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East Riding Local Plan Proposed Submission Strategy Document and Proposed Submission Allocations Document Regulation 17(d) Consultation Statement January 2014

East Riding Local Plan Proposed Submission Strategy Document and Proposed Submission

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Proposed Submission Allocations Document
Regulation 17(d) Consultation Statement
SCI (2007) ............................................................................................................................... 8
SCI (2013) ............................................................................................................................... 9
Introduction .......................................................................................................................... 11
Introduction .......................................................................................................................... 13
5. PREFERRED APPROACH CORE STRATEGY AND POTENTIAL SITES ALLOCATIONS DEVELOPMENT PLAN DOCUMENT (2010) ................................... 17
Introduction .......................................................................................................................... 17
Introduction .......................................................................................................................... 22
Introduction .......................................................................................................................... 26
Introduction .......................................................................................................................... 31
9. PROPOSED SUBMISSION STRATEGY DOCUMENT AND ALLOCATIONS DOCUMENTS (2014) ............................................................................................................ 34
10. SA/SEA/SITE ASSESSMENT METHODOLOGY (2006-2014) ................................ 35
Introduction .......................................................................................................................... 35
Fact Checking Exercise ......................................................................................................... 36
11. DUTY TO COOPERATE AND OTHER CONSULTATION (2004-14).................... 37
12. CONCLUSION ................................................................................................................ 38
TABLE OF APPENDICIES
1. EVIDENCE OF LDF PRELIMINARY CONSULTATION (2004-7) a. Attendance list b. Activities and Results
2. EVIDENCE OF CORE STRATEGY ISSUES AND OPTIONS CONSULTATION (2008)
a. Consultation Timetable b. Consultation Contacts c. Example of Consultation Letter d. Example of Workshop/Presentation e. Examples of Press f. East Riding News g. Leaflet h. Poster i. Questionnaire j. Photos
3. EVIDENCE OF PREFERRED APPROACH CORE STRATEGY AND POTENTIAL SITES ALLOCATIONS DOCUMENT CONSULTATION (2010)
a. Consultation Timetable b. Consultation Contacts c. Example of Consultation Letter d. Example of workshop/Presentation e. Example of Display f. Examples of Press g. East Riding News h. Summary i. Poster j. Questionnaire
4. EVIDENCE OF CORE STRATEGY FURTHER CONSULTATION (2011) a. Consultation Timetable b. Consultation Contacts c. Example of Consultation Letter d. Example of Presentation/Meeting e. Examples of press f. Your East Riding g. Summary h. Poster i. Questionnaire j. Example of Visioning Workshop
5. EVIDENCE OF DRAFT LOCAL PLAN CONSULTATION (2013) a. Consultation Timetable b. Consultation Contacts c. Example of Consultation Letter d. Example of workshop/Meeting e. Display/Drop in Session f. Examples of press g. Your East Riding h. Summary i. Poster j. Questionnaire
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k. Example of Gypsy and Traveller Call for Sites Letter l. Example of Gypsy and Traveller Further Consultation Letter m. Gypsy and Traveller Further Consultation Poster n. Gypsy and Traveller Further Consultation Questionnaire o. Example of Hinterland Villages Letter p. Example of Hinterland Villages Workshop
6. EVIDENCE OF DRAFT LOCAL PLAN PROPOSED MAJOR CHANGES CONSULTATION (2013)
a. Consultation Timetable b. Consultation Contacts c. Example of Consultation letter d. Example of Drop in Session e. Example of press f. Your East Riding g. Poster h. Questionnaire
7. EVIDENCE OF CONSULTATION ON SA/SEA/SITE ASSESSMENT METHODOLOGY
a. HSAM Consultation contacts b. HSAM Consultation Letter c. CABE Workshop Report d. Example Fact Check Letter and Questionnaire
MEMBER’S SEMINARS
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1. INTRODUCTION 1.1 The East Riding Local Plan will replace the four existing Local Plans covering the former districts of Beverley (adopted in 1996), Boothferry (adopted in 1999), East Yorkshire (adopted in 1997) and Holderness (adopted in 1999) and the Joint Structure Plan for Kingston upon Hull and the East Riding of Yorkshire (adopted in 2005). Once adopted it will form the Development Plan and will be used to determine planning applications. 1.2 The East Riding Local Plan will comprise the following documents:
• Strategy Document - the main document of the Local Plan, identifying how much development will occur in different towns and villages, as well as providing planning policies on topic specific issues (such as affordable housing) that will be used to make decisions on planning applications.
• Allocations Document - which allocates sites for development (e.g. housing and retail) or protection (e.g. open space).
• The Bridlington Town Centre Area Action Plan – Adopted January 2013. 1.3 All sites and designations resulting from the Strategy and Allocations Documents are shown on the Policies Map. Separate Joint Minerals and Joint Waste Plans will be prepared with Hull City Council. 1.4 This Consultation Statement is relevant to the Strategy Document and Allocations Document. Reference to the Local Plan within this Report should be taken to mean the Strategy Document and the Allocations Document. Although they are separate Documents, much of their preparation has been undertaken in parallel and they have evolved together. Therefore it is entirely appropriate to produce one Consultation Statement that covers both Documents. 1.5 Under Regulation 19 of the Town & Country Planning (Local Planning) (England) Regulations 2012, the Council must publish the Proposed Submission Documents. Regulation 17(d) states that the Proposed Submission Documents include a statement setting out:
(i) Which bodies and persons were invited to make representations under regulation 18, (ii) How those bodies and persons were invited to make such representations, and (iii) How those main issues have been addressed in the Local Plan Document.
The purpose of this document is to fulfil the requirement above.
1.6 The Planning and Compulsory Purchase Act 2004 (The Act) requires the Council to produce a Statement of Community Involvement (SCI). The SCI sets out whom the Council will involve and how key stakeholders and the local community will be consulted in the preparation of Local Plan. The preparation of the Local Plan has reflected he requirements of the SCI. 1.7 This Report explains in chronological order the consultation process undertaken on the preparation on the Strategy Document and Allocations Document. It demonstrates that they have been prepared with the active participation of a range of consultees including residents, businesses and other stakeholders. Early engagement was carried out and consultation has been carried out at all stages of the plan making process. The evidence in this Report demonstrates that the scope of consultation and the range of techniques which have been employed exceed that required in the SCI and accord with the requirements of the Regulations. This Report highlights the consultation methods which have been employed, summarises the responses received and explains how the Local Plan has evolved as a result of consultation. Evidence to
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demonstrate the consultation is reproduced in the appendices. 1.8 When the Council began preparing the Local Plan it was under the previous Local Development Framework (LDF) system. The evidence base and earlier consultation under the LDF system fed into the preparation of the Local Plan. This Report includes references to both the LDF and Local Plan. The decision to prepare a Local Plan resulted in the name of the Core Strategy being amended to the Strategy Document. The terminology used at the time of each stage of the preparation of the LDF/Local Plan is referred to in the different sections of the Report, for example consultation that took place prior to 2012 refers to the Core Strategy, where as consultation took place after 2012 is referred to as the Strategy Document. The name Allocations Document has not changed throughout its preparation. 1.9 The consultation on the Local Plan has been a continuous process. The key stages of preparation were:
• Preliminary Consultation – November 2007 • Issues and Options Core Strategy – 28 April – 13 June 2008 • Preferred Approach Core Strategy and Potential Sites Allocations Document
Consultation - 4 May – 26 July 2010 • Core Strategy Further Consultation – 31 October - 19 December 2011 • Draft Local Plan – 5 February – 15 April 2013 • Draft Local Plan Proposed Major Changes – 16 August – 30 September 2013 • SA/SEA /Site Assessment Methodology – 2006 - 14
The Key Consultation Documents Are available to view at: http://consult.eastriding.gov.uk/portal/
2. STATEMENT OF COMMUNITY INVOLVEMENT 2.1 The Act requires local planning authorities to prepare the Local Plan in compliance with the Statement of Community Involvement (SCI). 2.2 The Council’s first SCI was adopted in March 2007. A revised SCI was adopted in January 2013. 2.3 The Preliminary Consultation was undertaken before an SCI was in place. The Issues and Options Core Strategy, Preferred Approach Core Strategy, Potential Sites Allocations Document and Core Strategy Further Consultations were undertaken under the 2007 SCI. The Draft Local Plan consultation and Draft Local Plan Proposed Major Changes consultations were undertaken under the 2013 SCI.
SCI (2007) 2.4 The SCI advocated six key principles to underpin the way community involvement in planning should be undertaken, as follows:
• Consultation arrangements are 'fit for purpose' based upon an understanding of local needs;
• Early involvement in the process to ensure the community have an input into issues and options and the potential to make a difference;
• Use of relevant methods to encourage participation by the community, including respecting hard to reach groups;
• Continuous involvement with meaningful feedback on decisions and an opportunity to see how ideas have developed through the process;
• Clear process so people know how and when they will be able to participate and the ground rules for doing so; and.
• Community involvement should be planned from the start with consideration of linkages to other community involvement processes such as the Community Strategy.
2.5 The SCI set out in Chapter 3 the various consultation methods that should be employed in the production and consideration of development plan documents at each stage of their production. These include:
• Place posters and notices at Customer Service Centres and libraries and making copies of reports available at these locations for public inspection along with consultation response forms;
• Make printed copies and CD copies of documents available at a reasonable charge; • Use local news and media; • Send letters to parish and town councils, general and specific consultation bodies,
those who asked to be kept informed of progress; representatives of hard to reach groups and statutory and also non-statutory consultees in the Council’s database;
• Devise questionnaires where appropriate, some of which should to be targeted at hard to reach groups;
• Through the Council's website, invite comments from an early stage, publicising notices, reports, revised documents and supporting information with the ability to download documents and submit feedback and consultation responses on line;
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• Arrange group meetings with parish and town councils; • Discuss Local Development Framework matters at Area Forums; • Direct notification by post or email to all those who previously made comments
informing them of the venues and web address where future reports can be viewed; • Send copies of reports to Specific Consultation Bodies; • Make copies available in all Customer Service Centres and Libraries for public
inspection; • Raise awareness and publicise the existence and purpose of Yorkshire Planning Aid
to assist and encourage involvement of local communities in the planning process; • Work together with the local strategic partnership to encourage participation and
awareness; • Encourage the participation of hard to reach groups; • Hold meetings as needed with relevant individuals or groups to explore issues in
greater detail; and • Assist in the exchanges of information.
2.6 The SCI provided details of potential consultation bodies and divided them into three categories: (i) specific, (ii) general and (iii) other consultation bodies. The SCI also set out particular interest groups that should that should be involved in the preparation of each DPD. 2.7 The SCI set out the key stages of preparation for Local Development Documents such as the Strategy and Allocations Documents. The key stages of preparation required by the SCI are shown figure 1. Figure 1: Process for Local Development Documents
2.8 Additional stages of consultation have also been undertaken on the LDF/Local Plan. This included a Preliminary Consultation, in advance of stage 1, and a Further Consultation, which was in effect a second stage 2 (Preferred Options) consultation. A Revised SCI was produced whilst both the Strategy and Allocations Documents were at Stage 2 of preparation. It was necessary to produce a revised SCI to accommodate changes to the Planning System which had occurred since the publication of the first SCI. The 2007 version of the SCI is available at: http://www2.eastriding.gov.uk/environment/planning-and-building-control/east-riding-local- plan/statement-of-community-involvement/#consultation SCI (2013) 2.9 The majority of principles outlined in paragraph 2.4, 2.5 and 2.6 are continued in the 2013 SCI but changes have been made to reflect amendments to the Council’s Consultation Strategy
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and feedback from previous consultation. The SCI sets out in Chapter 3 the various consultation methods that should be employed in the production and consideration of development plan documents at each stage of their production. Table 1 is an extracted from the SCI. The table in the SCI includes 6 Stages. Stage 2 is Publication of the Proposed Submission Documents, the remaining stages are later in the process. Only Stage 1 is relevant to this report. Table 1: How the Council will engage stakeholders and communities in the preparation of the Local Plan
Document Stage What the Council will do Stage 1: Evidence gathering and preparing a Local Plan Document
Evidence will be gathered to help prepare the document and to identify the main issues and options.
Views will be sought on what the document should contain, including through the production of and consultation on draft documents, as appropriate.
Conflicts will be explored and resolved, as far as possible.
• Write to specific, general and other consultees, who the Council considers may have an interest in the document to inform them of the subject of the document and invite representations about what the document should contain.
• Make consultation documents available at customer service centres, main libraries main libraries are in Anlaby, Beverley, Bridlington, Brough, Cottingham, Driffield, Goole, Hedon, Hessle, Hornsea, Howden, Market Weighton, Pockington, Willerby and Withernsea and on the Council's website.
• Discuss issues and options with partners and existing forums/groups, as appropriate.
• Use local media/press to increase awareness. Offer appropriate advice and information to the public as requested.
• Arrange events and workshops to discuss issues and proposals, as appropriate.
• The Council will consider all responses received when drafting the next version of the document and will make changes as required.
• Comments received will be available to view and the Council will make a response available, as appropriate.
2.10 The current SCI is available at: http://www2.eastriding.gov.uk/environment/planning-and-building-control/east-riding-local- plan/statement-of-community-involvement/ 2.11 The evidence of consultation provided within this Document will demonstrate that the preparation of the Local Plan has complied with and exceeded the provisions set out in the relevant SCI.
3. LDF PRELIMINARY CONSULTATION (2004-7)
Introduction 3.1 In June 2004 the Council wrote to specific consultees expressing the intent to produce a Local Development Framework (LDF) and expressing that they would welcome their involvement in the process. In October 2004 the Council held a series of workshops for town and parish councils. The aim of the sessions was to explain the new LDF planning system and consider issues that could potentially be considered in the LDF. Between 2004 and 2007 the Council undertook significant work of the LDF. This included:
• consultation on Issues and Options Documents for Smaller Settlements, Housing, Employment, Transport and Development Control Policies, and
• consultation on the Preferred Approach Smaller Settlements Document. 3.2 In the period 2004 - 2007 the Council, following advice from Government, intended to use the up to date Hull and East Riding Joint Structure Plan (2005) (JSP) as the strategic element of the LDF (i.e. it would act as the Core Strategy). In 2007 it became clear, following a number of Inspectors Reports into the Examination of other local authority Core Strategies, that using the Joint Structure Plan as the Core Strategy would not be appropraite. The Council therefore decided to begin the preparation of a new LDF. 3.3 In order to frontload the preparation of the Local Development Framework (LDF) the Council organised a series of consultation events with key stakeholders and specific consultees at the very early stages of plan preparation. This was planned as an opportunity for the community to get involved in the LDF process at a very early stage and to help identify the planning issues that are important in the East Riding which should be covered in the LDF. A call for sites was also made to encourage the submission of further sites for consideration as future development allocations.
Approach to Consultation 3.4 Three half-day workshops were held in November 2007, with a mix of the general public who were on the Council’s LDF consultation database, key stakeholders and specific consultees. The sessions included:
• A brief presentation about the LDF in general and the role of the Core Strategy • Three short workshop activities aimed at:
o Identifying the key issues which will need to be considered in the Core Strategy
o Prioritising the issues identified; and o Devising a vision for how attendees would like to see the East Riding in
2026. • Two interactive voting exercises were conducted, which asked attendees to indicate,
using stickers, what infrastructure and facilities the Council should require developer contributions for and what makes a village work.
3.5 The aim of the sessions was to give key stakeholders a clearer idea of what the LDF and Core Strategy would do and to highlight the key issues the Core Strategy should consider in the Issues and Options document.
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The Response 3.6 After the event the output from all activities was collated and published. People who had asked questions and left contact details were contacted and their issues responded to. 3.7 The events showed that the main issues in the East Riding, in no particular order, are:
• Climate change mitigation • Energy/environment • Preserving the East Riding’s unique character and heritage • Maintaining local character • Making and maintaining links between Hull and the East Riding socially,
economically and in planning • Ensuring effective employment land use – mixed economy, incentives to businesses • Encouraging economic growth in the right places • Ensuring the exploitation the potential of the Ports • Ensuring the co-ordination of development and infrastructure • Improvement of integrated transport • Consideration of health care provision • Concern for the ageing population • Ensuring that we build communities and not just housing • Improvements to public services and local services • Creating a good housing mix and improve housing stock • Encourage growth in villages • Enhance quality of life • Realistically assess the needs of local people as a whole • Clarity in the planning process • Take more account of local views in planning decisions
3.8 Further information on the events is shown in Appendix 1. 3.9 The results of the events allowed the Council to consider the issues that key stakeholders felt were important in the East Riding. These issues then worked their way into the Core Strategy Issues and Options Document.
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4. CORE STRATEGY - ISSUES AND OPTIONS (2008) Introduction 4.1 Following the Preliminary Consultation the Council put together an Issues and Options Document. The Document set out the main issues that had been identified as requiring coverage in the Core Strategy. It then put forward a range of options for how the Core Strategy could deal with each of the issues, asked for comments on which options were preferable and allowed for any additional comments. 4.2 The six week consultation period ran from 28th April to 13th June 2008 and involved a wide range of methods used to reach and engage with all sectors of the community. 4.3 During the consultation the Council also consulted town and parish councils on Draft Settlement Profiles. The Council had prepared draft profiles setting out the key services facilities and demographics of each town and parish. The Council wrote to all town and parish councils asking for their comments on these draft profiles and invited them to one of a series of workshops where they could be discussed. Councils were asked whether:
• The information in the profile was correct? • They could suggest any changes or improvements to the profile? • There were there any key issues or challenges that are not brought out in the profile? • They had any other information, such as a Parish Plan or a local study, which may
help to provide a better picture of the town or parish?
Approach to Consultation Informing People of the Consultation 4.4 The Council maintains a database of contacts of people and organisations who have expressed an interest in the East Riding’s LDF. In total, over 800 letters and nearly 600 emails were sent to individuals and organisations on the database to inform them of the consultation on the Issues and Options Document. 4.5 As well as informing people by letter and email, the Issues and Options Document was publicised as widely as possible. Including:
• Press articles appeared in the Yorkshire Post, East Riding Mail, East Riding News, the Beverley Guardian and other local newspapers. Posters and leaflets were placed in customer service centres, libraries, leisure centres and supermarkets.
• Online advertising took place on the Council’s intranet homepage and LSP website. • Posters were placed in customer service centres and libraries. They were also given
to Parish Councils to place on notice boards. • Leaflets were available and distributed at events.
Document Availability 4.6 The Document was available as a hard copy, on CD and online in a downloadable format. It was available to download at:
• Council’s website
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• The Limehouse interactive portal • Council’s ‘Have Your Say’ consultation website.
4.7 Hard copies of the Document were available to view in the Council’s customer service centres and libraries, as well as a few other selected locations. 4.8 Copies of the Document were sent to town and parish councils and specific consultees (e.g. Government Office for Yorkshire and the Humber, English Nature, Environment Agency, neighbouring local authorities etc). CD copies of the document were sent to members of the ‘Speak Up’ panel, a group representing ethnic minorities in the East Riding. Meetings and Events 4.9 A range of events took place as part of the consultation. Including:
• Drop in Sessions o 5 drop-in sessions took place across the East Riding where members of the
public could find out more information and to talk to planning officers. • Presentations and Workshops
o Town and parish councils were invited to one of five presentations and workshops set up within the consultation period. These were established to provide town and parish councillors with a better understanding of the Issues and Options Document and give them an opportunity to discuss some of the details and issues within a workshop situation. In all, a healthy turnout was achieved with 62 parish councils represented by 93 councillors. The workshops were interactive. Participants took part in activities around different topics that were covered by the Issues and Options paper. Each activity considered the issues surrounding that particular topic and required attendees to think about their preferred approach.
o Similar events were held with the Local Strategic Partnership (LSP) and Council colleagues, the Youth Parliament and members of ERVAS (East Riding Voluntary Action Service). Throughout the process, officers attended and presented at a number of internal and LSP group meetings.
• Settlement Profile Events o Three further events were organised for town and parish councils to
introduce Settlement Profiles. These Profiles form part of the ‘Evidence Base’ for the LDF and are an attempt to capture a picture of particular towns and villages in the East Riding. Thirty-five parish councils were represented by fifty-six councillors.
• Exhibitions/Displays o The Council also prepared exhibition boards and displays which were set up
for a week at a time in the main libraries and customer service centres. The displays aimed to raise awareness of the consultation and encourage people to respond. Officers also attended markets in Beverley, Driffield and Cottingham and set up an LDF stall where members of the public could discuss the issues within the Core Strategy. A similar exhibition was set up outside of Tesco’s in Goole. A number of these events were held on a weekend in order to reach those who work during the week.
4.10 Evidence/examples of the consultation on the Issues and Options paper is shown in Appendix 2.
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The Response 4.11 The Issues and Options consultation was very positive. It not only provided the Council with knowledge to consider when preparing the Preferred Approach document but also raised the profile of the LDF/Core Strategy. 4.12 The Council invited comments and responses to the Core Strategy under the banner of ‘Have Your Say’ to tie in with the corporate consultation approach. This approach has been maintained throughout the preparation of the LDF/Local Plan. A questionnaire response form was prepared which included all of the questions set out within the Issues and Options Document. The Limehouse interactive web-document allowed users to comment on specific paragraphs as well as questions. The Council also welcomed standard emails and letters. Feedback was taken at the various meetings and exhibitions however, it was not logged as official responses and attendees were encouraged to make a formal response to the consultation. 4.13 Over 200 people and organisations responded, translating into around 3,000 specific comments on the Issues and Options paper. 4.14 The consultation received a positive response, particularly in regard to its structure and being easy to understand. Key responses are summarised below.
• Climate Change - Development supported by the Core Strategy should not add to the impacts of climate change
• Settlement Network and scale of development – The Settlement Network should set an overall spatial approach to development, which considers the links between homes and jobs, recognising the relationship with Hull and the demographics of individual settlements. Matters such as flood risk, townscape, infrastructure requirements and important open spaces need to be balanced against the need for development.
• Rural settlements – There was a mixed response. It was considered that rural settlements should be selected for development based on their existing services and facilities. However, some wanted development to take place in their village, whilst others did not. People in some of the more sustainable rural settlements did not want any more development and those in very small, unsustainable settlements wanted more development.
• Transport – There was support for transport improvements. It was highlighted that the Strategy should address potential congestion. Support was given to improvements to walking and cycling networks. There was also support for allowing high amounts of parking with new development, though it was noted that improvements to public transport would reduce the need for car parking.
• Housing – There was general support for providing a mix of housing and the needs of first time buyers, older people and Travellers were identified as being particularly important. Respondents supported varying the affordable housing requirement across the East Riding to consider housing needs. There was general support to ensure more affordable housing is provided. Respondents generally felt that a previously developed land target of 30% was realistic, though other percentages were suggested. Many parish councils felt that low density development should be supported. It was also felt that higher density development could be supported in more sustainable locations.
• Employment – It was identified that employment development should be directed
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to towards the settlement network and strategic employment locations, with consideration given to the impact on Hull. The importance of infrastructure availability for employment development was also raised as being as important as the allocation of land. It was noted that the links between homes, jobs and the environment should be recognised. Respondees considered that there should be a flexible approach to allowing employment development in rural areas and that support should be given to the tourism and visitor industry.
• Environment - The inclusion of design and heritage policies was supported. Respondents also supported the inclusion of local landscape designations and specifically identifying settlements where separation should be maintained to avoid coalescence. Responses favoured the inclusion of a policy which offered enhancements to biodiversity. There was support to managing development in flood risk areas, management of drains and drainage issues, and ensuring that the Council prepared an SFRA. It was also suggested that areas adjacent to Hull may be required for flood storage to reduce the risk of flooding. There was a mixed response to allowing development in areas at risk of flooding, however there was some support if the development resulted in wider sustainability benefits or increased flood protection.
• Energy – There were a range of responses to renewable energy development with most identifying that such development should be supported by the Council. Respondents also favoured the use of requiring the use of the Code for Sustainable Homes and requiring developments to include the use of renewable or decentralised energy.
• Minerals and Waste – The inclusion of ‘preferred areas’ and ‘areas of search’ for minerals working were supported. Most respondents also felt that the approach to the waste management hierarchy set out in the Issues and Options Document was appropriate.
• Communities – Town and parish councils felt that communities should be able to decided whether community uses are required and whether they can be closed to make way for development, whilst developers felt that market forces should take precedent. It was felt that viable services and facilities should be protected. It was felt that developer contributions should be collected for a range of uses including open space/recreation, flood defence, transport infrastructure, drainage infrastructure, public transport, crime/safety and community facilities. It was suggested that they should be negotiated on a site by site basis.
4.15 A summary of the responses received to each issue queried in the Issues and Options Document is set out as part of the justification for each policy in the Preferred Approach Core Strategy. The Preferred Approach Core Strategy is available at: http://www2.eastriding.gov.uk/environment/planning-and-building-control/east-riding-local- plan/strategy-document/strategy-document-preparation/ 4.16 All of the comments received as part of the Issues and Options consultation and officer responses to those comments are also available at the weblink above. 4.17 Responses, which were generally factual updates, suggestions for additional context, were also received to the Settlement Profiles. Following the responses they were updated and published on East Riding of Yorkshire Council’s website. The Settlement Profiles have since been updated periodically. They are available at: http://www2.eastriding.gov.uk/environment/planning-and-building-control/east-riding-local- plan/settlement-profiles/
5. PREFERRED APPROACH CORE STRATEGY AND POTENTIAL SITES ALLOCATIONS DEVELOPMENT PLAN DOCUMENT (2010)
Introduction 5.1 Consultation on the Preferred Approach Core Strategy was undertaken jointly with the Potential Sites Allocations Development Plan Document (Potential Sites Document). Combining the two consultations aimed to increase awareness of the LDF as a whole as it was recognised that many members of the community are more active once actual sites that they can physically relate to start to be discussed. Discussing both the strategic polices and individual sites at the same time gave consultees the opportunity to influence the scale and distribution of development, as well as the location of sites within each. 5.2 Following consideration of the responses to the Issues and Options Paper the Preferred Approach Core Strategy was produced. The Strategy was split into two sections, the Spatial Strategy and Development Policies. The vision, objectives and main strategy were set out in the Spatial Strategy whist more detailed policies such as those on affordable housing, landscape character and retail were included in the Development Policies section. The range of policies reflected the comments received to the Issues and Options Consultation. For each policy, the document provided details on the original options presented and reviewed the responses to the Issues and Options consultation. Reference was also made to the Sustainability Appraisal and parts of the evidence base which were being used to provide justification for the proposed policies. In addition, each policy was accompanied by text explaining how the policy would be applied. 5.3 The Potential Sites Documents showed all of the sites in and around the settlements in the Draft Settlement Network (see Preferred Approach Core Strategy) that the Council was considering for allocation. This included sites with extant planning permission, sites put forward by landowners and developers (land bids), existing allocations, land identified in the National Land Use Database, land identified in the Urban Capacity Study and land identified in evidence based studies. At this point the Council had not made any decisions regarding which sites should be allocated and was requesting views on the appropriateness of sites. As part of this consultation the Council also asked consultees to identify any other land that they felt would be suitable for allocation. 5.4 The consultation took place between 4 May and 26 July 2010. The closing date was extended by two weeks, to give a 12 week consultation period due to the high level of interest. Approach to Consultation 5.5 Extensive public consultation was undertaken. Informing People of the Consultation 5.6 The consultation included sending letters and emails to nearly 1,700 individuals and organisations on the LDF database to inform them of the consultation. 5.7 As well as informing people by letter and email, the consultation was publicised as widely as possible. Including:
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• Press articles. A press statement was released at the beginning of the consultation this lead to articles on Look North (TV) and BBC Radio Humberside; as well as in newspapers including at least 7 articles in the Hull/East Riding Daily Mail, at least 2 articles in the Bridlington Free Press, at least one article in the Driffield Times, at least 2 articles in the Holderness/Hornsea Gazette and at least 4 articles in the Pocklington Post.
• Newsletters and Publications. Articles were included in newsletters to advertise the consultation and to inform hard to reach groups. They included East Riding Voluntary Action Service Newsletter, Equalities and Diversity Newsletter and Parish Council News. East Riding of Yorkshire Council Publications and Websites were used to raise awareness of the consultation, including a double page spread in East Riding News which was delivered to every household in the East Riding, an article in Grapevine the Council’s internal staff magazine. There may also be other publications that have picked up on the consultation that we are not aware of for example a number of parish newsletters included articles on the consultation.
• Online advertising took place on the Council’s internet homepage, intranet homepage, the ‘have your say’ website and LSP website.
• Posters to advertise the consultation and individual events were on display in all libraries and customer service centres, they were also offered to town and parish councils for them to place on their notice boards.
Document Availability 5.8 Copies of the Documents were sent to all specific consultees. The consultation Documents were also available to view in all libraries and customer service centres within the East Riding and were available on-line to download and via the interactive version. A Summary of the Documents was available on request, on-line and at events. Meetings and Events 5.9 A range of meetings and events took place as part of the consultation. They included:
• Town and Parish Council Meetings o All town and parish councils were invited to a meeting. During the
consultation officers attended 21 evening meetings/workshops with town and parish councils, which were attended by 56 Councils. 3 were public meetings (for example over 80 members of the public attended a meeting at Hutton Cranswick). The remaining were with groups of Town and Parish Council representatives or with the whole Council. The events aimed to explain the content of the document and encourage attendees to make a formal response, most included workshop activities.
• Other Meetings o Officers attended 27 other meetings/presentations, including with The Hull
and East Riding Gateway Board, the Local Strategic Partnership, Planning Committees (including 2 sub committees), Commission for Architecture and the Built Environment (CABE), a specific consultees workshop, The Humber Planning Board, North Yorkshire Development Plan Forum, Hull City Council, the NHS, agents, developers and others.
• Displays o During the consultation period there were 12 displays advertising the
consultation in libraries, customer service centres and leisure centres where
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people could look at the proposals. • Drop in Sessions
o There were 13 afternoon/evening public drop in sessions, where people could discuss the consultation with a Planning Officers. The drop in sessions were very successful and attended by over 370 people. Officers encouraged attendees to make formal responses.
• Planning Aid o Planning aid were also involved in the consultation and undertook a series of
events with hard to reach groups including young people and older people, tenants and residents associations and those with disabilities.
5.10 Further information on the consultation is available in Appendix 3. The Response 5.11 A questionnaire response form was prepared which included all of the questions set out within the Preferred Approach Core Strategy and Potential Sites Allocations Document. The Objective interactive web-documents allowed users to comment on specific paragraphs as well as questions. The Council also welcomed standard emails and letters and took feedback from the various meetings and exhibitions. Feedback at meetings and exhibitions was not logged as official responses and attendees were encouraged to make a formal response to the consultation. 5.12 In total over 1,850 formal responses were received. Of these just over 250 were received on the Preferred Approach Core Strategy. This translated into over 2,000 comments on the Core Strategy. Over 1,600 formal responses were received to the Potential Sites Document, resulting in over 6,300 comments. A broad summary of these comments is set out below: Preferred Approach Core Strategy Spatial Strategy
• Generally, the settlement hierarchy and the intention to direct development to the most sustainable locations were supported but there was no consistent view on which smaller settlements should be identified.
• The decision to discount settlements within close proximity to larger settlements was queried, as the approach did not acknowledge the role, sustainability and accessible nature of these places.
• There was general concern about the scale of growth suggested for the Rural Service Centres and Supporting Villages and the ability of infrastructure to accommodate the level of development. It was suggested that the approach needed to be more flexible to local circumstances.
• There was general support for proposals to enhance the transport system (including A1079 improvements, safeguarding land for the Beverley – York train line and multi- modal freight transport in the east – west corridor).
• The approach to dividing the East Riding into 6 sub-areas was generally supported.
Development Policies
• Housing: It was suggested that viability must be considered when setting the
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affordable housing policy. The rural exception policy was supported. It was suggested the policy requiring a housing mix should be flexible and the density of new development should depend on the surrounding character.
• Economy: There was broad support for the policies on economic development, but noting that policies should support the growth of the rural economy and promotion of tourism. The policy on retail development was considered onerous.
• Environment: There was general support for the policies in the environment chapter, including the approach to flood risk and coastal change, with minor amendments suggested. There was a mixed response to the proposal to designate the Yorkshire Wolds as an Area of High Landscape Value. It was suggested that if the renewable energy policy is to include targets then further evidence based work will be required.
• Community: There was support for the policies aimed at protecting services and facilities. It was suggested that the effect that providing infrastructure would have on the viability of development needs to be considered.
5.13 A summary of the responses received to each policy that required significant amendment following the consultation was set out as part of the justification for the policy in the Core Strategy Further Consultation document. The Core Strategy Further Consultation document is available at: http://www2.eastriding.gov.uk/environment/planning-and-building-control/east-riding-local- plan/strategy-document/strategy-document-preparation/ 5.14 All of the comments received as part of the Preferred Approach Core Strategy consultation and officer responses to those comments are available at the weblink above. Potential Sites Allocations Document 5.15 Overall, there was general support for prioritising development of previously developed land ahead of greenfield sites. There was also support for directing development towards areas within existing development limits and avoiding development on the best and most versatile agricultural land. 5.16 There was widespread concern that new development should avoid areas of high flood risk and areas where drainage problems are apparent. Sites affecting the Yorkshire Wolds Area of High Landscape Value as well as those that would lead to the coalescence of settlements were not favoured. There was widespread concern over the capacity of infrastructure such as schools, sewers, and roads to accommodate further development. 5.17 Areas of the East Riding which attracted a particularly significant number of responses were:
• Major Haltemprice Settlements • Pocklington • Market Weighton • Beverley • South Cave • Hornsea • Hedon • Bridlington
6. CORE STRATEGY FURTHER CONSULTATION (2011)
Introduction 6.1 The Core Strategy Further Consultation document was prepared following consideration of responses to the Preferred Approach Core Strategy and the completion of further evidence base work. These highlighted that a number of significant revisions would need to be made to some policies. 6.2 The Consultation was focused on the significant revisions. They included amendments to the East Riding’s settlement network, scale and distribution of residential development, including amending the approach to recognise that Hinterland Villages, Primary and Secondary Rural Service Centres, and Rural Villages provide a sustainable option for limited development. The Document also revised as the scale of employment land, and provided new and amended place statements for settlements in the East Riding. In addition the policies on the provision of affordable housing and open space had not been fully incorporated in to the Preferred Approach Core Strategy and therefore needed to be consulted on. 6.3 Responses to the remaining polices in the Preferred Approach identified that only minor amendments were necessary, mainly to the structure and layout. It was considered that these amendments could be made without additional consultation and therefore these policies were not included in the Further Consultation. 6.4 The Further Consultation Document set out a summary of the responses to the Preferred Approach Core Strategy and if appropriate the Issues and Options consultation, revised draft policy wording, text on how to apply the revised policy and a justification for the revised approach. It also explained any alternative approaches that had been considered following the Issues and Options consultation. The consultation took place between 31 October and 19 December 2011. 6.5 In preparation for the Further Consultation the Council undertook workshops with town councils and other interested groups. The Preferred Approach Core Strategy had included statements to set out how the Major Haltemprice Settlements and Principal Towns would change over the plan period. The Further Consultation also included Place Statements for Local Service Centres. Visioning workshops were held in a number of towns where new place statements were being prepared. The results of the workshops, which were supported by the Planning Advisory Service (PAS), were fed in to the visions included in the Core Strategy Further Consultation. Approach to Consultation 6.6 Extensive public consultation was undertaken on the Further Consultation. Informing People of the Consultation 6.7 Over 3,500 letters and emails were sent to those on the LDF database to inform them of the consultation. In addition, a range of meetings and events took place as part of the consultation. They included:
• Press Articles. The media were again heavily involved in the consultation. A press statement that explained the document and targeted press statements that focussed on the implications for more localised areas were released. This lead to articles on
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BBC Radio Humberside and in newspapers such as the Hull Daily Mail, Yorkshire Post, and local newspapers such as the Beverley Guardian and the Holderness Gazette.
• Newsletters and Publications. Articles were included in newsletters to advertise the consultation and to inform hard to reach groups. Newsletters included the East Riding Voluntary Action Service Newsletter, Equalities and Diversity Newsletter, and Parish Council News. Advertising also included articles in Your East Riding (a magazine delivered to every household in East Riding) and Grapevine (an internal, staff magazine).
• Websites. The consultation was advertised on the Council’s website, including on the home page, the ‘Have Your Say’ website and on the intranet.
• Posters were used to advertise the consultation. They were on display in all libraries and customer service centres. They were also available to download on the Council’s website and copies were offered to town and parish councils.
Document Availability 6.8 The Document was available as a hard copy, on CD, online in a downloadable format. It was available to download at:
• Council’s website • The Objective interactive portal • Council’s ‘Have Your Say’ consultation website.
6.9 Hard copies of the Document were available to view in the Council’s customer service centres and libraries. Electronic copies of the document were sent to specific consultees. Town and parish councils were sent a hard copy of the document. 6.10 A Summary of the Document was available on the internet, on request and at consultation events. Summary documents were sent to all specific consultees and town and parish councils. Meetings and Events 6.11 A number of meetings and events were held during the consultation. They included:
• Town and Parish Council Meetings o All town and parish councils were invited to attend one of 6 meetings to
discuss the content of the consultation document, the implication of the changes to the Core Strategy and to encourage them to make a formal response. There was good attendance with 86 Councillors attending. Meetings were also held with individual town/parish councils, as requested, including Beverley, Hornsea, Woodmansey and Holme on Spalding Moor Councils.
• Other Meetings o Reports were also presented to a number of boards and meetings to ensure
consultees were aware of the wide ranging implications of the Core Strategy. This included Planning Committee and the 2 Planning Sub Committees, the Local Enterprise Partnership/Humber North Bank Sub-board, Renaissance Partnerships, agents and developers, the Rural Partnership, the Local Strategic Partnership Board and Sustainable Communities and Transport Action Group (part of the LSP). Meetings were offered to all neighbouring
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authorities and specific consultees. • Drop in Sessions
o 14 afternoon/evening public drop in sessions were held at customer service centres and libraries, where members of the public could talk to an officer about the consultation document. There was a mixed level of attendance with between 4 and 50 people attending in different locations.
6.12 Evidence of the Further Consultation can be found in Appendix 4. The Response 6.13 Consultees were able to respond to the consultation in a number of ways. This included a questionnaire (available in hard copy and electronic format); an interactive (website) version of the consultation document which allowed comments to be made against each paragraph and/or question, through the ‘Have Your Say’ part of the website, and via letter and email. The Council also discussed matters with consultees at drop in sessions and meetings. Feedback received at meetings and exhibitions were not logged as official responses and attendees were encouraged to make a formal response to the consultation. 6.14 The consultation resulted in over 1,050 formal comments from over 200 individuals and organisations. 6.15 The results of the consultation on the Further Consultation Core Strategy were broadly in line with those received during the previous consultation on the Preferred Approach Core Strategy; for example, the majority supported the Vision and Spatial Strategy, if with some amendment. On the other hand, there were clearly some conflicting views between the different respondents, reflecting their particular interests and responsibilities. For instance, where agents and land owners wished to see more development than local residents. It is in the nature of the LDF/Local Plan preparation process that such contrasts of opinion will occur. They were identified as early as possible and attempts have been made by the Local Planning Authority and the interested parties to reconcile their differences. A more detailed summary of the responses are set out below. Spatial Strategy 6.16 There was general support for the Place Statements. However, some respondents considered that it was not clear how the broad aspirations set out in the statements would be delivered and a number of minor amendments were suggested.
6.17 There was general support for amendments to the settlement network and scale and distribution of development. Nearly all agents and developers welcomed the move to increase housing growth but suggested the evidence supported a much higher figure. Many cited the Government’s household projections as their preferred growth scenario. There were also suggestions that the amount and location of development should be market rather than plan led. From others, there were mixed views whether the right amount of housing was being proposed. 6.18 Responses also required further clarification on points, particularly contingency plans, the distinction between different tiers of the settlement network and the scale of development that would be suitable in different tiers of the network. There were also some calls for Rawcliffe to be re-instated as a Secondary Rural Service Centre although the Environment Agency supported its omission. There were varying views on the role of individual villages within the Settlement
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Network and a number of requests for a list of Rural Villages to be explicitly set out in the document. 6.19 There was general support for the re-instatement of development limits in rural areas and recognition of the need to support development (particularly infill) within Rural Villages. There was general support for the removal of the ‘local needs’ condition/clause in rural locations. There were also some suggestions for other services and facilities to considered when identifying Rural Villages and some responses suggested that market housing should be acceptable in the countryside. 6.20 There was general support for the revised approach to employment land, which increased that amount of employment land proposed in the Plan. Respondents emphasised the importance of maintaining a flexible supply of land for different types of employment uses. Although there were some concerns that it could result in an oversupply of employment land. The significance of the M62/A63 corridor was highlighted, which should be identified as a key location for employment development. The opportunity presented by the renewable and low carbon energy sectors was highlighted, and the potential for land at Hedon Haven to accommodate businesses in these sectors was recognised. The importance of considering the impacts of employment development, such as on transport and heritage, was also highlighted. Development Policies 6.21 Policies on affordable housing and open space were the only Development Policies included in the consultation document. 6.22 In relation to the policy on affordable housing, there was broad support for allowing affordable housing in rural areas and allowing an element of market housing. There was a mixed response to the percentage requirements and thresholds set in the policy, as well as some detailed comments on the evidence base used to inform them. Splitting the East Riding into smaller areas with different requirements was generally supported, although there were some reservations about the lower thresholds for rural area. There was strong support for considering economic viability in the policy and some comments noted the relationship between the Community Infrastructure Levy (CIL) and affordable housing requirements. There were also questions on how the provision of affordable housing would relate to the general housing requirement for villages. 6.23 In relation to the policy on open space reponses emphasised the importance of keeping the evidence base (the Open Space Audit) up to date, in order to maximise the policy's effectiveness and suggested that further detail was required to explain the Open Space Standards. Some respondents expressed concern that development could take place on open spaces that are deemed surplus to requirements. It was also suggested that other types of open space could be covered by the policy. Developers and agents argued the policy should allow for more flexibility, for example, certain types of residential development might not require open space. 6.24 All of the comments received as part of the Core Strategy Further Consultation and officer responses to those comments are available at: http://www2.eastriding.gov.uk/environment/planning-and-building-control/east-riding-local- plan/strategy-document/strategy-document-preparation/ 6.25 The comments have been considered when producing the Draft Strategy Document. The comments mainly resulted in changes to the structure and presentation of policies and minor terminology and wording changes, largely to the supporting text.
• Comments received to both the Preferred Approach and Further Consultation Core Strategies;
• Completion of new Local Plan evidence, and • Changes to national planning policy introduced through the National Planning Policy
Framework (NPPF). 7.3 The changes focused on revisions that sought to improve the clarity of the Strategy Document and its relationship to other parts of the Local Plan. Amendments included simplifying the settlement network, increasing the housing requirement and revising the distribution of development to give greater consideration to the risk of flooding. 7.4 Part of simplifying the settlement network included amending the approach to Hinterland Villages which had first been included in the Core Strategy Further Consultation. The proposed amendment was due to significant comments being received to the Further Consultation which identified a number of concerns to the approach, such as comments questioning how Hinterland Villages were different to Primary and Secondary Rural Service Centres and also questioning the scale of development that would be appropriate. Prior to the consultation on the Draft Local Plan the Council wrote to parish councils whose area included the proposed the new Hinterland Villages and to the Environment Agency. The letters included a Briefing Note which set out a revised approach to small settlements, merging Secondary Rural Service Centres and Hinterland Villages into one category, Primary Villages. The Note included a proposed methodology for identifying the settlements and explained that the approach was being simplified to bring it in line with the approach to other villages. The Note also included two draft policies and sought comments on them. A meeting was held with the parish councils in April 2012 and 5 responses were received. The responses were taken into account when drafting the Draft Strategy Document. 7.5 With regards to the Allocations Document, a number of additional land bids had been submitted to the Council for consideration either as responses to or following the Potential Sites Consultation. Approximately 1,990 land bids had been received and were considered through the preparation of the Draft Allocations Document. In most settlements more land had been submitted for consideration than is required for allocation in the Local Plan. Consequently, site assessments were undertaken to identify those sites that would minimise any negative impacts. Where appropriate, information received in response to the consultation was investigated as part of the site assessment. The Draft Allocations Document showed the 212 sites that the Council proposed to allocate alongside the 1224 sites that had been rejected. In some cases multiple adjacent land bids were joined together to create one, more developable site. This was the first
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time that the Council had shown the sites it intended to allocate. The Draft Allocations were shown on the Draft Policies Map. 7.6 Prior to the consultation, in September 2012, the Council undertook a call for Traveller Sites. This involved writing to Gypsies and Travellers to ask if they were aware of any land that may be suitable for future sites. A specific consultation document on Gypsy and Traveller sites, the Gypsy and Traveller Sites Further Consultation, was also published as part of the Draft Local Plan. It identified additional options for the location of Traveller sites and showed a preferred option. Approach to Consultation 7.7 Extensive public consultation was undertaken on the Draft Strategy and Allocations Documents for 10 weeks between 5 February 2013 and 15 April 2013, this included a 2 week extension due to the level of interest in the Plan. Informing People of the Consultation 7.8 Consultation included sending letters and emails to approximately 4,000 individuals and organisations on the Local Plan database to inform them of the consultation. 7.9 The consultation was also advertised through:
• Press articles. The media were heavily involved in the consultation. Press releases targeted to specific areas of the East Riding were issued at the beginning and throughout the consultation. These led to numerous articles in the Yorkshire Post, Hull/East Riding Daily Mail, Beverley Advertiser, Beverley Guardian, Bridlington Free Press, Driffield Times, Goole Times, Holderness/Hornsea Gazette, Pocklington Post. The consultation has also featured on BBC Radio Humberside and Viking FM Radio.
• Newsletters and Publications. Articles were included in newsletters to advertise the consultation and inform hard to reach groups. They included East Riding Voluntary Action Service Newsletter and Parish Council News. East Riding of Yorkshire Council Publications and websites were used to raise awareness of the consultation, including articles in the winter and spring editions of Your East Riding, the replacement for East Riding News, which is delivered to every household in the East Riding, an article in Grapevine the Council’s internal staff magazine.
• Websites. The consultation was advertised on East Riding of Yorkshire Council intranet and internet, including a link in the top ten questions on the Council’s home page. There was also a description and link to the documents on the ‘have Your Say’ pages of the Council’s website.
• Posters to advertise the consultation and individual events were on display in main libraries and all customer service centres, they were also offered to town and parish councils for them to place on their notice boards.
7.10 Finally, many residents became aware of the consultation through word of mouth and through various action/interest groups that have been set up. Some of these groups have used leaflets, posters, placards and social media, including Facebook and Twitter to express their views and disseminate information. Various town and parish councils also publicised the consultation through their newsletters or through questionnaires.
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Document Availability 7.11 The Documents were available as a hard copy, on CD, online in a downloadable format. They were available to download at:
• Council’s website • The Limehouse interactive portal • Council’s ‘Have Your Say’ consultation website.
7.12 Hard copies of the Documents were available to view in the Council’s customer service centres and libraries. Town and parish councils were sent a copy of the Draft Strategy Document and the relevant parts of the Draft Allocations Document. 7.13 In addition a Summary Document was prepared, setting out the key content of the draft Local Plan and made available on request and at events and all documents were available to view in the main libraries and customer service centres. Meetings and Events 7.14 The Council hosted a number of events during the consultation. They included:
• Town and Parish Council Meetings o All town and parish councils were invited to a meeting. During the
consultation officers attended 25 evening meetings with town and parish councils, which were attended by 70 Councils. Some of these were public meetings where for example over 200 members of the public attended a meeting in Anlaby, 75 members of the pubic attended a meeting in Cherry Burton, 40 members of the public attended a meeting in Willerby and 25 members of the public attended a meeting in Bempton. The events aimed to explain the content of the document and encourage attendees to make a formal response.
• Other Meetings/Presentations o Officers also attended 34 other meetings/presentations, such as with the
Local Enterprise Partnership, Hull and East Yorkshire Local Nature Partnership, East Riding Biodiversity Partnership, developers and agents, Rural Partnership, Local Strategic Partnership, Beverley Civic Society and various Renaissance Partnerships.
• Displays o During the consultation period there were 14 displays advertising the
consultation in libraries and customer service centres where people could look at the proposals.
• Drop in Sessions o There were 19 afternoon/evening public drop in sessions, where people
could discuss the consultation with an Officer. The drop in sessions were very successful and attended by over 1,100 people. This included two Elected Member organised drop in sessions in Beverley and one in Cottingham and one drop in session in Snaith organised by the Town Council. Officers discussed the content of the consultation document and any concerns members of the public had. They encouraged attendees to make a formal response.
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7.15 Further information on the consultation is available in Appendix 5 The Response 7.16 Consultees were able to respond to the consultation in a number of ways. This included a questionnaire (available in hard copy and electronic format); an interactive (website) version of the consultation document which allowed comments to be made against each paragraph and/or question, through the ‘Have Your Say’ part of the website, and via letter and email. The Council also discussed matters with consultees at drop in session and meetings. Feedback received at meetings and exhibitions were not logged as official responses and attendees were encouraged to make a formal response to the consultation. 7.17 In total over 8,700 formal responses were received to the Draft Local Plan consultation. This included over 1,500 in relation to the Draft Strategy Document, over 6,300 comments in relation to the Draft Allocations Document and over 800 comments to the Gypsy and Traveller Sites Further Consultation. Of the responses received to the Draft Allocations Document approximately 100 were submitted as new land bids. These are new sites that are suggested for inclusion in the Local Plan by someone with an interest in the land, such as the land owner, a planning agent or a potential developer. 7.18 A broad summary of the main responses to the Draft Local Plan are set out below: Draft Strategy Document 7.19 There was general support for many of the policies in the Draft Strategy Document. However, the largest number of comments focused on the proposed scale and distribution of development, in particular housing development. This included a wide variety of comments that suggested alternative levels of development that should be planned for over the period to 2029, or opposed the level of development identified for a particular settlement. These comments mirrored similar comments received to both the Preferred Approach and Further Consultations. 7.20 A review of responses to the Draft Strategy Document identified that some elements of the Local Plan evidence base needed to be updated, for example to take account of newly published data. This included the Local Housing Study, which models the latest national projections of population and housing growth, the Employment Land Review and parts of the East Riding Infrastructure Study. There were also a number of more specific comments received. 7.21 All of the comments received as part of the Draft Strategy Document consultation and officer responses to those comments are available at: http://www2.eastriding.gov.uk/environment/planning-and-building-control/east-riding-local- plan/strategy-document/strategy-document-preparation/ Draft Allocations Document 7.22 A review of the responses to the Draft Allocations Document identified that there was general support for prioritising development of previously developed land ahead of greenfield sites. There was also support for directing development towards areas within existing development limits and avoiding development on the best and most versatile agricultural land. 7.23 There was widespread agreement that new development should avoid areas of identified high flood risk. Sites affecting the Yorkshire Wolds Important Landscape Area and those that would
• Major Haltemprice Settlements • Beverley • Bridlington • Elloughton-cum-Brough • Hornsea • Pocklington • Stamford Bridge • Swanland • Preston
7.25 The responses to the consultation included landbids suggesting that additional sites be considered for allocation, responses highlighting issues with sites that the Council had previously been unaware of and suggestions that some of the issues with rejected sites could be overcome, sometimes supported by evidence. These comments were considered by officers and where appropriate further investigation was undertaken. Comments and investigation led to a number of sites being considered or reconsidered against the Site Assessment Methodology. This in turn led to a revision of the SA/SEA and a reconsideration of whether the Draft Allocations were the most appropriate to allocate. It also led to consideration of whether some small amendments were necessary to the scale and distribution of development in the Draft Strategy Document. 7.26 All of the comments received as part of the Draft Allocations Document consultation, including the Gypsy and Traveller consultation, and officer responses to those comments are available at: http://www2.eastriding.gov.uk/environment/planning-and-building-control/east-riding-local- plan/allocations-document/potential-sites-consultation/
8. DRAFT LOCAL PLAN PROPOSED MAJOR CHANGES (2013) Introduction 8.1 Following consideration of the responses to the Draft Local Plan, including responses to the Gypsy and Traveller Sites Further Consultation, it was identified that a number of changes needed to be made to the Draft Local Plan. The majority of the changes were relatively minor and could be incorporated through the preparation of the 'publication' version of the Local Plan. However, a more limited number of major changes were suggested. These major changes were subject to a further public consultation. The changes largely related to the Draft Allocations Document, although there are a small number of changes to the Draft Strategy Document and as a result of the Gypsy and Traveller Sites Further Consultation. Changes included:
• Re-designating Keyingham as a Rural Service Centre • Removing the future housing requirement for Easington • Identify Buckton and Carnaby as Villages • A total of 71 major changes to the Draft Allocations Document, which relate to 25
settlements. Approach to Consultation 8.2 Consultation on the Proposed Major Changes took place for a 6 week period between 16 August and 30 September 2013. Informing People of the Consultation 8.3 Consultation included sending letters and emails to approximately 7,500 people and organisations whose details were on the Local Plan database to inform them of the consultation.
8.4 The general public were informed of the consultation through an extensive advertising campaign. This included:
• Press Articles. Press releases were issued which led to numerous articles in the Yorkshire Post, Hull/East Riding Daily Mail, Beverley Guardian, Driffield Times & Post, Pocklington Post and The York Press. The consultation has also featured on BBC Radio Humberside, Yorkshire Coast Radio and Look North.
• Newsletters and Publications. Including East Riding Voluntary Action Service Newsletter and Parish Council News. The consultation was advertised in Your East Riding (Autumn 2013),
• Websites. The consultation was advertised on East Riding of Yorkshire Council intranet and internet, including a link on the homepage top 10 questions, and on the ‘Have Your Say’ pages of the website.
• Posters were displayed in all libraries and customer service centres and also offered to town and parish councils.
Document Availability 8.5 The document was available as a hard copy, on CD, online in a downloadable format. It was available to download at:
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• Council’s website • The Objective interactive portal • Council’s ‘Have Your Say’ consultation website.
8.6 Hard copies of the Document were available to view in the Council’s customer service centres and libraries. Town and parish councils were sent the relevant sections of the document. Meetings and Events 8.7 As part of the consultation a number of meetings and events were held. They included:
• Town and Parish Council Meetings o Officers offered to meet with town and parish councils and specific
consultees. This resulted in meetings with 7 town/ parish councils. • Other Meetings
o The Council also attended 7 other meetings such as with the Local Enterprise Partnership and Local Strategic Partnership. In addition 9 displays were erected in libraries and customer service centres to increase public awareness of the consultation and allow people to view visual representations of the proposed major changes.
• Drop in Sessions o 10 afternoon to evening public drop in sessions were also held and attended
by over 600 people. Officers discussed and explained the changes that were proposed. Attendees were encouraged to make a formal response to the consultation.
8.8 Evidence of consultation on the Proposed Major Changes is set out in Appendix 6. The Response 8.9 Consultees were able to respond to the consultation in a number of ways. This included a questionnaire (available in hard copy and electronic format); an interactive (website) version of the consultation document which allowed comments to be made against each paragraph, through the ‘Have Your Say’ part of the website, and via letter and email. 8.10 Over 600 responses have been received to the consultation, which are all available to view from the Council's consultation portal, and predominantly relate to changes to the Draft Allocations Document.
8.11 Of those comments received to the Draft Strategy Document, six comments were received in respect of Keyingham’s proposed role as a Rural Service Centre, which are largely in support of the change. One response suggested that North Ferriby should also be a Rural Service Centre. Likewise, there has been little response in respect of removing the future housing figure for Easington with only one comment (no objection). The proposal to classify Buckton and Carnaby as Villages has also attracted few comments (four and six comments respectively). These have been either ‘no objection’ or are ‘land bids’, where a consultee is putting forward their land for consideration.
8.12 A number of the proposed major changes were welcomed, particularly where a proposed allocated site has been removed, or an alternative site has been put forward. For those allocations that previously attracted a very high level of objection, and have now been removed (e.g.
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COT3/3a/39, PRES7) or reduced in size (e.g. HOW9), there was a substantially lower level of response received. 8.13 Those changes to the site allocations that generally received a supportive response included:
• Anlaby, Willerby, Kirk Ella – AWK3 – Land off Lowfield Road (deleted allocation) • Bridlington – BRID30 – Land at Pinfold Lane (new allocation) • Cottingham – COT3/3a/39 – Land South of the Garth/Abbots Walk (deleted
allocation) • Stamford Bridge – SMB4/5 – Land South and West of Reckondales Field (deleted
allocation) • Stamford Bridge – SMB7/8 – Land West of Catton Road (deleted allocation)
8.14 For some of the changes there was a more mixed response. In some instances objections were received to a proposed allocation that replaced a previous allocation in another part of the settlement. Objections have also been submitted on behalf of some landowners to the proposed removal of their site. In addition, some responses welcomed an amended (often smaller) allocation, but felt that it did not go far enough and should be rejected in its entirety. Examples of proposed sites where there was a mixed response, include:
• Cherry Burton - CHER2 - Land on Etton Road (reduce allocation size) • Hessle – HES11/ HES12 – Land at Hessle Mount (amend allocation boundary) • Hessle – HES16 – Land North of Boothferry Road (new allocation) • Beverley – BEV47 – Land South of Holme Church Lane (new allocation)
8.15 Many of the objections raised through the consultation have concerned the following sites:
• Bridlington – BRID51 – Land South of Woldgate (Gypsy and Traveller site) (new allocation)
• Bridlington - CAR3 - Land off Moor Lane (new allocation) • Cherry Burton – CHER3/6 – Land off Canada Drive (new allocation) • Cherry Burton – CHER5/7 – Land at Manor Farm, Highgate (new allocation) • Cottingham – COT1 – Land South of Castle Road (increase allocation size) • Hutton Cranswick – CRA12 – Land South of The Green (new allocation) • Kilham – KIL7 – Roanne Nurseries and Land East of Driffield Road (increase
allocation size) • North Cave – NCA4 – Land North of Everthorpe Road (new allocation) • Preston – PRES2 – Land South of Abbey Lane (new allocation) • Snaith – SNA8/12 – Land East of Butt Lane and South of A1041 (new allocation) • Snaith – SNA3/9 – Land South of Punton Walk (reduce allocation size) • Stamford Bridge – SMB2/3 – Land South of A166 (new allocation)
8.16 A smaller number of responses were received to other sites. 8.17 All of the comments received as part of the Proposed Major Changes consultation and officer responses to those comments are available at: http://www2.eastriding.gov.uk/environment/planning-and-building-control/east-riding-local- plan/allocations-document/potential-sites-consultation/
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10. SA/SEA/SITE ASSESSMENT METHODOLOGY (2006- 2014) Introduction 10.1 Sustainability Appraisal/Strategic Environmental Assessment and Habitat Regulations Assessment (SA) have been undertaken alongside each stage of consultation on the Strategy and Allocations Documents. The SA Documents have been available to view and comment on alongside the Local Plan Consultation Documents. 10.2 In addition to the consultation outlined above additional engagement was undertaken on the preparation of a Site Assessment Methodology (SAM). The Site Assessment Methodology (SAM) sets out a series of social, economic and environment questions which have been used to assess and compare in a consistent manner all potential allocations. This has ensured that the most appropriate sites are allocated for development. The SAM has been used as a basis for the Sustainability Appraisal for the Allocations Document. Preparation of the Site Assessment Methodology 10.3 An initial Housing Site Assessment Methodology (HSAM) was published for consultation in 2006. Letters and emails were sent to nearly 1,100 consultees. Almost 600 comments were received on the draft and helped to influence the final HSAM which was published by the Council in May 2007. The HSAM was produced as part of the evidence base for the Housing Development Plan Document, which was not progressed beyond Issues and Options. Following the restructuring of the LDF, it became necessary to revise the HSAM to make it applicable to a wider range of types of development, including retail and employment and to ensure that it fulfilled the requirements of SA. 10.4 A draft Site Assessment Methodology (SAM) was published for public consultation, alongside the Potential Sites Allocations Document in May 2010. A series of 39 draft questions were included in the document. They were intended to be used to assess potential allocations. The document received 40 comments during the consultation. A summary of the comments is set out below:
• There is a need to assess how each site will deliver the settlement strategy and vision, • The document should reflect the terminology given in national policy. • The usability of the document needs to be improved with the use of plain English and
less ‘jargon’.
10.5 Following the consultation the Council undertook discussions with relevant internal and external experts regarding the questions in the SAM. This included discussions with, for example, the Environment Agency, the School’s Authority and the Highways Authority. The Council also held a meeting with developers and agents in November 2010 to discuss the methodology. 10.6 The preparation of the SAM also included a number of workshops with town councils and other local stakeholders. The workshops were supported by CABE and were aimed at developing the methodology and applying it to test sites. The workshops particularly focussed on the design elements of the methodology and were focussed on two particular towns.
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10.7 The final SAM was adopted by the Council in March 2011. It included a series of 33 questions. A briefing note, setting out how the SAM relates the Sustainability Appraisal and how the objectives of the Sustainability Appraisal are considered through the questions in the SAM, was also prepared. The SAM and briefing note are available to view at: http://www2.eastriding.gov.uk/environment/planning-and-building-control/east-riding-local- plan/allocations-document/draft-allocations-document-consultation/#assessed Fact Checking Exercise 10.8 Following the adoption of the SAM the Council assessed all of the land bids that had been received against the SAM and undertook a ‘fact checking’ exercise with land bidders (i.e. those who had submitted the site for potential allocation) and the relevant town and parish councils. This fact checking exercise was undertaking for all those settlements where it was proposed to allocate sites. The objective of the exercise was not to make any decisions on which sites may (or may not) be put forward as the preferred sites for allocation but to ensure that the sites had been assessed fairly and correctly in accordance with the SAM and in the light of all relevant available evidence and knowledge. 10.9 Therefore, though the Council had prepared an Individual Site Assessment sheet for each site in accordance with the SAM, it had deliberately not sought to answer questions relating to deliverability (Q31 - 33). However, the fact checking response form included four specific questions asking whether the land bidder know of any insurmountable constraints to development on the site, whether there were any ownership constraints and whether the site was developable within 5 and 15 years. 10.10 Land bidders and town/parish councils were asked to consider the assessments and comment, where necessary, on the accuracy of these in respect of each relevant SAM question and respond back with their comments and if relevant why the assessment was considered to be incorrect for any particular site or question. 10.11 Over 750 responses were received to the fact checking exercise. The responses were used to update the site assessments. In some cases it was necessary to seek professional advice from specialists in a particular field such as conservation, highways or flood risk in order to update the assessments. 10.12 Evidence of the ‘fact checking’ exercise is available in Appendix 7. Site Assessment Methodology Update 10.13 The Site assessment Methodology was subject to a small number of minor amendments in January 2014. This was necessary to improve consistency, accuracy and to reflect the NPPF. 10.14 The site assessments have been incorporated in to the SA for the Allocations Document and have been updated as necessary following both the Draft Allocations Document and Proposed Major Changes consultations.
11. DUTY TO COOPERATE AND OTHER CONSULTATION (2004-14)
11.1 In addition to the formal activities at each stage of plan making, the Council has ensured that residents and stakeholders have remained informed and engaged in the intervening periods. 11.2 The Council’s website is continually updated with relevant evidence and consultation documents uploaded. A briefing note, providing an update on the preparation of the Local Plan and the associated evidence base, has been prepared by the Council and updated on the website bimonthly since August 2009. Since Spring 2011 the Council has also produced a periodic newsletter, which has been sent to all contacts in the Local Plan database (whom the Council have an email address for). 11.3 There have also been regular meetings with other Local Authorities, town and parish Councils and key consultees when necessary, to attempt to gain consensus on the approach before each formal consultation stage. In some cases this also included additional opportunities to comment on draft policies, and creating or participating in steering groups for evidence based work and area based groups as appropriate. Ongoing liaison over the preparation of the Local Plan has continued with all statutory consultees including the Environment Agency, English Heritage, Natural England and the Environment Agency 11.4 The Council has also engaged with town and parish councils regarding neighbourhood planning. This has led to:
• Neighbourhood Plan Areas being designated for Cottingham and Woodmansey Village.
• Ongoing consultation on Neighbourhood Area Applications for North Cave, Pocklington and Wawne. Consultation ends on 24 February 2014.
• Completed consultation on Neighbourhood Plan Area Applications for Allerthorpe, Market Weighton and Sutton Upon Derwent. It is expected that the Neighbourhood Areas will be recommended for designation by Full Council in February 2014.
11.5 No Neighbourhood Plans have been adopted in the East Riding. Woodmansey Parish Council has indicated their intention to include allocations polices in their Plan. 11.6 The Council has ensured that Elected Ward Members have been engaged in the development of the Local Plan. This has included various correspondence, meetings and Member’s Seminars. Details of Member’