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PREPARED ON BEHALF OF
SOUTH MILFORD PARISH COUNCIL
Prepared by:
Kathryn Jukes
Directions Planning Consultancy
17 Otley Road
Harrogate
HG2 0DJ
T: 01423 503334
M: 07908 666530
E: kjukes@directionsplanning.co.uk
www.directionsplanning.co.uk
INTRODUCTION
This representation has been prepared by Directions Planning Consultancy on behalf of
South Milford Parish Council and it represents the views of the community of South Milford.
In order to inform the preparation of this representation, the Parish Council undertook
consultation across the village. Consultation was undertaken by providing every house with
a questionnaire which could be returned to either the Post Office or Sand Lane Stores, and
also the creation of a bespoke website which included an electronic version of the same
questionnaire to be completed online. 183 responses were received, along with a further four
emails with comments. The responses to the consultation form the basis of the views
expressed in this representation, and are referred to in the comments which have been set
out against each of the questions raised in the Selby DC SADPD consultation document. A
summary of the findings of the South Milford consultation has been attached at Annex A for
information.
Given the level of response and the strength of the views expressed then we hope that
Selby DC will truly reflect the wishes of the community in the drafting of the Site Allocations
DPD. South Milford would not expect the amount of development to be identified in the Site
Allocations DPD to be greater than what has being put forward in this representation.
Particularly, as we believe that a pragmatic approach has been taken to the situation in an
attempt to be helpful. If Selby DC attempted to allocate more development in addition to that
put forward in this representation, then the Parish Council would strongly object, especially
as to do so would not be in the spirit of Localism. The consultation and the Parish Council’s
position is with a mind to adopting a bottom up approach to planning and working with Selby
DC in a constructive manner.
South Milford has received a large amount of development over the Local Plan period which
has resulted in a perceived change in character across the village. The community feel the
character of their rural village has been threatened by a large amount of development, which
has caused a number of tangible problems, including too many cars parking on pavements,
no available parking at the train station, a lost sense of community, pressure on the junior
school and a shortage of nursery and after school childcare provision in general.
The community accepts the development of Site 002, as it is already an allocated site in the
Local Plan. The redundant greenhouses are also considered to be an eyesore. In addition to
the allocation of Site 002, we would like to remind the Council that there are also a number
of other sites which may also be developed for housing in South Milford, including the former
Kia garage and forecourt on the opposite side of the road. These are brownfield sites, which
means they could come forward as windfall sites. They will however still form part of the
housing land supply and therefore should count towards the contribution South Milford will
make to the housing land supply in the LDF period.
The allocation of Site 002 plus the potential development of the brownfield sites is
considered to be more development than South Milford might reasonably be expected to
accommodate given its size and role. Particularly, if compared with the number of houses to
be accommodated in Sherburn in Elmet and Tadcaster, and other villages.
Furthermore, the Green Belt boundary around South Milford was reviewed through the Local
Plan process, which means the current boundary has only been adopted since 2005. PPG2
sets out that Green Belt boundaries should endure, as they are intended to be permanent.
The Council should therefore have no need to review the Green Belt boundary so soon,
particularly as to do so would undermine the objective of setting a Green Belt boundary in
the first place. Green Belt is a policy tool to protect the openness of the countryside and to
prevent urban sprawl. If the Council needs to roll the Green Belt boundary back after only
just setting it, then it would amount to allowing urban sprawl. This also means the policy
could not be viewed as working, as the boundary which was drawn only six years ago could
not be said to be permanent.
South Milford is willing to support the allocation of Site 002, but on the basis that there will be
no further release of additional Green Belt land for development during the LDF period. The
consultation found that 62 per cent of respondents thought South Milford should receive less
development than other Service Villages and only one per cent thought it should receive
more. Furthermore, 87 per cent of respondents supported the on-going allocation of Site 002
instead of the allocation of a different site and 85 per cent believe no further land should be
allocated for development in addition to Site 002.
We therefore strongly object to the allocation of further land in addition to Site 002.
ISSUE A2: How should we apportion the 1573 houses between the Designated Service
Villages?
OPTIONS:
1. Split the number equally between the villages. This means every village gets the same
number of houses so the large villages will only grow a small amount while the smaller ones
will grow significantly.
2. Apply a standard 10% growth to each village. This means that each village will grow at the
same rate, but doesn’t take in to account their relative ability to take that amount.
3. Proportion the amount by looking at the evidence of how much is needed, and how many
services and facilities are available to take the growth. This may mean that none is allocated
in some villages and lots are allocated in others.
4. Proportion the amount by looking at the constraints on growth such as Green Belts, main
roads, flood zones etc. This may mean that none are allocated in some villages while lots
are allocated in others where there are fewer/no such constraints.
5. Other options (please specify)
6. Combine options? (please state which)
South Milford supports Option 5. The community of South Milford believe the village should
receive less development than other villages, due to the amount of development which has
been built in the village over the Local Plan period. The growth experienced in the village is
greater than growth experienced in other villages of a comparable size. The community
believe the amount of development which has been built in recent years has changed the
character of the village, and the village status is under threat. Furthermore, the village
accepts the allocation of Site 002, and it is understood that there are also brownfield sites in
the village which may come forward for development in addition to Site 002. These sites will
collectively deliver more development than the village might reasonably be expected to
receive if development was fairly portioned across settlements in accordance with Option 1,
and so the village would not support further allocations.
South Milford believes that it is being constructive by taking a pragmatic approach and
supporting the continuing allocation of Site 002 when it might actually expect less land to be
allocated during the LDF period. To ensure the situation is fair the community would want
the allocation to be released for development in a later phase of the LDF, and certainly after
all brownfield sites across the District have been released. We would not support Site 002
being identified in Phase 1, particularly if a sequential approach is too be advocated in the
LDF.
As set out in our response to QA1, the development of these sites will together deliver an
amount of development comparable to the proportion of housing development to be directed
towards Tadcaster and Sherburn in Elmet. These settlements are supposed to be Principle
Towns and should therefore be receiving a greater proportion of development than a village
such as South Milford. This however does not look like the case given the numbers which
are being put forward and the actual amount of development which might result. For this
reason, we would encourage the Council to release Site 002 only after allocations made in
the Principle Towns are developed, and certainly after the development of the brownfield
sites across the District. Otherwise, the LDF will result in unsustainable patterns of
development where development will be dispersed across Service Villages such as South
Milford before more sustainable sites are developed in the Principle Towns. This is clearly
not an approach which should be advocated by the Council if the LDF is to be in accordance
with national guidance.
ISSUE B: How do we prioritise the timing of development for housing over the next 15
years?
OPTIONS:
1. Release all land at once and let the market decide what gets built and when? (no Council
control)
2. Develop a staggered approach based on:
a. Size of site (biggest first), OR
b. Proximity to Selby (closest first), OR
c. Selby-centric model
i. Strategic Sites in the Principal Town, then
ii. Brownfield land within the Principal Town and Local Service Centres, then
iii. Other infill opportunities within Principal Town, Local Service Centres, then
iv. Sites on the periphery of Principal Town and Local Service Centres, then
v. All sites within Designated Service Villages, then
vi. Sites on the periphery of Designated Service Villages, then finally
vii. Any other sites. OR
d. District spread model
i. Strategic Sites in the Principal Town, then
ii. All sites within Designated Service Villages, then
iii. Brownfield and other infill opportunities within Principal Town, Local Service Centres, then
iv. Sites on the periphery of Principal Town, Local Service Centres and Designated Service
Villages, then finally
v. Any other sites.
3. Release all sites in Designated Service Villages at once, and only phase the sites in Selby
Town, Sherburn-in-Elmet and Tadcaster,
OR
4. Release sites based on the need identified in the Housing Needs Survey, OR
5. Other method?
6. Combine options above (state which)
We support Option 2c, as the approach promotes the principles of sustainable development,
and it is based upon the sequential approach advocated in PPS3. The correct approach
should focus development on the larger settlements first, and also encourage the release of
brownfield sites before greenfield sites. If the approach set out in PPS3 is applied correctly
then Option 2c is the result. The Council has not identified any reasons why the SADPD
approach should differ from that set out in PPS3 and under Option2c, so this is the approach
which should be taken forward.
Option 1 cannot be supported as this does not promote a planned approach in accordance
with the purpose of the planning system. If it were sensible to simply let the market decide
when sites were to be built then there would be no point in having a SADPD. We have a
plan-led planning system, which suggests this approach is inappropriate and would be
unsound.
Under Option 2, we cannot support the release of the largest sites first. Large sites take time
to deliver so the Council may end up with a five year land supply problem in the short term.
Also, large sites tend to be greenfield and on the periphery of settlements which means a
number of smaller brownfield sites in more sustainable locations would not be encouraged to
come forward first.
Option 2d appears to flip the sequential approach, so that some of the most sustainable
sites, which are brownfield infill sites within Principle Towns, would be released after sites in
Designated Villages. This approach is nonsense as there is no situation where development
should take place on greenfield sites in villages before brownfield sites in the Principle
Towns. For that same reason, we also object to Option 3, as this option too would see
development in the villages taking place before development in the Principle Towns. If this
Option were amended so sites in the villages were released only after the first two phases of
development had been released in the Principle Towns then this Option might be more
sensible and would better reflect the guidance in PPS3.
Option 4 is actually quite sensible as it would deliver houses where they were most needed,
so addressing market demand as well as housing need issues. We therefore would not
object to this Option. It is also an Option other local authorities have looked to adopt
because it would help deliver their affordable housing need requirement.
The results of the South Milford consultation support the release of all brownfield sites before
the development of greenfield sites. The community would also like to see allocations
developed in Selby and the Principle Towns before any further development takes place in
South Milford. There was also strong support for the need for more houses to be established
before land is released for development.
ISSUE C1: How should we work out the OVERALL amount of land required for
development?
OPTIONS:
1. Use a single District-wide density figure.
2. Use village-specific density figures.
3. Other method?
The character of the District varies so it is not considered appropriate to adopt a single
Districtwide density figure, as suggested by Option 1. In addition this would not be in
accordance with PPS3 which suggests development should now be designed at an
appropriate density to fit the character of the surroundings.
We would support the provision of houses rather than flats in South Milford so would look to
supporting Option 2. A number of developments in South Milford have over the last ten years
included small units of flats and terraced houses. There is support in the village for larger
family houses, and the LDF evidence base also suggests that family houses are needed
more than smaller unit. There is also demand for bungalows – a housing type which has
been overlooked over the last decade.
We would also like to request the LDF refers to the South Milford Village Design Statement
in determining an appropriate density for the village. The Design Statement defines the
different character areas across the village, and the appropriate types and forms of
development that should take place within those character areas. Planning is in the future
meant to be formulated from a ‘bottom-up’ approach, therefore it would now be appropriate
to take the opportunity for the LDF to reflect such locally prepared guidance.
We would suggest there is a different option which is that the Council needs to consider
what types of houses are required to meet future need and demand, and put forward a
density range which would promote that type of development. This option is being suggested
as we question whether Option 1 would help deliver the types of houses required to meet
future housing need given it has no base in policy (PPS3 deleted reference to standard
densities). Also the other options would simply reflect past patterns of development, which
again would not necessarily deliver the types of houses which are needed to meet future
need and demand.
We would also like to request the LDF refers to the South Milford Village Design Statement
in determining an appropriate density for the village. The Design Statement defines the
different character areas across the village, and the appropriate types and forms of
development that should take place within those character areas. Planning is in the future
meant to be formulated from a ‘bottom-up’ approach, therefore it would now be appropriate
to take the opportunity for the LDF to reflect such locally prepared guidance.
The South Milford consultation found that of the housing types suggested, detached (32%)
and semi-detached (28%) dwellings were the most popular, whilst flats (4%) were the least
popular. There was also good support for the provision of bungalows (23%) and terraced
housing (13%).
ISSUE D: Do you agree with this methodology for assessing and prioritising sites?
PRIORITY:
1. Undertake the Sequential Test (Seek Flood Zone 1 first, Zone 2 second, and Zone 3 last)
2. Prioritise land that is available soonest.
3. Prioritise land in this order:
a. “Brownfield” land already within the Limits to Development
b. “Greenfield” land already within the Limits to Development
c. “Brownfield” land immediately adjacent to* the Limits to Development,
d. “Greenfield” land immediately adjacent to* the Limits to Development.
e. Do not allocate land that is not physically linked to the limits to development.
4. Direct new development as near to the settlement’s services and facilities as possible
(including public transport).
5. Direct new development where there will be least traffic impact.
6. Direct new development to where there are no existing planning constraints such as
Green Belt, unless there are no alternatives.
7. Develop land that requires the least amount of infrastructure upgrading/development to
minimise costs and disruption
8. Direct development to the sites with least wildlife impact?
9. Site development where its carbon footprint can be managed and reduced.
The methodology appears reasonable, but we would like to see how the Council might
prioritise the criteria as the order does not appear to be quite right. We would also like to see
a couple more criteria added to the list which are:
• Look at the amount of development that settlements have received in the past in
comparison with other settlements to ensure it is fairly distributed; and
• Consider the affordable housing requirement and prioritise the allocation of land
where it will help deliver local housing need.
There is some overlap with this question and also Issue B, as the approach to identifying the
sites would also be appropriate to determine the order in which sites are released. We would
support the phased release of sites in accordance with the sequential approach set out in
PPS3 (as we suggested under Issue B), which would see brownfield then greenfield sites in
Selby and the Principle Towns released first, then brownfield and then greenfield sites
released in the designated village. The other considerations listed appear to be matters to
determine the availability, suitability and deliverability of sites within the sequential approach
outlined in the previous sentence. There are clearly several stages to determine how to
prioritise the release of sites where the sequential approach comes first and then site
considerations second.
In order to maintain a five year land supply, sites which are already committed, should be
taken into account in working out the phased release of allocations, as it is likely there are
sufficient commitments and brownfield allocations across the District to suggest greenfield
sites, such as Site 002, should be released in later phases. We would not support the
release of Site 002 in the first phase, in order to ensure it was only released for development
after brownfield sites across the District and allocation in Selby and the Principle Towns had
been developed first.
Based on the responses to the South Milford consultation, we would support the provision of
family houses and bungalows, which is simply a relatively low density of development. We
believe that specifying a density of development is as far as the LDF should go. To
determine the housing mix in a policy document would be a mistake as it would not allow the
market to react to demand, and also it is unlikely that the correct housing mix can be
determined the preparation of a policy document for a site which might be built in ten years’
time.
We would like to take this opportunity to request the LDF refers to the South Milford Village
Design Statement in determining an appropriate density for the village. The Design
Statement defines the different character areas across the village, and the appropriate types
and forms of development that should take place within those character areas. Planning is in
the future meant to be formulated from a ‘bottom-up’ approach, therefore it would now be
appropriate to take the opportunity for the LDF to reflect such locally prepared guidance.
Planning policy has never been considered to be more knowledgeable of market demand
than developers, and it has also not traditionally attempted to be so prescriptive. Planning
policy is after all only intended to provide a framework for shaping development.
For these reasons we would support Option 1 and cannot support Options 2 and 3.
ISSUE I1: How to secure contributions towards the strategic infrastructure delivery.
OPTIONS
1. Have a single District-wide structure so everyone pays a proportionate amount (for
example where every development in the District could contribute to road improvements in
Tadcaster)
2. Have set sub-District structures (such as Community Engagement Forum areas). (for
example where only development in the north west of the District could contribute to road
improvements in Tadcaster)
3. Have a “polluter pays” principle where the impact of each development is assessed and
those whose impact is greater pay more: (eg using traffic surveys or water meters to gauge
the amount of use a development generates)
4. Other options?
The Draft Infrastructure Development Plan has identified that the water supply infrastructure
in South Milford needs to be improved to accommodate further development. We would
therefore ask that this is taken into consideration in preparing the Infrastructure Development
Plan, and in securing necessary contributions from the developers to bring the supply up to
standard.
The Parish Council has consulted South Milford village and the overriding opinion is that Site
002 should continue to be allocated to meet development needs during the Plan period. The
site should however only be released in a later phase, to ensure it is released after all
brownfield sites have been developed and development has come forward in Selby and the
Principle Towns.
Furthermore the community would not support the development of lots of little sites instead.
87 per cent of respondents to the consultation accepted that Site 002 should continue to be
allocated in preference to any of the other sites.
Having looked at the size of allocations that needs to be identified then we would support the
development of brownfield sites in the village and the allocation of Site 002 only during the
LDF period. Collectively these sites will deliver more development than might reasonably be
expected over the LDF period from a village the size of South Milford. We cannot see any
reason why more development should be allocated to South Milford, particularly as it has
received more than its fair share of development over the last decade in comparison to other
villages.
Furthermore, the Green Belt boundary around South Milford was reviewed through the Local
Plan process, which means the current boundary has only been adopted since 2005. PPG2
sets out that Green Belt boundaries should endure, as they are intended to be permanent.
The Council should therefore have no need to review the Green Belt boundary so soon,
particularly as to do so would undermine the objective of setting a Green Belt boundary in
the first place. Green Belt is a policy tool to protect the openness of the countryside and to
prevent urban sprawl. If the Council needs to roll the Green Belt boundary back after only
just setting it, then it would amount to allowing urban sprawl. This also means the policy
could not be viewed as working, as the boundary which was drawn only six years ago could
not be said to be permanent.
The amount of development which has been developed in South Milford has changed the
character of the village and it is causing a number of tangible problems which need to be
resolved before further development takes place. Any further development will need to
ensure such problems are not made worse and no additional problems are introduced. It is
also important to protect the character of the village and ensure it does not end up growing
to such an extent that it is viewed as a town rather than a village.
As we have previously stated in responses to other questions, the community accept the
continued allocation of Site 002. South Milford does not want to see an alternative site
allocated or any further sites allocated in addition to Site 002.
However, the community would like to see the parking situation and waiting facilities
improved at the railway station. Respondents suggested they would like to see better
lighting, information systems and better facilities for waiting at the station, as well as the
provision of more car parking. However, the village would not support additional car parking
being provided as part of the development of Site 007, as Site 007 is not adjacent to the
railway station and there is no access from Low Lane. Instead a parcel of land should be
identified in a more appropriate location with access onto Low Lane if an extension to the
parking arrangements is to be provided in the future.
The community was asked to consider a number of services and facilities which might
reasonably be secured through development of land in South Milford during the LDF period
as planning obligations. The village would most like to see a financial contribution made
towards new school placed secured as part of any future development proposal, including to
provide pre-school places. Other reasonable suggestions included financial contributions
towards improving the waiting and information facilities at the train station, as well as new
bus stops, particularly at the bottom of Sand Land, on Low Street and outside the BP Filling
Station. We would be grateful if these matters were considered in preparing a CIL charging
schedule and the Infrastructure Delivery Plan. We would also like to ask for any
development to address the water supply issue.
The village also identified a range of other facilities and services they would like to see
developed. It is our opinion that some community facilities could be provided as part of Site
002 coming forward. The SHLAA suggests Site 002 has capacity for 130 houses, which is
much more development than might reasonably be allocated to South Milford, particularly
given there are also brownfield sites which may come forward for development too.
Therefore it would suggest that some of Site 002 should be developed or reserved for
community facilities rather than purely housing. There is a huge demand for allotments in the
village, and the Parish Council would be keen to secure a site so it might provide such
facilities for the village. Site 002 would provide the perfect opportunity for land to be given to
the village for allotments.
We would however like the opportunity to discuss the opportunity with the Council separately
for new facilities and services to be provided in South Milford, with a view to preparing a
Neighbourhood Plan.
ANNEX ONE
A summary of the South Milford Parish Council community consultation results are attached
for information.
The results of the consultation were used to inform a discussion of the Parish Council in
order to formulate a view to be presented to Selby DC which truly represents the collective
views of the community. The attached summary has therefore only been provided for
information, and it is the views to each of the SADPD consultation questions which should
inform the drafting of the Site Allocations DPD. This is because the Parish Council had to
determine how best to take all the individual views into account to provide a consistent and
coherent viewpoint on behalf of the village.
ANNEX ONE
SUMMARY OF RESPONSES
Prepared by:
Kathryn Jukes
Directions Planning Consultancy
17 Otley Road
Harrogate
HG2 0DJ
T: 01423 503334
M: 07908 666530
E: kjukes@directionsplanning.co.uk
www.directionsplanning.co.uk
1.0 INTRODUCTION
1.1 Selby Council is currently considering how future development needs might be met
through the preparation of a Site Allocations Development Plan Document.
Consultation was conducted across the village of South Milford in order for the Parish
Council to understand the community’s views of Selby Council’s proposals for the
allocation of land for housing development. The intention of the consultation was for
the responses to inform the Parish Council’s response to Selby’s consultation on the
Site Allocations Development Plan Document.
1.2 Directions Planning Consultancy, in discussions with the Parish Council, designed
two consultation exercises in order to ensure everyone in the village might be
consulted and would have opportunity to respond:
• A leaflet, which included a questionnaire, was posted through the letter box of
every house in the village by Parish Council Members over the weekend of 19th
and 20th March. A few leaflets were delivered and a few late, but all houses had
been provided with a leaflet by Tuesday 22nd March. Consultees were asked to
return the completed questionnaire to one of two collection points. The first was
at the Post Office and the second at Sand Lane Stores.
• A dedicated website which included more comprehensive details of the
consultation, along with an electronic version of the questionnaire and an email
facility.
1.3 A deadline for responses to be returned was set for 7pm on 9th March in order to
focus the return of questionnaires, and allow time for responses to be considered and
a formal response to be formulated. The leaflets were however collected from the two
collection points on the morning of 10th March, whilst the questionnaire was made
available until 11pm on 9th March. A number of responses were received after the
deadline and these have been taken into account.
4.2 This appears to be at odds with Question Two where the preference for sites was
reversed with Site A being the preferred site for development under Q2 and then
being the least popular site under Q3.
8.2 If development were to be brought forward through the phased release of sites, then
there is more support for development in the next five years than in 10 to 15 years’
time. This could be considered to be at odds with the level of support for
development to take place after all brownfield sites, as this would likely take much
longer than five years to achieve across the District.