01 March 2018

Local Plan Team

Barnsley Metropolitan Borough Council

PO Box 634

Barnsley

S70 9GG

Dear

Introduction

I understand that following feedback from the Inspector, indicating that there was a mismatch between the housing and employment figures in the submitted plan, Barnsley Metropolitan Borough Council has proposed to revise both figures to bring them more closely into alignment. I understand that this will involve the jobs figure being revised down from 33,000 (17,500 net) to 28,840 (16920 net), and the housing figure revised up from 1100 dwellings per annum to 1134 pa, in order to provide 646 additional units over the life of the plan.
As a consequence BMBC are consulting on 19 additional sites for housing and safeguarded land allocations.

Approach to villages

I would say first of all that I do not agree that the Inspector’s comments about the need to plan positively for villages necessitates the inclusion of so many additional housing sites. Indeed I would argue that the prior inclusion of several safeguarded land sites demonstrates ably that the local authority has planned for potential future expansion of rural villages, if necessary, whilst recognising that such expansion would be inappropriate at this time.

I disagree with the suggestion that Barnsley MBC's previous approach to safeguarded land was inconsistent with the National Planning Policy Framework on the basis that the approach focused development on urban sites. I would argue instead that a key tenet of the NPPF is promoting the vitality of urban areas and protecting the Green belt that surrounds the sites.

Methodology

I should like to raise a number of issues with regard to the methodology utilised by Ove Arup and Partners in their appraisal of the proposed sites. Indeed Barnsley MBC has suggested, on the basis of this appraisal, that no strongly-performing areas of Green belt are proposed for development.

EG3: Local Economy

First of all I would express concern at the approach taken to Objective EG3 relating to the local economy. I agree that it would be logical to classify development close to existing employment centres as having a minor positive effect on the economy, and remote development as neutral to the economy. I am not convinced however that the redevelopment of land previously used for employment should necessarily be automatically classified as a negative factor, given the emphasis on redeveloping brownfield sites in national planning policy. This is especially so for those sites

which have been derelict for a significant period of time. Indeed the additional work required to remediate some of these sites would create fruitful, albeit temporary specialised work in much the same way as housebuilding stimulates the construction industry more generally.

SP4: Housing

Under the proposed methodology, all sites are considered to have a significant positive effect with regard to Objective SP4 as they all contribute to the provision of new homes in the borough. I would contend however that as the various sites do not contribute equally to this outcome, they should not be considered as equally important to the objective. Instead I would suggest that the sites with larger capacities, perhaps those of 100 units or more, could be considered as significantly positive whilst those sites with lower capacities should be considered as merely positive.

SP6: Education and Skills

I have significant concern with the contention within the framework that all sites should be considered as neutral in terms of education and skills on the basis that insufficient information is held to make a robust assessment of each site’s likely impact. I believe that this is a logical fallacy as it suggests an equivalence of unknown factors, when it is entirely possible, even likely, that each site’s impact will be unknown and different.
SP7: Health, safety and security
I would agree that sites which lead to a loss of green space or allotments should be considered as having a minor negative impact on this objective. I would contend however that this consideration should be further refined, and that those developments which both result in a loss of green space and promote unhealthy travel choices through a lack of public transport should be considered as significantly detrimental under this objective.

SP8: Community

I have serious concerns with regard to objective SP8, which states that although insufficient information is available to make a robust assessment of each development’s effect on community, all sites should be treated as having a minor positive effect. This suggests an equivalence to an unknown factor unique to each development site and to the various communities bordered by those sites. I would argue instead that those sites which are large in proportion to the size of the settlements they border should be considered as having a minor or significant detrimental effect upon community.

    NR11: Land and soil

I am disappointed that this objective makes reference only to the agricultural value of the land. Open green space contributes significantly to natural drainage and flood prevention, and so I would argue that the development of agricultural land of grade 4 or worse should be considered as a minor negative factor. In addition, given the concerns raised regarding food security and supply, and the risks to the agricultural sector associated with the UK’s departure from the European Union, I would argue that the development of land of agricultural grade 3 or better should be considered a significant negative factor.

EP15: Biodiversity

I understand that Barnsley MBC’s site selection methodology has been cross-referenced with GIS data, and a professional judgement made as to the existence and extent of any likely effects. I am concerned that this test does not provide clarity regarding the assessment process for each site.

EP16: Landscape character

The landscape character of an area is extremely important, not just to existing and future residents, but also to the local economy, as has been clearly evidenced in recent cycling events in the Barnsley area. I am concerned therefore that Objective EP16 appears to have such a limited impact upon the appraisal of sites. I would argue that any development in an area with high landscape sensitivity should be considered as having a significant negative effect, as should medium- or high-capacity development in an area with medium landscape sensitivity. Low-capacity development in an area with medium sensitivity should be considered as having a minor negative effect, as should high capacity development in a low-sensitivity area. Low- and medium-capacity development in low sensitivity areas can rightly be considered as having a neutral impact.

Methodological Conclusion

I disagree with the suggestion that all sites are considered to have a significant positive effect with regard to Objective SP4. Instead I would argue that the level of impact on this objective is relative to the number of homes which could be accommodated on site.
I was concerned to read in Ove Arup and Partners’ conclusion that it was considered that all sites were expected to deliver positive benefits for Objective SP8 (Community). Whilst this assertion might to an extent be applicable to objectives regarding housing supply or economic benefit, this does not automatically follow for arguments regarding community. Indeed it is incongruous with Arup’s own methodology, which stated that insufficient information was held to determine the effect on community.
I would also argue that, considering the problems outlined previously with regard to the appraisal methodology, a number of the proposed sites can be considered to have significant negative effects upon the objectives listed in the assessment framework.
Taking into account the above considerations, the previous summary for each site should be reappraised as follows:

Original

  Revised

  Detailed Sustainability Appraisal of individual sites

  EC6 and EC7 – Land East of Sheffield Road, Oxspring

Both sites EC6 and EC7 would provide only a modest number of houses, and so they should not be considered as significantly beneficial to the delivery of housing, but rather merely beneficial. I am pleased however to see that there is a recognition that the sites are detrimental to objective SP5 in that they would promote the use of unsustainable modes of transport. As with other sites, I would express concern about the assumption that these sites are neutral with regard to their effect upon education and skills (objective SP6), when in fact this is an unknown factor.
In terms of SP7, this sites are considered by BMBC as neutral. I would disagree, as both sites would result in a loss of green space and an uptake of unhealthy transport uses. I would therefore contend that this would present a significantly detrimental factor. In terms of SP8, the two sites are very large in comparison to the existing village of Oxspring, and I believe that if the village is to be significantly enlarged with no additional facilities it will significantly harm the location’s identity as a village and create a sense that it is instead a suburb of nearby towns. In addition a key feature of Oxspring is that the built village is on the south-west side of the road, with a predominantly open aspect to the north-east. This would be destroyed completely by the development of sites EC6 and EC7, and would be a negative factor in terms of EP16.
The development of riparian sites such as EC6 and EC7 would not in all likelihood minimise or manage flood risk, and would also in this case result in the loss of Grade 3 agricultural land. As a consequence I would contend that this results in negative implications for both NR10 and NR11 and possibly NR14, as a riparian development will be more vulnerable to future climate change-related flooding.
It is evident that there is a plethora of wildlife nearby, owing largely to the riverside habitat, and the species present include water voles which are a priority conservation species protected under Schedule 5 of the Wildlife and Countryside Act 1981. I do not believe that a buffer area of only eight meters would afford sufficient protection to nearby wildlife, and would put species such as the water vole at unacceptable risk.

  EC8 – Land off Roughbirchworth Lane, Oxspring

Site EC8 would provide only a modest number of houses, and so should be considered as beneficial to housing delivery rather than significantly beneficial. I am pleased however to see that there is a recognition that the site is detrimental to objective SP5 in that it would promote the use of unsustainable modes of transport. As with other sites, I would express concern about the assumption that this site is neutral with regard to its effect upon education and skills (objective SP6), when in fact this is an unknown factor.

In terms of SP7, this site is considered by BMBC as neutral. I would disagree, as it would result in a loss of green space and an uptake of unhealthy transport uses and I would therefore contend that this would present a significantly detrimental factor.
The development would result in the loss of Grade 4 agricultural land, and as a consequence would be detrimental to NR11. BMBC’s own assessment has identified that development of EC8 would be detrimental to biodiversity.

  EC9 – Land North of Darton Road, Cawthorne

  Site EC9 would provide only a modest number of houses, and so should be considered as beneficial to housing delivery rather than significantly beneficial. I am pleased however to see that there is a recognition that the site is detrimental to objective SP5 in that it would promote the use of unsustainable modes of transport. As with other sites, I would express concern about the assumption that this site is neutral with regard to its effect upon education and skills (objective SP6), when in fact this is an unknown factor.

In terms of SP7, this site is considered by BMBC as neutral. I would disagree, as it would result in a loss of green space and an uptake of unhealthy transport uses and I would therefore contend that this would present a significantly detrimental factor.
I disagree that this site would be beneficial to the community of Cawthorne as the development, although providing only a modest number of houses, would be very large in the context of the current size of Cawthorne and would to a degree change the nature of the settlement. I would also argue that as the site is currently Grade 3 agricultural land, this constitutes a significant negative factor in terms of NR11.
I am concerned that the appraisal of this site appears to minimise or dismiss issues regarding built heritage of the area on the basis that nearby listed buildings are outside the site boundary. I would contend however that the setting of listed buildings is as intrinsic to their character as the fabric of the buildings themselves, and indeed I would contend that the development of site EC9 would be significantly detrimental to objectives EP16 and EP17 in addition to being a negative factor for EP18.

  CA2a – Land at Cawthorne

  Site CA2a would provide only a modest number of houses, and so should be considered as beneficial to housing delivery rather than significantly beneficial. I am pleased however to see that there is a recognition that the site is detrimental to objective SP5 in that it would promote the use of unsustainable modes of transport. As with other sites, I would express concern about the assumption that this site is neutral with regard to its effect upon education and skills (objective SP6), when in fact this is an unknown factor.
In terms of SP7, this site is considered by BMBC as neutral. I would disagree, as it would result in a loss of green space and an uptake of unhealthy transport uses and I would therefore contend that this would present a significantly detrimental factor.
I disagree that this site would be beneficial to the community of Cawthorne as the development, although providing only a modest number of houses, would be large in the context of the current size of Cawthorne. I would also argue that as the site is currently Grade 3 agricultural land, this constitutes a significant negative factor in terms of NR11.
I am concerned that the appraisal of this site appears to minimise or dismiss issues regarding built heritage of the area. I would contend however that the setting of conservation areas is as important as the layout of the conservation areas themselves, and indeed I would contend that the development of site CA2a would be significantly detrimental to objectives EP16 in addition to being a negative factor for EP17 and EP18.

  EC11 – Land at Silkstone Common

Site EC11 would provide only a modest number of houses, and so should be considered as beneficial to housing delivery rather than significantly beneficial. I am concerned at the statement that it is reasonable to redefine the boundary of the resultant parcel in which this site is located, when no justification is given for this redefinition. As with other sites, I would express concern about the assumption that this site is neutral with regard to its effect upon education and skills (objective SP6), when in fact this is an unknown factor.

In terms of SP7, this site is considered by BMBC as neutral. I would disagree, as it would result in a loss of green space and an uptake of unhealthy transport uses and I would therefore contend that this would present a significantly detrimental factor.
I disagree that this site would be beneficial to the community of Silkstone Common as the development, although providing only a modest number of houses, would be large in the context of the current size of the village. I would also argue that as the site is currently Grade 3 agricultural land, this constitutes a significant negative factor in terms of NR11.
I am concerned that the appraisal of this site appears to minimise or dismiss issues regarding built heritage of the area. I would contend that the development of site EC11 would have a detrimental impact upon the setting of the Huskar Memorial, and would therefore have a significant negative impact upon EP18

  EC12 – Land off Cote Lane, Thurgoland

  Site EC12 would provide only a modest number of houses, and so should be considered as beneficial to housing delivery rather than significantly beneficial. As with other sites, I would express concern about the assumption that this site is neutral with regard to its effect upon education and skills (objective SP6), when in fact this is an unknown factor.
In terms of SP7, this site is considered by BMBC as neutral. I would disagree, as it would result in a loss of green space and an uptake of unhealthy transport uses and I would therefore contend that this would present a significantly detrimental factor.
I disagree that this site would be beneficial to the community of Thurgoland as the development, although providing only a modest number of houses, would be large in the context of the current size of the village. I would also argue that as the site is currently Grade 4 agricultural land, this constitutes a negative factor in terms of NR11, and BMBC’s own assessment has identified that development of EC12 would be detrimental to biodiversity
I am concerned that the appraisal of this site appears to minimise or dismiss issues regarding built heritage of the area. I would contend that the development of site EC12 would have a detrimental impact not only upon Thurgoland, but would narrow the separation between Thurgoland and the small settlement of Huthwaite.

  SAF22 – Land North of Halifax Road, Thurgoland

  Site SAF22 would provide only a modest number of houses, and so should be considered as beneficial to housing delivery rather than significantly beneficial. As with other sites, I would express

concern about the assumption that this site is neutral with regard to its effect upon education and skills (objective SP6), when in fact this is an unknown factor.
In terms of SP7, this site is considered by BMBC as neutral. I would disagree, as it would result in a loss of green space and an uptake of unhealthy transport uses and I would therefore contend that this would present a significantly detrimental factor.
I disagree that this site would be beneficial to the community of Thurgoland as the development, although providing only a modest number of houses, would be significant in the context of the current size of the village. In addition the proximity of the site to the junction of Halifax Road/Cote lane/Smithy Hill would also lead to additional problems with the already-busy highway network. I would also argue that as the site is currently Grade 4 agricultural land, this constitutes a negative factor in terms of NR11.

476 – Land off New Road, Tankersley

Site 476 would provide only a modest number of houses, and so should be considered as beneficial to housing delivery rather than significantly beneficial. As with other sites, I would express concern about the assumption that this site is neutral with regard to its effect upon education and skills (objective SP6), when in fact this is an unknown factor.
In terms of SP7, this site is considered by BMBC as neutral. I would disagree, as whilst this is a brownfield site it would encourage an uptake of unhealthy transport uses and I would therefore contend that this would present a minor detrimental factor.
I would ask that the above points are taken into consideration with respect to the current consultation.

  Yours sincerely

 Angela Smith MP

 Penistone and Stocksbridge
 Dods Constituency MP of the Year 2011-12
 LACS Parliamentarian of the Year 2013-14