York Green Party submission to Local Plan consultation October 2017

General Points

·       We support the majority of the aspirations in this plan. It needs to be more ambitious in terms of specifying how they will be achieved.

·       Throughout the document statements of intent need to be clearer and more definite, without so many qualifying clauses.

·       There is lack of consistency between the treatment of the various strategic sites in the document. There is a great deal of detail in the policy principles for some relatively small sites, whilst some far larger sites are very short on detail. Principles that apply to one site, for example requirements for very high levels of sustainable building, should be applied to all sites, unless there is an exceptionally good reason why they wouldn’t be applicable.

·       Not at all clear why for some sites make reference to the provision of affordable housing in keeping with the affordable housing policy and some don’t. Surely they should all say this?

·       Cross references to other policy areas should also be more comprehensive, for example for York Central.

·       We believe it is crucial that York agrees a Local Plan as soon as possible both to provide it with the protection it needs from uncontrolled development and to guide the city towards an environmentally, socially and economically sustainable future in the face of climate change and other global challenges.

·       Therefore, whilst we still believe that the number of houses proposed and the resulting extent of land allocation in this Plan is pushing at and beyond the boundaries of what the city can sustain, particularly in terms of transport systems and air quality, the impact on biodiversity and the impact on other infrastructure such as drainage, our submission doesn’t focus on a significant reduction in housing or employment allocations, although we still believe that house building targets well below 800/annum would be more appropriate for York.

·       Providing more affordable housing accessible to York residents is one of the key issues facing York and we see little evidence that pushing the overall house building target even higher will do anything to deliver more affordable housing to rent or to buy in the city. Experience over the last 10 years and more has shown that the number of affordable dwellings actually delivered has fallen far, far short of both target house building levels and the amount of non-affordable, market housing actually built.

·       We believe that city strategies should focus on the delivery of affordable housing through as many means as possible including direct Council investment combined with developer contributions. However, for affordable housing to be truly accessible it must be combined with sustainable affordable public transport.

·       This plan should also consider a more equitable distribution of new housing development across the city, protecting and improving the high quality of life that is a special feature of York for all residents in both rural and urban parts of the city.

·       Defining and protecting the Green Belt is important, but so is protecting access to green open space for residents in the city centre and the urban areas.

·       The level of development that is still proposed in this Plan will only be viable and deliverable for York residents if a bolder and more ambitious approach is taken to providing non-polluting, environmentally sustainable public transport infrastructure fit for the 21st century. At present the aspirations are laudable, but there is not enough vision or proposed strategic action to actually reduce road traffic levels, tackle air quality and promote access for all. The development principles for one strategic site after another state that traffic impact will be a major problem and yet offer very limited solutions. We believe that, alongside other measures (see Transport), the inclusion of plans for a light rail system of some kind, using planning gain and regional infrastructure funding to provide transport for the future, not the past, will be the only way to make this Plan work.

·       To create sustainable developments which respect York’s environment, provide warm affordable homes and are resilient against a future of rising energy prices and diminishing resources the Plan must also include an active and clear commitment to the environmental sustainability embodied in the One Planet York principles, including zero carbon building and the development of local renewable energy networks. All development principles and site allocations should be measured against this using an improved version of the decision making tool currently being trialled for major policy decisions.

DP1

v. ‘improvements to the outer ring road’ should not be listed as an element of ‘City of York’s role as a key node for public transport’. Reference should be added here to ‘work with West Yorkshire Transport Board to develop enhanced public transport links to the proposed new garden village sites and new peripheral development sites’

vii Support safeguarding of strategic green corridors from development with the exception of essential new public transport infrastructure where this is integral to new out of centre development.

Ix This should say that development will not lead to these problems ‘for the City of York or adjacent local authority areas’.

DP2 – generally support with the following amends:

i) should include new bullet point: ensuring priority is given to high skill employment opportunities with training for future skills needs in a low carbon future.

Iii) Protect the Environment: Strongly support this section

3rd bullet add ‘taking opportunities to ‘slow the flow’ and introduce SUDS drainage wherever possible’

5th bullet, reword as follows: ‘ensuring design techniques to maximise environmental sustainability and minimise energy use are incorporated in new developments and etc ….’

Iv Transport Links strongly support the first bullet point, but should say improving and developing new …networks

2nd bullet, reword as follows: ‘improving the connectivity and effectiveness of the strategic highway network capacity whilst protecting residential areas, including safeguarding routes and sites.’

Should also include reference to safeguarding and designing with connections to long term strategic routes eg former rail lines that could become public transport corridors.

DP3 Reword introduction as follows: ‘New development, including all the allocated sites as identified on the proposals map, should, except where clearly not applicable, where appropriate, address the following overarching development principles:’ 

iv) before ‘sustainable’ insert ‘environmental’

insert a new ix) as follows: ‘Ensure that small green open spaces, pocket parks and public amenity areas in the city centre and urban areas are protected and enhanced in order to provide the benefits of green open space across the city.’

Andy – amends/additions?

xi. amend as follows: ‘minimise the environmental impact number of private vehicle trips to and from the development and mitigate the impact of residual car trips on the highway network where possible;

DP4 Add comment about working with applicants at an early stage.

SS1 Replace third bullet as follows: ‘Preventing any additional exceedences or increases in illegal levels of air pollution’.

SS3 City Centre – generally supportive of the principles in this policy but disappointing there is no mention of city centre residents. The Plan should be more clearly ambitious about seeking a largely car free city centre and further strengthen the requirement to protect and provide green space for city centre residents, workers and visitors.

Support ‘Change of use of existing Use Class A, B1(a) and town centre leisure, entertainment, and culture uses will be resisted.’ 

Amend as follows:

Proposals that promote accessibility and movement are encouraged, particularly those that prioritise pedestrian and cycle movement, move towards a largely car free city centre and improve linkages between key places such as the railway station, York Central and the National Railway Museum, the Minster, Castle Gateway, Hungate and the universities.’

ii) Amend the last part to read ‘….and improved settings to showcase all heritage assets including the Minster and Clifford’s Tower.’ The settings of the Minster and Clifford’s Tower are hugely important but so are the settings of the many other heritage assets in York.

iii) Amend as follows: ‘Enhance the gateway streets leading into the city centre, ensuring that new developments balance the needs of residents, traders and visitors to the city.  This will include giving a better sense of arrival and improving any areas of transition to the footstreets, improving pedestrian and cycle routes and encouraging visitors to explore further, whilst working towards a largely car free city centre. Streets include Gillygate, Goodramgate, Peasholme Green and Stonebow, Walmgate and Fossgate, Piccadilly, Micklegate and Bootham.

v) Reword as follows: ‘Strengthen the daytime and evening economies by diversifying the current functions of the city centre to provide for the widest possible range of residents and visitors including children and families, young people, older people, people on low incomes and cross-generational activities. Encourage early evening opening.’

x)Reword to read as follows: ‘‘Provide community and recreational facilities including the protection and additional provision of green amenity spaces in the city centre, essential to enhance the physical and emotional health and well being of city centre residents and workers, promote active lifestyles and provide an attractive city centre for visitors. Green amenity space also helps to combat the effects of higher temperatures, air pollutants, flooding and climate change.’

Add an additional policy principle regarding the use of upper floors eg. ‘Proposals that bring upper floors in York City Centre back into an appropriate use, particularly residential use, are encouraged to ensure that upper floors do not become a wasted resource.’

SS4 York Central

i) Between ‘quality’ and ‘sustainable’ insert ‘economically, socially and environmentally’

ii)Reword as follows: ‘Provide a new business district consisting of a wide range of modern workplaces including a critical mass of high quality offices suitable for modern business requirements, managed workspaces, business start-up locations and small-scale workshops and manufacturing venues.’ Create a sustainable new community with a range of housing types and tenures. To reflect the site’s location, high density development may be appropriate.

xi)not clear what this means?

Suggest add following principles:

·       Deliver a green infrastructure network combining dedicated and substantial areas of public green open space with pockets parks and green corridors, including a central green spine throughout the site which will provide for open space, biodiversity, recreation and a sustainable transport corridor, whilst integrating with wider public realm in the city.’

·       Deliver either no car or very low car developments.

·       Maximise the site’s contribution to the provision of housing to rent and to buy that is affordable to existing York residents.

·       Minimise the use of fossil fuel based energy throughout the site and maximise the production of renewable clean energy on the site including the infrastructure for a district heating system and or site-wide ground source heat pumps or similar low cost renewable heat technology.

SS5 Castle Gateway

We support much of the approach in this policy section with the following provisos:

Delivery principles/actions:

We support the removal of the Castle car park. We believe the option of replacing it with an underground car park should be discounted immediately – apart from the expense, the likely difficulties regarding flooding and potential impact on the structural integrity of Clifford’s Tower itself, the key reason is that retaining a car park entrance/exit on the Castle site will totally undermine the objective to remove the majority of through traffic from this area and enhance the setting of Clifford’s Tower and other historic buildings in the area through creating a high quality pedestrian space.

We would also strongly suggest that the plan doesn’t specify that replacement car parking space should necessarily be provided at Castle Mills. Whilst this may turn out to be the case, specific assumptions about the most appropriate replacement parking shouldn’t be made until a detailed review of all the city’s off road parking capacity has been completed.

Castle Piccadilly

The form and design of any building along the western bank of the Foss is crucial. The limitations on what is acceptable should be clearly defined from the outset.

i)Add the following ‘The building should be highly legible and maximise opportunities for full and open (non-paying) public access to the river frontage (required at v) directly from the Castle site, facing both the river and the new civic open space; it should maximise views of the Foss from the Castle site, preserve the current view of Clifford’s Tower from Piccadilly and facilitate an awareness of being between two rivers on the Castle site ; it should be no more than one storey high for a significant part of its length; and it’s footprint should take up less than one third of the area between the Foss and the bottom of the Castle mound. 

ii)Replace with ‘Deliver a contemporary new car park if required to meet evidence based city centre parking needs, for example on the site of existing surface level parking at Castle Mills.’

The principles should include some kind of definition of what is required on the Castle car park site. Add new principle ‘Create a new city centre park on the former Castle car park, connecting this area with the Eye of York to provide a flexible civic space that includes green infrastructure, informal open space, more formal space for small and large events, reflects the heritage of the area and better connects the city centre to the Castle Museum.

Comments on specific strategic housing sites

SS6 British Sugar/Manor School

As a major development site in the city and one that is zoned for a significant housing development, the site should be subject to the same standards as the nearby York Central in terms of requirement for affordable housing, sustainable building and traffic minimisation. Much of this seems to be missing from the current site principles.

Amenity and recreational open space in the area for existing and new residents should also be protected.

The potential for a tram/train/light rail link through this site to the railway station shouldn’t be a long term possibility but an immediate strategic transport priority. It should be mentioned here in SS^, not in SS7.

SS7 Civil Service Sports Ground

The serious concerns about the traffic impact from this site and the cumulative impact with the British Sugar site are noted, but no solutions offered ….

SS9 Land East of Metcalfe Lane

3.43 mentions ‘The northern boundary runs along Tang Hall Beck for the most part’ and yet there is no mention of the importance of flood mitigation measures in the site principles. This is for a very significant number of dwellings which could have a very serious impact on surface water drainage into the Beck, which could have impacts for large areas of the city. An additional principle to this effect should be added.

SS10 Land north of Monks Cross

Principle iv) and the paragraph to begin ‘Create a new green wedge ….’ If this needed, which it would seem it is, then it should be a clear part of the strategic plan.

 

SS12 Land West of Wigginton Road. This site is too small to stand alone as a sustainable garden village, but is still very large as a development site which if built without additional sustainable transport provision will generate unacceptable traffic congestion both in the immediate area and on arterial routes into the north of the city centre. Reducing the numbers on this site should be considered.

Policy SS13: Land West of Elvington Lane 

Whilst the new settlement will include affordable housing, there is no mention of making the new build affordable to run for everyone. In keeping with our climate change commitments and One Planet York as well as tackling fuel poverty, the principles must include a commitment to high standards of sustainable building. Design should not be constrained by an implication that the new ‘village’ should look exactly the same as villages built in previous centuries.

Policy SS14: Terry’s Extension Sites ST16 111 dwellings

General comment: there is no reference to affordable housing on this site. A principle requiring affordable housing should be added – this site which was originally subject to widespread resident consultation has hugely disappointed by delivering housing and other services that are way beyond the budget of most local residents.

Terry’s Car Park site

Support this principle: ii. Be of a low height and complement existing views to the factory building and clock tower from the Ings, Bishopthorpe Road and the Racecourse. Add ‘Development should complement the rural character of the Ings up to where it joins the cycle path and incorporate a suitably graded disabled accessible route between Bishopthorpe Rd and the riverside.’

Add ‘v) A full controlled pedestrian and cycle crossing must be provided to facilitate access between the main site and this extension.’

Policy SS15: Nestle South

iv. Maximise accessibility and connectivity to the city centre and local area by pedestrian and cycle routes, including direct access from the site to the Foss Island Cycle Path which runs alongside the site boundary.

vii. Assess appropriate access from both Haxby Road and Wigginton Road along with associated junction improvements as necessary through Transport Assessment and Travel Plan. Access between Haxby Road and Wigginton Road will be limited to public transport and walking/cycling links only.  Strongly support. Add ‘segrated, purpose built cycle link’.

Add:

Phase 2 must include an assessment of the need for any further on-site community facilities such as community meeting space, local shops, cafes, doctor’s surgery, childcare facilities, on-site open space and play areas.

These requirements should be included in more detail in the site principles both in order to provide appropriate amenity for residents and to reduce the need to travel in an area where the traffic impact is going to be very challenging. Why is there no more detail in the site principles? Phase 2 should include areas of car free development with car club provision.

Policy SS19: Queen Elizabeth Barracks

Serious concerns about the impact on the biodiversity of Dtrensall Common would call in doubt the viability of this site.

SS20 Imphal Barracks

We do not support this being allocated for housing, particularly given the constraints of historic and Listed buildings, proximity to Walmgate Stray, fine mature trees on parts of the site, the Conservation Area status at the front of the site, and the existing congestion and pollution constraints on access from and to Fulford Rd/ A 19. We consider that IF it is ultimately closed at the end of the plan period it should be identified as mixed use to reflect its current important role in local employment as well as accommodation for army personnel. In terms of housing numbers, if the Barracks is vacated there will also be some further 70 or more ‘Army houses’ outside the confines of the barracks in Bray Rd, Smith Close, Broadway Close etc that will become available. Any new development would have to look closely at sustainable travel options since the A19 operates above capacity already at peak times and is an Air Quality Monitoring Area because of dangerously high air pollution levels. We would like to see a long term strategy for modern public transport such as light rail linking from Germany Beck alongside the Imphal Barracks and on towards the city centre. This should be added to the strategic transport network plan as a long term project for which initial feasibility work is commissioned now to evidence the sustainability and viability of the site.

SECTION 4: ECONOMY & RETAIL

Policy EC1 Provision of Employment Land

Add in ‘Small windfall sites will be considered for employment land where they can be demonstrated to meet a local need and cause adverse impacts.

Policy EC2 Loss of Employment Land – what can we put in to make this policy meaningful?

Policy EC3 Business and industrial uses within residential areas

EC4 Tourism

First bullet point – why the focus on 4 and 5 star hotels? ‘Encourage development of a wide range of accommodation to suit all pockets and thereby encourage overnight stays.’ Surely B & Bs are struggling in York and yet retain far more money in the local economy than corporately owned hotels.

EC5 Rural Economy – support policies on diversification of rural economy

R1 Retail Hierarchy and Sequential Approach – support

R2 District and Local Centres and Neighbourhood Parades – support

4.29 support

R3 York City Centre Retail support, particularly the clauses aimed at controlling the balance of retail and non-retail establishments in the city centre and addressing the potential negative effects of cumulative impact of non-retail premises.

Add to first list of bullet points: ‘Explore the extension and consolidation of the footstreets, leading to a largely car free city centre and a world class pedestrian environment, to support city centre businesses by providing an attractive and welcoming environment for residents and visitiors.’

Policy R4 Out of centre retail – support. Add new bullet: ‘Will not add significant additional congestion to existing stress points on the highway network.’

SECTION 5: HOUSING

Policy H1 Housing allocations

Strongly support the principle of phasing, however note that only 3 sites, in addition to Imphal Barracks are phased to start later than Year 1, leaving all the sites open to developer choice. Surely some of the major greenfield sites should be phased from Year 6 or later?

Policy H2 Density 

Support the principle of site specific flexibility in this policy and the principle that good design and density are intrinsically linked. The policy should say more specifically that good sustainable design can facilitate high density development which still delivers a good quality of life including green open space.

Further consideration should be given to a mix of densities in the garden villages and greenfield sites including elements of considerably higher density than the current guideline, as long as these are accompanied by more ambitious sustainable transport provision. The number of dwellings at the Elvington site in particular could be increased in this way and therefore provide greater critical mass to help fund sustainable transport solutions such as a tramline/light rail system.

Some higher densities in the outer sites would facilitate the protection of quality of life, open space and better design in the city centre and urban areas.

Policy H4 – support

Policy H5 Gypsies and travellers – support

Policy H6 – Travelling Showpeople – support

Policy H7 Student Housing

Amend first para. Insert new second sentence ‘Whenever possible the first recourse for additional purpose built student accommodation should be on campus.’

‘In assessing need, consideration will be given to the capacity of independent providers of bespoke student housing in the city and whether it is economically prudent to provide additional student accommodation.’ What does this mean?

Delete ‘To meet any projected shortfall, provision by the University of York can be made on either campus. Provision by York St. John University is expected to be off campus but in locations convenient to the main campus.’  

– add point iv. As follows ‘where the cumulative impact of purpose built student accommodation in an area can be shown to be un-balancing the local community.

Policy H8 – support

Policy H9 – support

Policy H10 Affordable Housing

The affordable housing target should apply to sites under 15 dwellings (and 4 dwellings or more) via either onsite provision or off-site contribution in both rural and urban sites.

Add point vi) with regard to larger development sites seek to work pro-actively with the Council or another registered social landlord to deliver additional direct funded affordable housing.

SECTION 6 HEALTH AND WELLBEING

Policy HW1 Protecting existing facilities – support

Policy HW2 New community facilities – support, especially ‘Applications for residential developments of 10 or more dwellings must be accompanied by an audit of existing community facilities and their current capacity.’

Policy HW3: Built Sport Facilities – support

Policy HW4: Childcare Provision – support all of this policy, especially ‘All strategic sites will be expected to conduct an audit of existing childcare facilities and their current capacity.’

Policy HW5: Healthcare Services – support

Policy HW6: Emergency Services = support

Policy HW7: Healthy Places – support

SECTION 7 – EDUCATION

Policy ED3 Campus East (ST27/SS22)

We question the sustainability of the expansion site ST27 and in particular 7.11 states that this will be accessed from Hull Rd via Campus East.

Commercial knowledge based and research led activities are already the basis of York Science Park on Campus West. It is not clear how the two will relate to each other and whether there will be increasing demand for connections and movement between the two. Experience from the Science Park demonstrates considerable parking pressures which are likely to create problems for ST27, especially given the cap on parking space numbers for each campus and the fact that vehicular access will be through a public transport only campus. ‘Upwards of 15% by public transport’ is far too low a target even allowing for walking and cycling for more local trips around the university area.

Direct access from the A64 (in conjunction with ST15) is likely to promote a higher level of trips by car, again exacerbating parking pressures. It would be preferable to explicitly state that this allocation will be dependent on a public transport link as part of a master plan for both sites (ideally a tram connection to serve the new garden village, the extension and campus east linking in due course to campus west and the city centre.

ED4 Lord Mayor’s Walk Campus – similar comment as above at H7. Not convinced that on-campus student provision should be reduced.

ED6 Add at the end of i) any new primary schools should be located so a large majority of pupils can walk or cycle to school.

ED8 Community access – support.

SECTION 8: PLACEMAKING, HERITAGE, DESIGN AND CULTURE

Policy D1: Placemaking – strongly support this broad approach

Iv Building Heights and views

Add:  In general existing tall buildings will not be modified to include more modern additional accommodation on top of existing roofscape unless it can be clearly demonstrated that this is essential for the viable conversion of the building to its new use.

Policy D2: Landscape and Setting

Welcome this and the cross reference to Green infrastructure

D4 D5 D6 Conservation areas, Listed Buildings Archaeology – support

D7 Non designated heritage assets

Add bullet point in the policy specifically mentioning SPD Local Heritage List

Policy D10: York City Walls and St Marys Abbey Walls (York Walls) – support

D12 support explicit policy to retain existing historic shop fronts. Add reference to retaining and repairing historic features including signs, clocks etc

D13 Add reference to traditional (non illuminated) hanging signs attached to buildings being considered as alternative to A boards within the city centre where they are justified to direct customers into side streets.

SECTION 9: GREEN INFRASTRUCTURE

Support all of this policy. Especially welcome the references to the importance of access to nature.

Policy G14 should also include reference to the development of a city wide Tree Strategy aiming to increase tree cover in York in line with the objectives of Treemendous.

SECTION 10: MANAGING APPROPRIATE DEVELOPMENT IN THE GREEN BELT

Policy GB1: Development in the Green Belt – generally support this policy with following amend:

minerals extraction, provided high environmental standards are attainable and including all the safeguards specified in the Minerals and Waste Plan.

SECTION 11 CLIMATE CHANGE / ENERGY

CC2 Sustainable Design and Construction

We fully support policies which require maximum permissible uplift in energy efficiency and renewable generation in order to meet and exceed our carbon reduction targets and commitments in the Climate Change Act, Paris Agreement and Climate Change Framework for York (2010)
We believe there should be a commitment to uprate all targets on an annual basis in line with national and international policies and scientific evidence.

11.16 Water consumption is an important consideration – reference should be made here to rainwater and greywater recycling having dual benefit of reducing consumption of clean water supplies and reducing discharge rates to watercourses. Such systems are particularly appropriate for larger developments such as student accommodation, factories, supermarkets, offices etc.

CC1 Renewable and Low Carbon energy generation and storage

For new developments, the cost of installing ground source heat systems is significantly lower if done at the time of groundworks when other utilities are installed. We therefore believe all new developments should assess and factor in the whole life cost of installing ground source heat pumps and higher levels of insulation against the requirement for linking to district heating networks. Where ground source heat provision would be more cost effective, this should be installed.

CC3 District Heating and Combined Heat and Power

Support this policy, especially for developments that are close to the existing network at University of York (ST27 and ST4)

Add: ground source heat systems may be more appropriate for smaller /less intensive development and must be assessed to decide which is most appropriate taking account location and scale of the development.

 

SECTION 12 ENVIRONMENTAL QUALITY AND FLOOD RISK

ENV1 /ENV2 Air Quality

Reference should be made to the proposed city centre ‘Clean Air Zone’ and the intention to remove all pre Euro 6 buses and diesel operated deliveries to premises from within the inner ring road by 2020. Developers of city centre sites will be required to contribute to the operational costs of a freight transhipment service unless they can demonstrate the intention to use their own electric fleet or cycle couriers. 

There should be a statement specifying the date by which all AQMA zones are set to comply with the maximum pollution levels set by WHO health based objectives. From May 2020 all new developments accessed directly from or within an AQMA (which has not been revoked) should include a requirement that only electric vehicles or Euro 6 minimum will be allowed to use parking provision within the development. Car club membership, free bike and public transport passes can be provided as incentives to new occupants.

ENV4 Flood Risk

We support this policy and welcome the inclusion of surface water, groundwater and sewage overflow flooding. Reference should be made here to a requirement for an appropriate flood warning system, evacuation plan and escape routes when the development is in or near flood risk areas.

ENV5 Sustainable Drainage

Reference should be added to the biodiversity, water quality and aesthetic benefits of green roofs, open swales and balancing ponds or lakes as part of a SuDS in appropriate developments. New habitats can help to mitigate wildlife loss at the same time as slowing runoff and preventing localised flooding.

SECTION 13: WASTE AND MINERALS

WM1

v. This should include requirement for new commercial developments to include separate recycling as well as waste storage facilities.

Add reference to new food premises having provision for food waste collection, separate from recycling and other waste collection and requirement to store waste within the site prior to collection.

WM2

Reference should be made to ensuring mineral exploitation takes full account of residential amenity and the unique heritage on which so much of York’s economy now depends.

Add Iv Biodiversity, environmental , heritage, transport and residential amenity considerations will be carefully considered when suitable sites are being selected.

SECTION 14 TRANPORT

Policy T1

We support the overall objective of creating an effective sustainable transport network which minimises the need to use private cars and promotes healthy active travel modes such as walking and cycling.   We welcome the LSTF funded ‘i-Travel York’ programme (not referred to in T1) which seeks to influence travel behaviour in favour of more sustainable and active forms of travel and thereby reduce levels of use of the private car. However, this has focused mainly on the north-east sector of York and there is no indication how this might be extended more widely. Furthermore the current version of the plan does not appear to contain any evidence of the measurable outcomes of the programme and the most effective measures that might be more widely deployed during the plan period. Such data should form part of the evidence base to demonstrate the most effective local strategies to mitigate the likely car trips that may be generated by new developments in the city.

We support the general approach of establishing frequent high quality public transport and safe attractive walking and cycling networks to access local services and facilities. The specific support for provision of public transport from first occupation for a period of 10 years is welcome. However there should be a ‘master plan’ to give certainty to developers, potential businesses and future residents as to the long term infrastructure that will serve the site.

The suggestion that this could be ‘relaxed’ is too weak and should be removed since all conditions will inevitably be open to some negotiation in the light of exceptional circumstances.  The Sustainable Transport for Development SPD should provide examples of good practice from other European locations and funding solutions for innovative approaches to creating 21st century public transport options. Developments such as car clubs, electric bike hubs, driverless vehicles, uber style taxi minibus services and ‘on demand’ trip services such as Vamooz should all be factored in ensure new developments capitalise on emerging new transport options. More specifically a business case model should be considered for orbital bus services, shuttle bus services such as UB1 operating between the two university campuses, light rail/ tram/ trolley bus/ guided bus routes etc

Policy T2

We believe there should be a comprehensive review of the existing strategy. This should include the development of minimum standards for new services to include early morning, evening and weekend frequencies of no less than hourly services for new developments. Consideration may also be given to whether or not one or more park and ride routes might be superceded in time by a new electric light rail system eg The Monks Cross route between the Stadium/ Vanguard site and the city centre and routes linking both Designer Outlet and Grimston Bar with the new Elvington settlement the University and the city centre, potentially also linking in to Germany Beck/ Imphal Barracks. This would be implemented over the medium- long term and be linked with parallel enhanced strategic pedestrian and cycle routes. It would replace the proposed expansion of Poppleton Bar and Askham Bar as lower priority if a successful tram network and tram train service can be established. The proposed segregated bus route over the A1237, presumably in association with ST14 is welcome but would need to be linked to both Clifton Moor and a dedicated priority route into the city centre, potentially in place of the route 6 service. There also needs to be a bus service review under the auspices of the Quality Bus Partnership to identify new service requirements such as orbital routes reflecting the shift in focus away from the city centre to out of town locations notably Clifton moor and Monks Cross. Consideration needs to be given to alternative modes of provision eg minibus shuttles to shops, leisure centres and workplaces.

We support the long term ambition for a new rail station at Haxby with exploration for options at Strensall, Copmanthorpe, and a tram/train halt at British Sugar.

We believe that traffic restraint measures and public transport priority within the city centre are far more urgent that ‘long term’ and should be introduced incrementally, starting next year with making Coppergate, Fossgate, Tower St, Micklegate etc more pedestrian friendly as part of the Castle Gateway developments. Footstreets changes should include anti-terror measures that physically prevent vehicles entering the footstreets during hours of operation, including closing off the current  Monk Bar – Goodramgate – Kings Sq – Colliergate route.

Policy T3 York Railway Station

We support the identification of York station as an important transport hub and specifically pedestrian access within and through the station. Opportunities should be taken to reduce long stay parking at the station (including by development of appropriate park and ride links and parking in the vicinity of a new Haxby station). Priority for existing space should be given to expanding platforms, services for rail customers etc.  Provision would also need to be made for interchange to any new bus, shuttle bus or taxi services and tram train if developed from British Sugar site. We support the development of a more formal western entrance and square linking to the new approach for rail passengers working at or living in York Central. This should be designed to enhance the attractiveness of walking and cycling, accommodating taxis and buses serving the station from the west side.

Policy T4 Strategic Highway Improvements

The explanation 14.36 Is NOT borne out by policy T2 which proposed city centre traffic restraint measures as ‘long term’ ones (when they need to be short term to achieve this objective). We welcome the stated objective for enhanced capacity on the outer ring road, namely discouraging driving through the city centre. There is nothing in the transport policies as currently presented to indicate action to achieve this. The short and medium term improvements are all focussed on heavily congested routes on the ring road and arterial roads. Given the growth of traffic to new developments and the community stadium, such improvements are likely to do little more than absorb the projected increase in traffic and not provide the incentive suggested here.

The long-term ambition to upgrade the ring road to dual carriageway is rather like planning to build more canals long after the coming of the railways!! This ambition should be scrapped now in favour of a regionally funded feasibility study for an appropriate light rail network to serve the largest new development sites within the plan. This is supported by para 4.11.9 of the Sustainability Appraisal Main Report “Co- location of development with sustainable transport is paramount and without policy intervention this may not be achieved… While behavioural change and education can go so far in influencing the population, planning policy and the location of development could dramatically support sustainable development, helping to minimise any impact of new development on existing infrastructure. “

Inadequate Transport Model

We endorse the detailed criticism of the transport model as submitted by York Cycle Campaign and York Bus Forum. The whole approach in the Transport topic paper fails to acknowledge anything other than private car movements in its modelling and therefore seeks to mitigate increased traffic rather than pro-actively identify potential public transport walking and cycling corridors that might be developed from the outset. As stated in response to T1 it also fails to anticipate the likely change in travel behaviour during the plan period, with less commuting and business travel, more remote working, internet shopping etc. The model also fails to take account of the known phenomenon of ‘induced traffic’ with increased highway capacity. Neither does it consider the detrimental effect such increased traffic across the network is likely to have on cycling and walking on roads in general and especially in and around rural villages where roads often do not have separate facilities for cyclists and pedestrians. The transport model should start from the premise of looking for the most cost effective transport provision for given new development(s) in an area before seeking to mitigate the residual private car movements. This should take account of the potential to link up a critical mass of existing and new housing and places of employment or recreation in order to finance the infrastructure. Reference to this approach particularly for major new ‘garden village’ sites should be made to this in T1. Lessons should be learned from the city of Freiburg which opened a new tram route linking 5000 households on Vauban to the city centre. Developing from 1998 with all homes built to be within walking distance of a tram stop, the proportion of residents living without a car has increased over time from 50% to around 70%, with nearly 60% of those now without a car having given up owning one on moving there. While funding mechanisms and cultures may be different this is a model that York should seek to emulate.

Therefore we believe a much wider study is needed which:

a)      Takes full account the transport requirements of the proposals for housing, employment and industry developments set out in the Local Plan;

b)      Does not assume that private car highway demand should or could be met;

c)      Fully explores the potential for public transport interventions including new modes such as light rail/ tram networks

d)      Considers the wider impacts – particularly on the environment and air quality.

Without this, the Transport Strategy will fail to meet the test of soundness in terms of the viability of development coming forward in a sustainable manner which doesn’t place unacceptable pressure on existing highway networks.

Policy T5 Cycle and Pedestrian Networks

The short term projects are welcome, notably the improvement to Scarborough Bridge which has potential to create a major boost in walking and cycling between the west side of York and the city centre/ Minster quarter. Additional work needs to be done to ensure the links and signage at either side are appropriate for increased cycle traffic and movements across Bootham, cycle parking at the edge of the footstreets etc. Other corridor schemes need to be more clearly specified into Phase 1,2,3 if they are to take place incrementally as development progresses. Each phase must have some coherence in its own right for local users.

The Pedestrian/Cycle Bridge as part of the Castle Gateway regeneration must be in Short – Medium term, NOT long term to have any beneficial contribution to the development of this area. The University East -West campus link was supposed to be a planning condition funded by S106 and must be included in the Short term provision – it is needed now and funding was made available for this several years ago!

Strategic cross centre cycle routes should be implemented in the medium term as changes associated with Castle Gateway and stronger links to the city centre are implemented.

The whole Network evaluation and prioritisation should be reviewed in the light of the latest version of the Local Plan so that phasing is adjusted to relate to the anticipated timescales for new development sites. The review of the city centre inner ring road and the severance caused from surrounding suburbs as proposed by Prof Tony May on behalf of the Civic Trust should inform this section of the local plan. In particular the ‘Fishergate North corridor’ needs to be in the short term with a high priority to linking Fishergate School directly to Fishergate Bar and George St as a two way route.

Reference in this section should be added to the impact of flooding on walking and cycling routes and work with the Environment Agency – riverside routes need to be provided with signed alternatives (as we have on Fulford Rd).

Resilience measures need to be given priority for short term action eg Raising the Butcher Terrace approach to Millennium Bridge so that this important East – West route remains passable during flooding.

Policy T6 Public Transport corridors

Supported

These corridors and potential corridors eg of former railway lines need to be identified as such on the site allocations plans. Ideally potential extensions into and through new development sites should be identified from the outset and developers required to demonstrate how use of the facility will be maximised. Para 14.46 should also make reference to their value for recreational use and health benefits for residents, with new access points from development being encouraged to facilitate this.

Policy T7

The Transport Statement or Assessment should be more proactive in demanding evidence of potential for viable public transport, walking and cycling provision regardless of the anticipated car trips and the capacity of local roads. Behaviour change is far more likely to be in response to active marketing of a changed lifestyle supported by appropriate infrastructure than by ‘anti-car’ ‘mitigation’ measures.

Iv support the importance of monitoring – for big sites there should be a requirement for staff resource to be funded as part of the S106 to ensure that this responsibility is effectively carried out.

14.52 Should not say ‘in some cases’ Ie amend to read: Where developments are in close proximity a joint master travel management plan will be required’ This should also specify that sites of over 100 dwellings will require a proactive examination of sustainable travel options linking in with existing nearby networks before undertaking any assessment of the need to increase highway capacity.

 Policy T8

We support this policy. However there should be a presumption that new developments within the inner ring road will be ‘car-free’ (except for disability needs) in accordance with the progressive extension of foot streets and reducing traffic in the area. Specifically there should be no new parking provision unless it is replacing existing parking in a more appropriate location away from the footstreets.

Conversion of city centre car parking to long stay cycle parking in appropriate locations would be supported. New ‘shopmobility’ and off street disabled parking would also be supported as compensation for the loss of current on street parking where cars need to be excluded as part of pedestrianisation schemes.

Policy T9

We support this although have concerns that a suitable location is not identified in the current version of the plan. As set out in the explanation this is yet another stalled element of the council’s Low Emission Strategy 2012 and the Air Quality Action Plan 3 Dec 2015. Pump priming funding needs to be identified for this to become a viable option. Frequent damage by vehicles to historic buildings in the city centre and tragic pedestrian accidents are clear evidence of the urgent need to remove HGVs from the city centre, quite apart from the Air quality impact that diesel vehicles are having.

General points

References to ‘frequent bus services’ through the document are welcome but in order to contribute significantly to model shift bus services must also be affordable and run reliably every evening till late and Saturday and Sundays.

The requirement for public transport to be accessible within 400m walking distance of all parts of the site should be changed to 200m. This would be in keeping with our Health and Well Being Strategies and strategies to encourage active living amongst our growing older population (some of whom may be able to walk a shorter distance but not 400m, which is based on an average person’s capacity

Policy C1

Support. Would like to see some control included on the ancillary infrastructure, with a presumption against advertising material on junction boxes when located in conservation areas and the Green Belt.

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