The Ryedale Plan: Local Plan Sites Document Examination
The above links to the document I submitted to the Planning Inspector, Mrs Caroline Mulloy, during the Ryedale Plan: Sites Allocation Document – Public Hearing in September / October 2018. The document is on the Ryedale Plan website.
As you will see, my submission is brief (only 9 pages plus a single page of references) and relates to topics including: the increase in traffic congestion caused by the over-development of Malton and Norton, the reduction in the quality of life of the existing and future residents of the twin towns and the cumulative impact of new developments on the air quality in Malton (I provide planning document reference numbers) and the wider impact of the Ryedale Plan on the vitality and long-term sustainability of Ryedale’s rural communities.
Ryedale District Council’s written response to my submission was uploaded to the Ryedale Plan website (Examination Page) on 17 October 2018. I have made a few comments already (when I choked on my coffee) but will add more in due course.
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The Ryedale Plan: Local Plan Sites Document Examination
RDC Response to further information provided by Mr S. Thackray
Over the course of the examination hearing sessions, Mr Thackray submitted additional information to be considered as evidence. The Council confirmed that it would have no objection if the additional information was accepted and considered as part of the examination process. It is understood that Mr Thackray declined the opportunity to have the additional information discussed at an additional hearing session.
To that end, the Council has prepared a brief written response to the additional material.
The additional information consists of:
A report on the predicted impacts on pollutant emission associated with a proposed heavy commercial vehicle restriction over Norton level crossing.
A written submission embellishing [great word] the representation made by Mr Thackray when the plan was published, together with additional/new representations.
[embellish: make (something) more attractive by the addition of decorative details or features. “blue silk embellished with golden embroidery”, make (a statement or story) more interesting by adding extra details that are often untrue.]
Report: Proposed heavy commercial vehicle restriction over Norton level crossing – Predicted Impacts on Pollutant Emissions.
The above report was prepared by Ryedale District Council.
The report was produced by the Council’s Environmental Protection Officer, a member of the Environmental Health team. The assessment was undertaken in conjunction with North Yorkshire County Council. The County Council being the Local Highway Authority which has the power to introduce a vehicle weight restriction.
The assessment provided evidence of the predicted impact of a Heavy Commercial Vehicle (HCV) restriction at the crossing. The assessment methodology was the ‘Emissions Factors Toolkit’ – a nationally recognised model provided by the Department for Environment, Food and Rural Affairs (DEFRA). Traffic flow and fleet composition used in the assessment was existing/observed traffic flow data, with flows adjusted to take account of the removal of HCV’s from parts of the internal network. All data inputs were agreed with NYCC.
The report concluded that the HCV restriction would have a positive impact on air quality within the Malton Air Quality Management Area [but increase traffic volume]. The assessment considered the impact of the restriction in relation to observed traffic flows over a twelve hour period.
In this respect, the assessment is not evidence which the Local Planning Authority can use or rely on as evidence to support the plan-making process [because it shows a bad outcome] as it does not take into account background traffic growth or future development requirements/local plan growth [all of which will make matters worse].
The air quality assessment supporting the Local Plan is the SYSTRA report (Malton and Norton Air Quality Assessment. Local Plan Assessment and Air Quality Action Plan Recommendations). This report uses two modelling techniques – an atmospheric dispersion model to predict air quality concentrations at specific locations and an assessment tool to provide estimates of changes in emissions cumulatively across links in the road network.
(The SYSTRA report confirms that the version of the assessment tool used is consistent with the version of the DEFRA Emissions Factors Toolkit used by the Council to assess the impact of the HCV restriction). The SYSTRA report was specifically commissioned to assess the impact of additional development and traffic in the local road network over the plan period. The traffic data (trip numbers and distribution) used was taken directly from the Malton and Norton Transport model and the development scenarios modelled mirror two of the development scenarios (Scenarios 3 and 7) which were modelled as part of the highway assessment work undertaken to support the plan.
The modelling undertaken by SYSTRA took into account additional level crossing downtime and took into account the impact of highway interventions (the full package of the Brambling Fields Complimentary measures and the introduction of a HCV restriction only.)
The SYSTRA report is the only technical evidence which assesses the impact of the plan on air quality. The report draws a number of conclusions, including:
“The Atmospheric Dispersion modelling has indicated that all 2027 scenarios indicate pollutant levels well below objective levels and there is a notable improvement in air quality in 2027 compared to current pollutant levels.”
“The modelling also suggests that there will be significant reduction in emissions overtime, as the Euro 6/VI emission standard becomes more prevalent in the relevant vehicle fleets.
This reduction over time is much more significant that the modest increases created by the new developments or the changes created by the proposed highway schemes”.
This is a ten page new submission.
In order to provide a timely response, the Council has summarised what it considers to be the main points raised by Mr Thackray in the statement and as summarised in his ten  concluding points. In summary, the submission expresses concern that the Council’s approach to development at Malton and Norton will result in increased traffic congestion and a “predicted deterioration” in air quality.
The statement repeats Mr Thackray’s concerns over the reliability of the Systra report which was his substantive duly made representation, made when the plan was published.
The statement asserts that the plan is not deliverable because the Brambling Fields junction upgrade has not been delivered and questions the value of the proposed link road.
The statement challenges the application of the Site Selection Methodology and sustainability appraisal conclusions. It goes on to promote an alternative development/distribution strategy of promoting more development in rural villages to prevent a further deterioration in air quality at Malton and Norton and to prevent the ‘slow death of small rural communities’.
The Ryedale Plan – strategy and distribution of development
The Sites Document has been prepared to align with the Local Plan Strategy which established strategic policies including the level and distribution of growth / development requirements.
The examination of the Local Plan Strategy fully considered the sustainability issues associated with the strategy and the role of the Malton and Norton within this, as well as rural villages. Alternative options were considered as part of the process and choices were informed by a wide and detailed evidence base.
The Inspector appointed to examine the strategy concluded that “Overall, it establishes an effective, deliverable, positively prepared and soundly based spatial strategy for Ryedale”. (Para 33, Inspector’s report, August 2013).
[Inspectors get things wrong, obviously].
The policy approach to the rural villages was not considered to be in conflict with national policy. In relation to alternative approaches of dispersing development to smaller settlements, the Inspector noted that “these alternative approaches were considered at the options stage, with good reasons for their rejection, largely due to poor accessibility and sustainability”. (Para 26, Inspectors report , August 2013).
[As above – The policy approach to the rural villages deliberately engineers unsustainability and poor accessibility.]
The Council notes that Mr Thackray considers that the strategy should be changed to prevent the ‘slow death of small rural communities’. This statement is conjecture and no evidence is provided to substantiate or explain this assertion.
The Council is of the view that it is not the role of the examination of the sites document to revisit strategic policies of the adopted Local Plan Strategy. That is a matter for the future review of the Ryedale Plan as a whole.
Mr Thackray’s statement includes a number of assertions that the Council’s approach will lead to ‘illegal air quality’ and a ’predicted deterioration in air quality’. These statements are not substantiated by evidence.
The SYSTRA report is the only evidence which models the impact of the plan on air quality. The methodology used in the report is robust and SYSTRA are a well-respected company with considerable experience in this field.
There is no evidence which suggests that SYSTRA’s methodology and conclusions are not reliable or realistic.
Highway modelling demonstrates that the impact of sites with planning permission as well as those proposed in the plan, on key junctions in the network can be mitigated with improvements, including signal optimisation. The work recognises that Butcher Corner will continue to operate at/ overcapacity in peak periods.
[Thereby, in a masterstroke, the claims made by officers of RDC in 2011/12 are superseded. RDC and NYCC claimed that the £6 million pounds Brambling Fields junction upgrade scheme, on which the Ryedale Plan depends, would reduce traffic passing through Butcher Corner by 33%.]
The modelling demonstrates that it is the congestion at this junction that triggers the redistribution of traffic across the network and which in turn prevents an exponential increases in queue lengths at the arms of this junction.
[I am still taking this in… This statement harks back to a long-since abandoned Highways idea that the way to make traffic avoid Malton is to let Malton become so congested it finds another route (to where we might ask?). When the destination of Malton and Norton traffic is Malton town centre facilities and supermarkets, the argument and above comment is ridiculous. Heaven preserve us.]
The Highway modelling has been undertaken by Jacobs who are a consultancy firm who have a good understanding of Malton and Norton’s highway network and who are technical experts in the field of transport modelling.
[Hence the traffic congestion we all enjoy!]
Brambling Fields Upgrade
From the outset of the plan-making process, the Council and the Local Highway Authority recognised that the Brambling Field junction upgrade was an infrastructure improvement which was critical to the delivery of the plan and the approach to accommodating development at Malton and Norton. This is reflected in the Local Plan Strategy and in the Infrastructure Delivery Plan.
The improvement related to the addition of an eastbound diverge slip to create a full movement junction in this location.
Historically traffic travelling eastbound on the A64 from York would need to exit the trunk road at Malton and travel through the central road network/Butcher Corner to access Norton.
In this way, the improvement provides the capacity for the road network to accommodate additional development. The junction improvement has been delivered by the District Council, the County Council and Highways England and was fully operational from early within the plan period.
The Council has explained over the course of the hearing sessions that highway modelling demonstrates that the junction is used when traffic redistributes to avoid congestion at Butcher Corner and if new development is located on the eastern side of Norton .
An assessment of the Brambling Fields junction has demonstrated that it will operate well within capacity with local plan and background traffic growth.
Contribution of the (Beverley to Scarborough Road) Link Road
The Council has not claimed that the link road will reduce congestion or that the development would not result in increased traffic in the network with destinations in Norton and Malton Town Centres.
The road will provide an additional route in the network which will provide traffic heading to/from the south to access the A64 trunk road via Brambling Fields without the need to travel through the central road network.
Trip generation and distribution from the site has been taken into account in the highway modelling and air quality modelling undertaken to support the plan. In this respect the link road is necessary to mitigate the impact of the development at Wold Street and Mill Street.
(In addition to signal optimisation improvements at Hugden Way to mitigate the impact of the development at that junction.)
Application of the Site Selection Methodology
The Site Selection Methodology is designed to ensure that new development sites are chosen within the context of local sustainability objectives and to align with the Local Plan Strategy – itself informed by sustainability appraisal. It is applied within the context of the Local Plan Strategy.
The Council stands by the commentary it has made relating to site sizes in the methodology. (The extract of which is included in Mr Thackray’s statement). This is consistent with the evidence base used to inform the Local Plan Strategy.
Mr Thackray disagrees with the Site Selection Methodology in so far as it does not support an alternative development strategy which he considers to be more appropriate.
In this respect, the Council would emphasise that it is not the role or purpose of the Site Selection Methodology to test or apply an alternative development strategy/plan. [Even though the current plan strategy is wrong.]
Alternative development strategies
The Local Plan Strategy together with proposals in the Sites Document will address development requirements to 2027 and the Council is of the view that there is no requirement to review the development plan to ensure requirements to 2027 are met.
The Council will begin the process of reviewing the Development Plan in the next year in order to ensure sufficient time for the preparation [of a] new plan to meet development requirements post 2027.
The review will consider whether the current plan strategy remains appropriate in the longer term or whether alternative approaches to the distribution of development require consideration.
The Council will consult all interested parties in undertaking such a review and proposals for alternative development options (Including, for example, the new town suggested by Mr Thackray) will be considered as part of the review process. The extent to which alternative options are justified and effective/deliverable will be key considerations.
[RDC RESPONSE ENDS]