses each potential site by reference to a preferred growth strategy set out elsewhere in the draft local plan. This seems logical, but we would submit that a broader approach is needed to assess something that is an exceptional requirement. The growth strategy focuses on the east-west corridor. Nothing wrong with that, provided any new housing requirements can be delivered along that corridor using normal planning principles. The whole point is that this cannot be done, which is why a new settlement is being considered, as an exception to the normal rules, which would not permit development on arable land. In these circumstances, it is unduly restrictive to give preference to development sites that meet narrow criteria. In exceptional situations, normal considerations do not apply and all options need to be considered. That would suggest that more consideration should have been given to the Deighton site.
- Site Characteristics
The description of bus services in the Hammerton area is technically correct, but the impression given is that the service is (a) quite good and (b) comparable to Flaxby and Deighton, both of which are misleading. There is a bus once a week from Kirk Hammerton which takes people to the Morrisons supermarket in Boroughbridge. That is the only bus serving the main part of the village.
It is possible to walk all the way to the A59 at the end of Station Road (up to a mile distant, depending on where one lives), wait at a stop with no shelter from the elements and catch one of about 5 buses a day that pass along the main road, travelling between York and Boroughbridge (with some onward journeys to Ripon). Very few people wish to travel to Boroughbridge and it is necessary to cross the busy A59 to catch the bus into York, without the benefit of any crossing facilities. There is no bus service to Harrogate or Knaresborough. The reality is somewhat different from that implied by the report’s description of a “frequent service on a daily basis”(see page 20) and it should be no surprise that bus services are little used. In contrast there is an hourly service linking Flaxby with Harrogate, as the report explains.
- Constraints and Opportunities
The report suggests that junction 47 of the A1(M) represents a major constraint to development, but the report goes on to explain that funding is already in place to carry out improvements, with construction starting in the current financial year. It is therefore hard to see this as a significant constraint. It appears, instead, to be a significant factor in favour of a development close to this junction.
We do not agree that FX3, CA5 and GH11 are all affected equally by the situation at junction 47 – FX3 is sited just a few hundred yards away from the junction and has already benefited from significant public expense in the creation of a roundabout. Now it will benefit from junction improvements as well. Traffic heading in the other direction from FX3 soon gains access to the Harrogate ring road. Surely it is obvious that any development would be better sited here, allowing it to benefit from the significant investment in road infrastructure over recent years at junction 47 and on the west side of the AI(M). There has been no investment to speak of in roads to the east of the A1(M). Traffic from GH11 or CA5 is less likely to benefit from the Junction 47 improvements – many cars will either head in the opposite direction, towards York, or will choose to use the minor roads heading north and south, placing more strain on the likes of Cattal bridge.
On page 20, the report comments that the development of CA5 may require a new bridge across the railway line at Cattal station. We note that both the Maltkiln and Hammerton developments appear to require massive investment in road infrastructure, simply to make the developments feasible. One of them requires a road bridge over the railway line; the other expects to re-route a major A road for some considerable distance. Both developments will require major road improvements at the Whixley crossroads junction. They both require mains gas pipelines and infrastructure to be laid either from Harrogate or York.
These costs are huge and will have to be be incurred in addition to any normal infrastructure works required for a new development of this size. In contrast, none of the additional costs that affect CA5 or GH11 will apply to FX3, where the road and mains gas infrastructure is already broadly in place (with a roundabout already constructed at public expense and further publicly funded road improvements already scheduled for the next few months). There is also another development taking place at site FX4 which could share any infrastructure costs with a housing development at FX3.
The additional costs of CA5 and GH11, compared to FX3, are surely likely to be in the tens of millions of pounds. It is a matter of basic common sense to conclude that this must make the Flaxby site by far the most deliverable. Yet there is no evidence that the report has taken serious account of this.
In the “heritage” section the report correctly notes that “…development of [the GH11 site] has the potential to impact on the setting of listed buildings within or in close proximity to the site…” This is then dismissed with a statement to the effect that appropriate mitigation measures may be applied.
Since the only measure evident from the developer’s proposals at the public consultation was a proposal to divert the A59 so that it runs within 2-300 yards of the listed buildings in Kirk Hammerton, thereby increasing pollution and noise, KHPC is more concerned about the heritage aspects than the report’s authors seem to be. Please can this issue be properly taken into account.
In the “economy” section on the same page, there is a statement about GH11 that “..On-site employment opportunities would be available within the local centre..”. Could it please be explained what these will be, because there were no proposals for any new employment areas in evidence at the consultation event on 25 July and none exist at present. In contrast, a whole new development area with employment use has been approved on a site adjacent to FX3.
Kirk Deighton connectivity (page 24)
In contrast to the description of bus services for sites GH11 and CA5, where the services are significantly over-played, the description of the bus services that could be available at the Deighton site is very much under-stated. There is an excellent service throughout the day at very regular intervals, with the last service back to Deighton Bar from Leeds departing not long before midnight. It is a service which large numbers of people actually use. This service could easily be extended to serve a new settlement. The “problem” is that the bus takes people to Leeds, not Harrogate, but if exceptional measures have to be taken to deliver more housing, parochial issues like this surely have to be disregarded.
In general, it is clear from the assessment that the Deighton site, using conventional and objective evaluation measures, is a much better proposition than the report is willing to allow. It merits much closer consideration than it seems to have received. The main problem is that most of the economic benefit of this development will go to Leeds City Council, but that alone surely cannot justify the report’s apparent failure to give it due consideration. The analysis of site OC5 on pages 24 and 25 is skimpy in the extreme.
- Comparative Analysis- pages 28-30
After many years of preparation, a decision to choose a rural site for a substantial 3,000 house development is to be made based on 2 pages’ worth of bullet-point-style comparisons. This is disappointing. People living in the affected areas deserve better.
We believe the assessments in many cases do not reflect the evidence, as follows:
As explained earlier, creating a new settlement is an exceptional matter. Identifying the right site should not be constrained by “regular” planning issues such as the growth strategy. If we were applying normal planning principles to this issue, there wouldn’t be a new settlement at all because it contravenes all the basic principles that have applied for years. All sites should be rated equally on this issue.
Scope for future expansion
GH11 and CA5 are rated more highly as a result of this, but it is surely a bogus criterion. It is true that the two sites overlap, but if the proposal is to build two new settlements rather than one, a completely different consultation would be required, meaning that the present process would need to start again from scratch. That is not what we have been asked to comment on.
The fact is that all 4 sites could be extended, if the planning authority was willing to authorise yet more loss of adjacent agricultural land and if the developers controlled the relevant land. None of the developers of these sites currently have the ability to deliver additional land (it is not clear if they can even deliver the land they propose to develop). This factor is therefore of very limited relevance, if any, and all sites should be rated equally.
For the reasons explained earlier, we disagree with the assertion that FX3 results in greater loss of agricultural land. The opposite is the case, as we have demonstrated.
We also disagree with the assessment that the impact of FX3 and GH11 on existing settlements is the same. As the report explains, there will be little impact on Coneythorpe or Goldsborough if FX3 proceeds.Flaxby will be affected, but this is a far smaller settlement than either Kirk or Green Hammerton. In addition the GH11 development is on rising ground and is therefore more visible. There is simply no comparison in terms of the impact GH11 will have on existing communities.
There was very limited consideration of this in the report and it would be reasonable to expect the comparison to rank all sites equally. We question the allocation of a lower rating to the Flaxby site as a result of the existence of Tree Preservation Orders. The site is vast and there is room to develop large numbers of houses without anything happening to the wooded area to the south of the A59 (which is by far the smaller part of the site in any case).
All sites are rated equally, but this cannot be justified by a proper examination of the evidence. Admittedly, the analysis of the Deighton site is very light touch, but it is hard to see any serious reason, based on the information given, to rate this as anything other than very low risk for heritage. For the reasons given earlier, the heritage ranking of FX3 should be lower risk than that of either CA5 or GH11.
The assessment here takes no account of the impact which diverting the route of the A59 would have on Kirk Hammerton. This would increase noise and air pollution to an existing settlement. The alternative would be to leave the road in its present location, in which case it will bisect the new settlement, also leading to issues of noise and air quality. Given that the A59 will have to pass within yards of some of the houses in any GH11 development, whatever road layout is adopted, it is hard to understand why this is rated as better for noise than FX3. FX3 will of course be within range of the A1(M) but it will not be right next to it. There are measures available to reduce noise impact.
As explained above, the assessment needs to take proper account of the bus services available to each site, which vary greatly in quality.
For the reasons we have explained, far too much importance has been attached to the benefits of the existing railway stations at Cattal and Hammerton. Their significance is fatally undermined by the fact that the developer of the GH11 site intends to build a replacement station to replace these facilities as they are considered inadequate to support developments of this magnitude. That is not KHPC’s assessment – it’s what the very people who want to develop the site have concluded.
We agree that OC5 should be assessed as low risk. The same assessment should surely apply to FX3, given that large sums of public money have been spent, and will soon be spent, in improving the road infrastructure that will serve this site, and the fact that any further costs can be shared with the developer of site FX4. What more does the taxpayer have to do to de-risk this project for the developer?
The CA5 and GH11 schemes are correctly rated as the highest level of risk. As noted above, we would suggest that, if the CA5 scheme requires a bridge to be built over the railway line and the GH11 scheme requires a long stretch of A road to be diverted, the related costs on their own are enough to render these two schemes undeliverable, when compared to FX3 or OC5. The assessment should take this into account.
If the overall conclusion has been reached simply by adding up the values of the risk gradings for each section, and awarding the same marks for (say) achieving the same assessment level for growth strategy and physical limitation, with no weighting for issues of higher importance, it is hardly surprising that the report reaches the wrong conclusion. The issues in this section result in additional costs in the many millions of pounds and are therefore fundamental.
Impact on existing communities
For the reasons explained above, the impact on the Kirk/Green Hammerton communities should be assessed with a different weighting to the FX3 development, simply because of the numbers of people affected. This is no disrespect to the people of Flaxby, but just common sense based on scale.
No comment – all sites are rated equally, which seems correct.
The Flaxby site appears to be rated as less satisfactory than GH11 or CA5 as regards employment possibilities. Presumably this means that the report assesses GH11 and CA5 as offering better employment options locally than FX3.
Is this simply a production error in the document? Given the relative proximity of Flaxby to employment possibilities in Harrogate and Knaresborough and the creation of a large new employment site immediately next to the FX3 site, it surely has to rate much more highly than any of the other alternatives for employment. If the report is seriously suggesting a different conclusion then its finding is perverse.
We agree with the assessment that CA5 and GH11 are the highest risk in terms of deliverability. For reasons of cost of infrastructure, we would argue they should be assessed as simply undeliverable and therefore ruled out altogether.
When the various factors identified in the report are analysed objectively and applying common sense, it is impossible to escape the obvious conclusion – that of the two sites which have been subjected to the most detailed consideration (FX3 and GH11) the site at Flaxby is clearly the one which merits being taken forward.
The Maltkiln site (CA5) suffers from most of the same disadvantages as GH11.
There are a number of factors which suggest that the Deighton site (OC5) has merit and deserves greater consideration than it seems to have received to date.
KIRK HAMMERTON PARISH COUNCIL
22 August 2017