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From: Hamish Robertshaw/GBRTo: CDV Aire Valley Leeds AAPSubject: PDE00830_Harworth Estates - Aire Valley Area Action Plan RepresentationsDate: 16 November 2015 16:41:23Attachments: image001.png

Let LCC (HE Skelton Grange reps) 161115.pdfHarworth Estates AVL-AAP representation HE_1 Rail Spur.pdfHarworth Estates AVL-AAP representation HE_3 Rail Water Freight.pdfHarworth Estates AVL-AAP representation HE_4 AV68).pdfHarworth Estates AVL-AAP representation HE_5 NRW200 Employment).pdfHarworth Estates AVL-AAP representation HE_6 Interim Uses).pdfHarworth Estates AVL-AAP representation HE_7 Road Infrastructure).pdfHarworth Estates AVL-AAP representation HE_8 GI south of AV68).pdfHarworth Estates AVL-AAP representation HE_9 PedCyc).pdfHarworth Estates AVL-AAP representation HE_10 Energy).pdfHarworth Estates SAP AAP representation HE_2 AAP Outer South Boundary.pdf

Given the large number of files, please could you confirm receipt of this email andattachments. Dear Sir/Madam Please find attached ten representations submitted on behalf of Harworth Estates to the currentAire Valley Area Action Plan consultation. The representation is supported by an explanatory letter, also attached. Please note that our representation ref. HE_2 has also been submitted to the consultation on theSite Allocations Plan. Should you have any queries or wish to discuss the representations, then please contact me onthe number below. Kind regards Hamish Robertshaw, MRTPIAssociate Director, Planning – Leeds

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Your Ref

Our Ref 1516YU00

By email only 16 November 2015

Dear Sirs

Aire Valley Leeds Area Action Plan – Publication Draft

Site Allocations Plan – Publication Draft

Representations submitted on behalf of Harworth Estates

This representation is submitted on behalf of Harworth Estates as the owner of the former Skelton

Grange power station site and surrounding land located in the Aire Valley. As Harworth Estates

acquired this site in November 2014, this is its first opportunity to submit representations to the Area

Action Plan and the Site Allocations Plan which will become instrumental to the regeneration of this

important site and which it is believed can help accelerate the delivery of Leeds’ wider Enterprise Zone.

We recognise that representations at this stage are sought in relation to the soundness and legal

compliance of the draft plan. Please find enclosed a series of response forms each relating to a

different aspect of the plan, indicating why this is not sound in its current form. This is expanded upon

in the body of this letter (below) and specifically within the appended pages which supplement each

representation form completed.

We also take this opportunity to provide a context for these representations in terms of Harworth

Estates’ aspirations and strategy for the development of this site, which will realise significant socio-

economic and environmental benefits, not just for the site but also for the wider Leeds City Region.

Skelton Grange Development Aspirations (context)

Harworth Estates aspires to develop land in its ownership for a range of beneficial uses, which may

comprise:

general employment (industry/warehouse) development (in conformity with site allocations AV67,

AV68 and potentially NRW site 200)

waste disposal and energy generation (in conformity with NRW site 200)

interim and temporary use of land prior to redevelopment

use and enhancement of existing infrastructure for rail and water freight access and interchange

enhancement to road infrastructure on site and integrated with the Aire Valley central area

proposals and existing strategic network

2

enhancement of pedestrian and cycle route infrastructure (where compatible with the above)

enhancement of green infrastructure incorporating water attenuation/drainage features (SUDS) for

the wider Aire Valley (where compatible)

The Skelton Grange site has a number of significant opportunities and constraints which must be

recognised and addressed if a beneficial development is to be delivered and the Area Action Plan to be

found to be sound. At present, these are not considered to be adequately recognised and form the

basis of our representations.

Please see the enclosed representation forms as listed below. Each form is supplemented by an

additional page providing full comments in relation to soundness and our suggested changes and

explanation. These supplementary pages are also appended to this letter to provide a single

representation and cross-referenced accordingly.

No. Document Subject

HE_1 AVL AAP Skelton Grange Rail Spur Alignment

HE_2 AVL AAP & SAP Aire Valley Leeds AAP and ‘Outer South’ Area Boundary

HE_3 AVL AAP Rail and Water Freight

HE_4 AVL AAP Site AV68

HE_5 AVL AAP NRW Site 200 / Employment Use

HE_6 AVL AAP Interim Uses

HE_7 AVL AAP Road Infrastructure

HE_8 AVL AAP Green Infrastructure to South of AV68

HE_9 AVL AAP Pedestrian and Cycle Routes

HE_10 AVL AAP Energy Generation

I trust that the comments made in this letter and the enclosed forms and plans are of assistance in

refining and finalising the draft AAP and SAP for examination. Should you have any immediate queries

or wish to discuss then please contact me on the number above.

I would be grateful to receive confirmation of your receipt of this submission and to be notified of the

forthcoming stages of consultation and examination.

Harworth Estates looks forward to continuing to engage with Leeds City Council through the preparation

of the Area Action Plan and in the on-going development projects at Skelton Grange and within Aire

Valley Leeds.

Yours faithfully

Hamish Robertshaw

Associate Director - Planning

Enc.

Representation HE_1 – Skelton Grange Rail Spur Alignment

The draft AAP does not recognise the existence of the rail spur route which formerly served the power

station and (subject to further detailed technical due diligence and cost planning etc) provides a feasible

rail connection between the Central Aire Valley / Enterprise Zone and the rail network to the southeast.

With the exception of the track, which has been removed, the core infrastructure of this rail spur

remains, including bridges over the river and canal, and a motorway underpass. The retention and

safeguarding of this infrastructure is recognised in the Natural Resources and Waste Local Plan 2013

(item 19).

Harworth Estates is currently in active discussions with a national rail-freight operator which has

previously confirmed interest in entering into detailed feasibility assessment of a potential rail freight

facility at the former Skelton Grange power station site. This is on the basis that this could deliver high-

value rail-based employment at higher than average levels of GVA, which would be complementary to

(rather than in competition with) the existing facilities currently located elsewhere in the Leeds City

Region.

The publication draft AAP is considered not to be sound on the basis that it is inconsistent with the

adopted Natural Resources and Waste Local Plan 2013 and does not adequately consider or promote

use of rail freight infrastructure in this location.

To make the plan sound in this regard, the alignment of the former rail spur and its interface with the

main line should be indicated and safeguarded for potential rail freight access to serve site AV68 and

the wider employment area as shown on plan ref. A3\LLE\BUS\001_A. In particular, key existing

infrastructure should be specifically referenced and safeguarded for this purpose, including the bridges

over the river/canal, the motorway underpass and the main line interface strip south of the river/canal.

Notwithstanding its basis in the NRWLP (policy Mineral 13(5)), the indicated intermodal freight area of

search south of the river should be extended to include site AV68 and the land to the southeast of this

around the rail spur as shown on plan ref. A3\LLE\BUS\001_A.

The text at paragraph 4.5.51 should be amended to include further details as follows:

“…alongside construction of the ERF. This site benefits from a position which may incorporate the

alignment of a rail spur to accommodate rail served development or interchange. To preserve the

opportunity for rail served development the site included within the intermodal freight area of search.”


“A further 7.8 hectares of land to the south (AV68) is also carried forward from the UDP and identified

as a general employment site. This site benefits from a position that incorporates the alignment of the

rail spur which served the former power station and which may potentially be reinstated to

accommodate rail served development or interchange. To preserve the opportunity for rail served

development, the alignment of the rail spur and its interface with existing line is safeguarded, and the

site included within the intermodal freight area of search. As delivery of rail served development will

depend upon a viable proposition given prevailing demand and the cost of development, its inclusion is

not a condition of development of this site.”

A series of consequential amendments to the AAP will also be required to accommodate this, including:

alteration to the green infrastructure designation (representation HE_8)

alteration to the proposed pedestrian/cycle route designation (representation HE_9)

4

Representation HE_2 – Aire Valley Leeds AAP and ‘Outer South’ Area Boundary

In order to accommodate and integrate the prospective rail spur described in representation HE_1, we

suggest that a minor boundary change to the Aire Valley Leeds AAP and the Site Allocations Plan

‘Outer South’ area should be made. The proposed change is illustrated on plan ref.

A3\LLE\BUS\001_A.

The publication draft AAP and SAP are not considered to be sound given that the boundary alignment

between the plans/areas and the omission of detail regarding the rail spur interface with the main line

may prejudice delivery of sustainable rail freight development and is inconsistent with the adopted

Natural Resources and Waste Local Plan 2013.

The proposed change constitutes a minor extension to the Aire Valley Leeds area to incorporate

adjacent land required to connect the rail spur with the main line. It is proposed to include the land

located south of the existing boundary and north of the existing railway, predominantly east of the M1

motorway and extending approximately to the western boundary of the adjacent Rothwell Country Park.

This tract of land would enable a siding to be provided adjacent to the main line, thereby allowing freight

trains serving Aire Valley Leeds (i.e. site AV68) to access/egress the main line in both east and west

bound directions of travel.

Inclusion of this land within the AAP area would serve to clearly demonstrate the nature of the interface

between the rail spur and the main line which is required.

However, should the boundary of the AAP not be changed as described above, then recognition of the

rail spur interface should be made within the Site Allocations Plan on the ‘Outer South’ area map and

with additional text to follow paragraph 3.8.18 of the Section 3 Area Proposals ‘Outer South’

document to state:

“Aire Valley Leeds Rail Interface

The Aire Valley Leeds Area Action Plan facilitates substantial economic growth through promotion of

land for general employment development and identification of significant infrastructure upgrades.

Included within this is a potential rail freight spur to serve Aire Valley Leeds via the former Skelton

Grange power station site which would follow the alignment of the former rail spur which served the

power station and which connects with the main line south of the Aire and Calder Navigation and east

of the M1 motorway.

To allow full integration of this rail spur with the existing rail network, the development of additional

infrastructure including rail junction and siding immediately adjacent (north side) of the existing railway

will be required.”

5

Representation HE_3 – Rail and Water Freight

Harworth Estates recognises the strategic importance of Aire Valley Leeds as an existing confluence of

road, rail and water infrastructure. In order to help realise the potential of this confluence, Harworth

Estates will explore the feasibility of incorporating or facilitating the development of rail and water freight

infrastructure within its future development of the former Skelton Grange power station site. Subject to

land ownership, technical feasibility and economic viability, this may include creation of wharves to the

north side of the Aire and Calder Navigation and rail sidings/interchange within the development area.



use of rail and water freight infrastructure in relation to land north of the Aire and Calder Navigation,

including the former Skelton Grange power station site.

To make the plan sound, an additional paragraph to follow paragraph 3.5.38 should be included to

state that:

“Sites north of the Aire and Calder Navigation also have the potential to accommodate new

development of rail and water freight infrastructure and interchange facilities, subject to assessment of

technical feasibility and economic viability.”

6

Representation HE_4 – Site: AV68

The area of land identified as AV68 should be extended to the south as shown on plan ref.

A3\LLE\BUS\001_A. The current boundaries are inadequate to efficiently accommodate a rail freight

use at this site (see representation HE_1) which makes the optimum use of existing infrastructure and

ground conditions. Extension of this allocation will facilitate comprehensive development of the site,

potentially including rail freight infrastructure, and will therefore slightly increase the supply of

employment land and enhance the consequent economic benefit, not only for the site, but for the wider

Aire Valley Enterprise Zone.

The publication draft AAP is considered not to be sound on the basis that it does not make effective use

of the land and infrastructure available for employment development.

To make the plan sound in this regard, the boundary of site AV68 should be extended to the south

as shown on plan ref. A3\LLE\BUS\001_A with a consequential increase in its stated area from 7.33ha.

7

Representation HE_5 – NRW Site 200 / Employment Uses

It is recognised that NRW Site 200 is a designation of the Natural Resources and Waste Local Plan

2013 (NRWLP) rather than the AAP itself. Policy ‘Waste 6’ of the NRWLP protects this site for residual

waste treatment use (inc. energy recovery) unless it is demonstrated that there is no longer a

requirement for this to meet the needs of the district. Paragraph 3.7.15 of the AAP recognises that

planning permission is in place for an energy recovery facility at Skelton Grange.

However, its extent and the nature of uses allowed are instrumental to the comprehensive development

and employment generating potential of the wider site. In physical terms, NRW Site 200 is comprised

of two adjacent parcels of land which have significantly different ground levels. It is therefore

considered unlikely that a single site-wide development proposal (such as that permitted) will come

forward and it should be considered whether the site is likely to be fully developed in this policy context.

Harworth Estates is in active discussions with a prospective developer/operator for a ‘waste to energy’

use on the southern part of this site (s/t planning permission). Should this be developed, then the north

part of the site will remain constrained by a limitation of its use to waste treatment only.

Whilst remaining consistent with the NRWLP, the AAP should state that in the event that only part of the

site is developed for waste treatment uses, the remaining part of the site should be considered for

alternative uses (e.g. energy generation or general employment).

The publication draft AAP is considered not to be sound on the basis that it does not facilitate the

comprehensive development of this site and make effective use of the land for energy generation or

employment development.

To make the plan sound in this regard, NRW Site 200 should be indicated on the plan as an

employment site (overlaid with the waste treatment designation) as shown on plan ref.

A3\LLE\BUS\001_A. Corresponding text in the AAP document should be amended within table 2 and

at paragraph 3.2.16 and 4.5.50 as suggested below.

Table 2: Schedule of Identified General Employment Sites

Site No. Site Name Area (ha)

NRW 200 Skelton Grange (West) 11


“…Development for energy generation or general employment at NRW Site 200 is allowed provided

that it is demonstrated that there is no requirement for or feasible development for waste treatment use

for all or part of the site.”


“…Should this development not come forward, then alternative development of the site for waste

treatment and/or energy generation and/or general employment will be allowed provided it is

demonstrated that there is no requirement for or feasible development for waste treatment use for all or

part of the site.”

8

Representation HE_6 – Interim Uses

Harworth Estates recognises that the AAP will be instrumental to transforming the Aire Valley area and

realising its full development and employment potential. In contribution to this, Harworth Estates is

committed to the development of the Skelton Grange site for employment use and realisation of its full

socio-economic and environmental benefits.

Given the location of this site remote from existing road frontage or other compatible development, and

its current access and infrastructure limitations, it may be some time before the site’s surroundings and

profile are able to deliver the development in both practical and economic/market terms (unless

additional strategic changes to the road network are implemented to create or upgrade an additional

link road between the site and the M1 via Knowsthorpe Lane – see representation HE_7)

In the current context, development at Skelton Grange is anticipated to come forward in 5-10 years

when that part of the Aire Valley between the site, the A63 and the M1 is developed to create an

established employment location and provide improved access infrastructure. In the period before this,

there is not expected to be demand for substantial or high profile employment development at the

Skelton Grange site. The values that development will realise in the current context would not cover the

site preparation and infrastructure costs, thereby rendering development unviable or unattractive in the

short-term without significant additional investment from public sources.

In recognition of the above, the site presents an opportunity to accommodate temporary and informal

uses in the interim period before the ultimate development is brought forward. Such uses could

incorporate, for instance, short-term employment and outdoor open storage, energy generation and/or

construction/demolition material recycling etc, which would be served by the existing infrastructure. The

site is well suited to these type of uses given its remote location from sensitive uses such as residential

areas.

The publication draft AAP is considered not to be sound as it is not effective insofar as it does not

facilitate development capable of coming forward in the short term period before substantial

employment development is viable.

To make the plan sound in this regard, text should be included to confirm the acceptability of temporary

and informal uses provided that these can operate with existing infrastructure and do not prejudice the

ultimate development aspirations. An additional paragraph should therefore be added after

paragraph 4.5.56 to include further details as follows:

“Given the location of these sites and the cost and scale of infrastructure requirement to facilitate

development, it is likely that an interim period may occur before the ultimate employment development

proposals are deliverable. During this interim period, the sites present an opportunity for temporary or

informal uses such as outdoor storage, energy generation and construction/demolition material

recycling etc. Such uses will be supported provided that they do not prejudice the ultimate development

aspirations. The sites are well suited to these uses given the location is remote from any sensitive uses

such as residential areas, and that existing infrastructure provides access via Knowsthorpe Lane and

Skelton Grange Road.”

9

Representation HE_7 – Road Infrastructure

The former Skelton Grange power station site, and much of the Aire Valley central area, is served by

Knowsthorpe Lane, which is a private road crossing beneath the motorway and providing a link to M1

junction 45.

This represents a valuable piece of infrastructure which can provide immediate vehicular access to the

former Skelton Grange site for a range of interim uses (see representation HE_6) and, beyond that, be

upgraded to provide a primary route between the motorway and the employment development, linking

in with the wider existing and proposed network beyond.

With the upgrade to Skelton Bridge Road and its bridge over the river/canal as planned, the upgrade

and adoption of Knowsthorpe Lane could complete a link between Pontefract Road and the M1 via the

Aire Valley central area and avoiding the existing low bridge beneath the railway. This therefore

represents a significant improvement which is deliverable without wholesale new infrastructure.

The draft AAP is unclear about Knowsthorpe Lane insofar as paragraph 3.5.18 indicates that this route

may be opened up as a road and/or public transport link and a second access to the Skelton Gate area,

whereas Policy AVL12 indicates the Skelton Gate link along Knowsthorpe Lane to form a new/improved

cycle route.

The plan is therefore considered to be unsound in this regard as it is inconsistent not effective in

realising the use of Knowsthorpe Lane as an important vehicular link. To make the plan sound, policy

AVL12 should be amended to reflect paragraph 3.5.18 as follows:

“Highway Network

2. Upgrade and adoption of Knowsthorpe Lane and/or the construction of a link road, including

improvements to the junction at Skelton Grange Road and Pontefract Road and new river bridge at

Skelton Grange, to connect the A63 to Pontefract Road to the A63/M1 junction 45 to enable better road

access to employment development sites and to allow traffic including public transport and the

cycle/pedestrian network to cross the river.”

The central area map should also be amended to indicate the alignment of Knowsthorpe Lane as a

potential primary route for vehicular traffic as shown on plan ref. A3\LLE\BUS\001_A, not just for

pedestrian/cycle and public transport use.

10

Representation HE_8 – Site: Green Infrastructure to south of AV68

Harworth Estates supports the designation of land in the location south of AV68 as Green Infrastructure

(subject to the extension of AV68 and preservation of the rail spur corridor for development as per

representations HE_1 and HE_4) and its opportunity for enhancement to create a mix of natural

habitats.

The publication draft AAP is considered not to be sound on the basis that paragraph 4.5.33 is not

effective as it does not recognise the range of ecological/environmental work which will be required to

achieve the habitat creation and enhancement given the former use of the site and its existing ground

conditions.

Harworth Estates is aware that ground treatment and restoration works will be required to achieve a

high quality natural environment. This will include the import and removal of material to treat the ground

and create sustainable growing conditions. Besides the community woodland and grassland identified,

the site provides an opportunity to grow energy crops, which themselves then contribute to the

sustainable energy aspirations of the AAP.

Furthermore, this site presents an opportunity to accommodate natural type drainage features such as

SUDS ponds which may enhance biodiversity whilst serving the wider development of the area.

To make the plan sound in this regard, paragraph 4.5.33 should be amended to include further details

as follows:

“A significant opportunity is identified on the northern bank of the river. This area of land is allocated for

employment use in the UDP, but is not considered to be deliverable for development during the plan

period due to the high costs of remediating contaminated land. The land includes former sludge lagoons

associated with the Knostrop works and adjoining land to the south covering a total area of over 20

hectares. Vegetation on the land is naturally re-growing and The land provides an opportunity for

enhancement to create a mix of natural habitats including community woodland, grassland and semi-

permanent wetlands, as well as the potential to accommodate drainage features (SUDS) and to grow

crops for energy generation. To realise this potential, ground improvement works are required including

the import and removal of material to treat the ground and create sustainable growing conditions.”

Policy CAV3 should be amended to include further details as follows:

“POLICY CAV3 – GREEN INSTRUCTURE IN THE CENTRAL AIRE VALLEY

…1. Integration and improvement of 20 hectares of previously developed, former employment land, to

the north of the River Aire and west of the M1 motorway into the wider green infrastructure network,

with the potential to include drainage features (SUDS) and energy crops as well as natural habitats.”

11

Representation HE_9 – Pedestrian and Cycle Routes

Harworth Estates supports the provision and enhancement of pedestrian and cycle routes within the

Aire Valley and will seek to facilitate these within and adjacent to its Skelton Grange site providing these

are compatible with its development aspirations and on-site activities. Harworth Estates is comfortable

in principle with the prospective relocation of a pedestrian/cycle route to the north bank of the river and

will seek to ensure that any development can accommodate this wherever feasible.

However, Harworth Estates is concerned that a pedestrian/cycle route is indicated on the alignment of

the existing bridges over the river and canal which are required to provide the rail spur to site AV68 and

which is safeguarded in the NRWLP. The alignment is highlighted on the extract from AAP map 12

below, which also includes indication of the Skelton Grange Rail Spur (orange square no.19).

The publication draft AAP is considered not to be sound as it does not present a deliverable and

compatible provision for the rail spur and pedestrian/cycle route enhancement.

To make the plan sound in this regard, the map should be amended to remove the indication of

pedestrian/cycle route from the safeguarded alignment of the rail spur and, in particular, the bridge

infrastructure as shown on plan ref. A3\LLE\BUS\001_A.

See also Harworth Estates’ representation HE_2 regarding the boundary of Aire Valley Leeds in this

location and the interface between the rail spur and the main line.

See also Harworth Estates’ representation HE_7 regarding road infrastructure, which states that

Knowsthorpe Lane should not be identified as a route solely for pedestrian/cycle and public transport

use, but should be upgraded to also provide vehicular access to the employment development sites


12

Representation HE_10 – Energy Generation

Harworth Estates supports the recognition in the AAP that Aire Valley Leeds is an area with significant

potential for low carbon energy production and distribution, including the use of solar energy. The AAP

policies and supporting text, however, only support delivery of this on existing buildings and within new

developments (paragraph 3.7.10).

We consider that the AAP should focus on addressing the recognised power supply constraint within

Aire Valley Leeds rather than just promoting low carbon or renewable energy generation, which form

part but not all of the solution. A comprehensive range of temporary and permanent energy generation

opportunities should be facilitated by the AAP. This may include, for example, development of STOR

(short term operating reserve) and bio-fuel generating facilities as well as a range of renewables and

energy-from-waste as described in the AAP.

The publication draft AAP is considered not to be sound as it is not effective in realising the full energy

generation potential of the site.

To make the plan sound in this regard, the following sections should be amended to facilitate

development of a wider range of energy generation facilities.

Paragraph 3.7.10 should be amended to include further details as follows:

“Solar energy is collected through either photovoltaic (generating electricity) or solar thermal panels.

AVL is identified as an area with significant potential for installation of solar panels on existing buildings,

and within new developments and with standalone installations, including, for example, the park & ride

facility at Temple Green, and on commercial buildings with large roof areas and solar farm installations.”

An additional sub-heading and paragraph should be added after paragraph 3.7.17 to include

further details as follows:

“Flexible Energy Supply

Appropriate sites within AVL may be suitable for energy generation facilities additional to the range of

renewable and energy-from-waste infrastructure, potentially including STOR (short term operating

reserve) generating facilities. This flexible generation of electricity responds to increased demand at

peak times.”

Please also note that the publication draft AAP is numbered incorrectly between paragraphs 3.7.17 and

3.7.20.

Your city. Your plan.Working with you to find the best locations for

new homes, jobs, greenspace and retail.

Leeds Site Allocations Plan and Aire Valley Leeds Area Action Plan

Publication Draft

Response form22nd September to 16th November 2015

These Plans are now at Publication stage and this is your chance to comment on them before they are examined by a Planning Inspector. We would like to hear your views on the Soundness and Legal Compliance of the Plans.

Any terms we’ve underlined are explained in the guidance notes. Please read these before completing this form. Interactive versions of the maps and this form can be found at www.leeds.gov.uk/yourcity.

How to find out more about and comment on the two Plans:

• The easiest way to take part is online atwww.leeds.gov.uk/yourcity, where you will find a link to the interactive site maps and consultation material.

• At your local Library, One Stop Centre,or Leeds City Council Leonardo Buildingreception in the city centre

• You can also return completed responseforms to:Site Allocations: [email protected] Valley Leeds AAP: [email protected] via post to:LDF Publication Draft ConsultationForward Planning & ImplementationThe Leonardo Building2 Rossington StreetLeeds, LS2 8HD

Should you need help please phone us on (0113) 247 8092

Data Protection

The council is required by law to publish the comments you send us about the Plans, including your name and postal address. Your comments will be made available for the public to read in council offices and online. Your telephone number, email address, and signature will not be published. In addition, the council is required to provide all information submitted to us, including all personal information, to the Planning Inspectorate and their designated Programme Officer as part of the public examination of the Site Allocations and Aire Valley Leeds Area Action Plans. The Planning Inspectorate may use your personal information to contact you during the public examination process. All data provided to the Planning Inspectorate and their programme officer will be shared in accordance with the Data Protection Act 1998. Please note that we cannot provide anonymity or accept comments marked ‘private’ or ‘confidential’. Comments that include offensive, racist, discriminatory, threatening and other non-relevant statements will be destroyed.R

ef:

(For

Offi

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Onl

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We need to receive your comments by 5pm, 16th November 2015

4.3. Please give details of why you consider the Plan is/or is not legally compliant. Please try to be as precise as possible, using headings to break up your comments and continue on a separate sheet if you need to.

Please give evidence in support of the comment you gave in Part 2.

Part 4 - Is the Plan legally compliant?

4.1. Do you consider the Plan to be legally compliant?

Yes No Don’t Know (Please read the guidance notes on how to complete this section)

4.2. Which part of legal compliance is your comment about?

Local Development Scheme Planning and Compulsory Purchase Act 2004

Statement of Community Involvement Sustainability Appraisal Report

Consultation of appropriate Statutory Bodies Town & Country Planning (Local Planning) Regulations

Duty to Cooperate

Part 5 - Take part in the public examination

5.1. Your comments will be taken into account by the Planning Inspector. Would you like to take part in the forthcoming Public Examination?

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N.B. The Planning Inspector will decide the best way to hear from those who wish to take part in the examination

Part 6 - Future updates

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The Submission of the Plan(s) for Public Examination

The Adoption of the Plan(s)

Please sign and date this form

Signature: Date:

Thank you for taking the time to give your comments on the Leeds Site Allocations Plan and/or Aire Valley Leeds Area Action Plan.

If you would like to make another comment on another site or different part of the Plan (s), please use a separate response form.

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Part 1 - Your details

Please use a separate response form for each site/ part of the Plan(s) you wish to comment on.

Part 2 - What comment do you wish to make?

At this stage, before the Plan is sent to the Secretary of State for Public Examination, we are asking for your views about the ‘soundness’ of the plan. An independent Inspector will examine the plan against the ‘tests of soundness’ (Please read the guidance notes on how to complete this section)

Part 3 - Is the Plan sound?

Agent details Only complete if you are an agentPersonal details / Client details

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IF YOU HAVE COMPLETED 2.2 a - PLEASE GO STRAIGHT TO PART 3

2.1. Which Plan do your comments relate to?

Leeds Site Allocations Plan Aire Valley Leeds Area Action Plan

2.2. Which section of the Plan do your comments relate to?

a. A specific site/designation in the Plan Site reference from the document or Map (e.g. HG2-1 (3026))

Do you agree with the proposed use of this site? Yes No

Please tick all the themes you wish to comment on;

Ecology/Landscape/Tree(s) Local services/facilities Schools

Conservation/Heritage Loss of Greenbelt

Highways/transport Site Boundary (please submit a revised boundary)

Other (please specify)

3.1. Do you consider the plan to be sound?

Yes (go to Q3.3) No (go to Q3.2)

3.2. Which test of soundness are your comments about? (You must select at least one option)

Positively Prepared Effective

Justified Consistency with National Policy

3.3. Please set out why you think the Plan is sound / unsound? Your comments should briefly cover all the evidence and supporting information necessary to support or justify your view. It helps us if you can use subheadings to deal with specific issues. Please continue on a separate sheet if you need to. There may not be another opportunity to make further comments before the plan is sent to examination.

b. Another part of the Plan

Title of document (e.g. Publication Plan, background paper, sustainability appraisal)

Policy Ref. (e.g. – RTC1) Paragraph Number

Diagram / Inset Map Other IF YOU HAVE COMPLETED 2.2 b - PLEASE GO STRAIGHT TO PART 3

c. A site previously considered and not allocated in the plan (See Housing & Employment Background Paper)

Reference No (e.g. SHLAA ref)

Address IF YOU HAVE COMPLETED 2.2 c - PLEASE GO STRAIGHT TO PART 3

d. A new site which has not been considered. Please attach a site plan.

Address

IF YOU HAVE COMPLETED 2.2 d - PLEASE GO STRAIGHT TO PART 3

3.4. Please set out what change(s) you consider necessary to make the Plan sound. You will need to say why this change will make the Plan. It helps us if you can be precise as possible and providing any suggested revised wording. Please continue on a separate sheet if you need to.




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Representation HE_1 – Skelton Grange Rail Spur Alignment

The draft AAP does not recognise the existence of the rail spur route which formerly served the power

station and (subject to further detailed technical due diligence and cost planning etc) provides a feasible

rail connection between the Central Aire Valley / Enterprise Zone and the rail network to the southeast.

With the exception of the track, which has been removed, the core infrastructure of this rail spur

remains, including bridges over the river and canal, and a motorway underpass. The retention and

safeguarding of this infrastructure is recognised in the Natural Resources and Waste Local Plan 2013

(item 19).

Harworth Estates is currently in active discussions with a national rail-freight operator which has

previously confirmed interest in entering into detailed feasibility assessment of a potential rail freight

facility at the former Skelton Grange power station site. This is on the basis that this could deliver high-

value rail-based employment at higher than average levels of GVA, which would be complementary to

(rather than in competition with) the existing facilities currently located elsewhere in the Leeds City

Region.



use of rail freight infrastructure in this location.

To make the plan sound in this regard, the alignment of the former rail spur and its interface with the

main line should be indicated and safeguarded for potential rail freight access to serve site AV68 and

the wider employment area as shown on plan ref. A3\LLE\BUS\001_A. In particular, key existing

infrastructure should be specifically referenced and safeguarded for this purpose, including the bridges

over the river/canal, the motorway underpass and the main line interface strip south of the river/canal.

Notwithstanding its basis in the NRWLP (policy Mineral 13(5)), the indicated intermodal freight area of

search south of the river should be extended to include site AV68 and the land to the southeast of this

around the rail spur as shown on plan ref. A3\LLE\BUS\001_A.


“…alongside construction of the ERF. This site benefits from a position which may incorporate the

alignment of a rail spur to accommodate rail served development or interchange. To preserve the

opportunity for rail served development the site included within the intermodal freight area of search.”


“A further 7.8 hectares of land to the south (AV68) is also carried forward from the UDP and identified

as a general employment site. This site benefits from a position that incorporates the alignment of the

rail spur which served the former power station and which may potentially be reinstated to

accommodate rail served development or interchange. To preserve the opportunity for rail served

development, the alignment of the rail spur and its interface with existing line is safeguarded, and the

site included within the intermodal freight area of search. As delivery of rail served development will

depend upon a viable proposition given prevailing demand and the cost of development, its inclusion is

not a condition of development of this site.”

A series of consequential amendments to the AAP will also be required to accommodate this, including:

alteration to the green infrastructure designation (representation HE_8)

alteration to the proposed pedestrian/cycle route designation (representation HE_9)

M1

A63

Leeds Rd

A61

A639

Knowsthorpe Way

Haigh Park Rd

Bullough La

Bullough

La

KnowsthorpeRd

Sewage Work

s Rd

Thwaite La

Knowsthorpe La

Lockside Rd

Pontefract La

KNOWSTHORPE_LANE

B6481

Pontefract Rd

Stourton

John O'Gaunts

Di a t ld Ra wa y

DismtdRlyContainerBase

RothwellHaigh Workings

DogKennelHill

ParkWood

PumpWood

SpringWood

TempleNewsamParkGolfCourse

MatherWood

DunstanHills

BellWood

DismantledRailway

Knostrop

Tanks

GolfCourse

WorksRifleRangeSewageWorks

ContainerBase

StourtonSidings

FreightlinerTerminal

IndustrialPark

WatersideIndustrialPark

KnostropSewage

FarmHaighCottage

HaighFarmRose Cottage

Farm

Works

Works

SkeltonMoor

Works

WarehouseWarehouse

Museum

College

CR

ETL

DrainDrai

n

Drain

Track

Drain

Drain

Drain

Gantry

Gantry

Track Track

WarehouseWarehouse

River AireRiver Aire

WardBdy

Pipe Line

Wyke

Beck

River Aire

Boro Cons

t& Wa

rdBdy

Aire andCalderNavigation

M 1

M 1

M 1

A 63WES

T ROAD

SOUTH ROAD

432500 433000 433500 434000 434500 435000 435500 436000

429500

430000

430500

431000

431500

432000

BUSINESS SPACE

PROPOSED AMENDMENTS TOAVL AAP CENTRALAREA PLAN.

A3\LLE\BUS\001

MR16/11/15

DT16-11-15

1:11,500

SKELTON GRANGE ROAD, LEEDSWEST YORKSHIRELS10 1RR

REPRODUCED FROM ORDNANCE SURVEY MAP DATABY PERMISSION OF ORDNANCE SURVEY ON BEHALFOF THE CONTROLLER OF HER MAJESTY'S STATIONERY OFFICE.© CROWN COPYRIGHT 2015 ALL RIGHTS RESERVED.LICENCE No. 100030994.

A

FIRST ISSUEDRNDATE

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DRAWNDATE

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ArcGISA3

SCALE :-

DRAWING No.

THE COPYRIGHT IN THIS DRAWING BELONG TO HARWORTH ESTATESAND THE DRAWING MAY NOT BE REPRODUCED WITHOUT PRIOR CONSENT.

DEPT :-

TITLE :-

SITE NAME :-

Harworth Estates 2015 ©

E

0 100 200 300 400 500 600 700 800 90050 Meters

A3\LLE\BUS\001Legend

Harworth Estates OwnershipDevelopment Classification

Knowsthorpe Lane (upgrade to provide link road)Rail Link New / Extended Employment AreaMinerals 13 (5) Intermodal Freight Proposed Extended AreaExisting AAP BoundaryExtended AAP Boundary

p_title: Mr

p_fore: Stuart

p_sur: Ashton

p_job: Planning and Development Manager

p_org: Harworth Estates

p_pcode: S60 5WG

p_phone:

p_email:

a_fore: Hamish

a_sur: Robertshaw

a_title: Mr

a_org: Cushman & Wakefield

a_pcode: LS1 2ND

a_phone: 0113 2337465

a_email: [email protected]

2_2b_Title: AVL AAP publication draft

2_2b_Policy:

2_2b_Diagram:

2_2b_Para: 3.5.38, 4.5.52

2_2b_Other:

2_2c_Ref:

2_2c_Addr:

2_2d_Addr:

3_3_Sound: Please see Cushman & Wakefield explanatory letter and appended page regarding 'Representation HE_1 Rail Spur Alignment'

3_3_SoundChange: Please see Cushman & Wakefield explanatory letter and appended page regarding 'Representation HE_1 Rail Spur Alignment'

2_1Plan: 2_1_AVL

2_2_Agree: Off

2_2a_GRN: Off

2_2a_SCH: Off

2_2a_LSF: Off

2_2a_CNV: Off

2_2a_HWY: Off

2_2a_OTH: Off

2_2a_Ref:

2_2a_OTX: Rail infrastructure

a_job: Associate Director - Planning

2_2a_BND: Off

3_1_Sound: 3_1_No

2_2a_ECO: Off

4_1_Legal: 4_1_Yes

4_2_CSB: Off

4_2_LDV: Off

4_2_DTC: Off

4_2_PLN: Off

4_2_SST: Off

4_2_LCL: Off

3_2_Cnst: Off

3_2_Prep: Off

3_2_Jstf: Off

3_2_Effc: On

5_1_PEX: 5_1_Yes

4_2_COM: Off

6_1_Sub: On

6_1_ADP: On

4_3_Legal:

p_Add1: AMP Technology Centre

p_Add2: Brunel Way

p_Add3: Rotherham

a_Add1: St Paul's House

a_Add2: 23 Park Square South

a_Add3: Leeds

6_1_Date: 05/11/15

6_1_Sig: Hamish Robertshaw

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5

Representation HE_3 – Rail and Water Freight

Harworth Estates recognises the strategic importance of Aire Valley Leeds as an existing confluence of

road, rail and water infrastructure. In order to help realise the potential of this confluence, Harworth

Estates will explore the feasibility of incorporating or facilitating the development of rail and water freight

infrastructure within its future development of the former Skelton Grange power station site. Subject to

land ownership, technical feasibility and economic viability, this may include creation of wharves to the

north side of the Aire and Calder Navigation and rail sidings/interchange within the development area.



use of rail and water freight infrastructure in relation to land north of the Aire and Calder Navigation,


To make the plan sound, an additional paragraph to follow paragraph 3.5.38 should be included to

state that:

“Sites north of the Aire and Calder Navigation also have the potential to accommodate new

development of rail and water freight infrastructure and interchange facilities, subject to assessment of

technical feasibility and economic viability.”

p_title: Mr

p_fore: Stuart

p_sur: Ashton

p_job: Planning and Development Manager

p_org: Harworth Estates

p_pcode: S60 5WG

p_phone:

p_email:

a_fore: Hamish

a_sur: Robertshaw

a_title: Mr

a_org: Cushman & Wakefield

a_pcode: LS1 2ND

a_phone: 0113 2337465

a_email: [email protected]

2_2b_Title: AVL AAP publication draft

2_2b_Policy:

2_2b_Diagram:

2_2b_Para: 3.5.38

2_2b_Other:

2_2c_Ref:

2_2c_Addr:

2_2d_Addr:

3_3_Sound: Please see Cushman & Wakefield explanatory letter and appended page regarding 'Representation HE_3 Rail and Water Freight'

3_3_SoundChange: Please see Cushman & Wakefield explanatory letter and appended page regarding 'Representation HE_3 Rail and Water Freight'

2_1Plan: 2_1_AVL

2_2_Agree: Off

2_2a_GRN: Off

2_2a_SCH: Off

2_2a_LSF: Off

2_2a_CNV: Off

2_2a_HWY: Off

2_2a_OTH: Off

2_2a_Ref:

2_2a_OTX: Rail and water freight infrastructure

a_job: Associate Director - Planning

2_2a_BND: Off

3_1_Sound: 3_1_No

2_2a_ECO: Off

4_1_Legal: 4_1_Yes

4_2_CSB: Off

4_2_LDV: Off

4_2_DTC: Off

4_2_PLN: Off

4_2_SST: Off

4_2_LCL: Off

3_2_Cnst: Off

3_2_Prep: Off

3_2_Jstf: Off

3_2_Effc: On

5_1_PEX: 5_1_Yes

4_2_COM: Off

6_1_Sub: On

6_1_ADP: On

4_3_Legal:

p_Add1: AMP Technology Centre

p_Add2: Brunel Way

p_Add3: Rotherham

a_Add1: St Paul's House

a_Add2: 23 Park Square South

a_Add3: Leeds

6_1_Date: 05/11/15

6_1_Sig: Hamish Robertshaw

btnSubmit:




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Data Protection

The council is required by law to publish the comments you send us about the Plans, including your name and postal address. Your comments will be made available for the public to read in council offices and online. Your telephone number, email address, and signature will not be published. In addition, the council is required to provide all information submitted to us, including all personal information, to the Planning Inspectorate and their designated Programme Officer as part of the public examination of the Site Allocations and Aire Valley Leeds Area Action Plans. The Planning Inspectorate may use your personal information to contact you during the public examination process. All data provided to the Planning Inspectorate and their programme officer will be shared in accordance with the Data Protection Act 1998. Please note that we cannot provide anonymity or accept comments marked ‘private’

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