The Local Plan - Regulation 24

We've now been provided with the two key documents that are our guide to the Inspector's examination of the Borough Council's Local Plan proposals. These are below and comprise:

Harrogate Local Plan Exam Guidance Note
Inspector's Matters in Question

When reading these documents (the second one is 25 pages long and only part refers to the Parish) please note in the guidance note the dates for both the submission of requests for representation as well as the examination timetable.

Both are worth reading in full and the PC has taken advice from its principal consultancy - Arrowsmith Associates (AA) - as to how best to respond to the examination.


The PC has now prepared its submission to the Inspector (submitted on 7th December) and it uses the key reference documents shown in the list below (all referenced as "PBB" for clarity).

For ease of reading, the covering email submission to the Programme Officer is shown below as well as the combined "Matters" which were attached to the submission.
Submission to the Programme Officer
Combined Matters

PBB list:

PBB1 - PBB1 - Detailed HEDNA appraisal Oct 2018
PBB2 - Smeeden Foreman Landscape Reports March 18, parts a, b and c
a - PBB2a
b - PBB2b
c - PBB2c
PBB3 - PBB3 - Appraisal of sites Nov 2018
PBB4 - PBB4 - SHELAA covering document
PBB4 Visuals- Figure 2 Boroughbridge Kirby Hill DishforthFigure 3 Cattal Green Hammerton Kirk HammertonFigure 4 Flaxby Pannal HubyFigure 5 MiddletonFigure 6 Northeast Harrogate South KnaresboroughFigure 7 Northeast KnaresboroughFigure 8 Northwest Harrogate Killinghall RipleyFigure 9 RiponFigure 10 Southeast HarrogateFigure 11 Southwest Harrogate BeckwithFigure 12 Tockwith Long Marston Wetherby
PBB5 - PBB5 - AA Full Report March 2018
PBB6 - PBB6  BWB Transport Assessment
PBB7 - PBB7 - THaT - Review of Transport Issues
PBB8 - PBB8 - AA Aug 2017 Report
PBB9 to 11 - PBB 9 10 and 11 combined visual
PBB12 -  Cumulative traffic Study - Western Arc
PBB13 - Supporting drawings of Western Arc allocations

Additional information for reference only (not necessarily submitted to the Inspector).

In preparing its materials for the examination The PC has used a range of source documents it has commissioned or been party to during the  Consultation Period in March 2108 and beyond. The list (not exhaustive) is shown below:

Submissions made in March 2018 and uploaded noto the planning portal:
DM1 Housing PN17 PD1195 ID 1155764 9-3-18
DM1 Housing PN19 PD1197 ID 1155764 9-3-18
DM2 Employment PN 18 PD1196 ID 1155764 9-3-18
For ease of reference, the PC prepared a document with combined submissions as shown on the HBC portal: Combined submissions
The original documents are here:

The PC commissioned further studies which are attached below:
Appraisal of sites from LUC report Nov 2018
The Full LUC report
Review of Transport Issues Nov 18
Detailed HEDNA appraisal Oct 2018

With HAPARA, The PC commissioned BWB transport consultants to carry out a "cumulative impact" traffic study to consider the effect of developments planned in the western arc of Harrogate. The relevant source documents are here:

BWB report - cumulative impact study
Supporting evidence from HAPARA
HAPARA Executive Summary - Matter 15.1

Additional supporting documents are here:
Crimple Valley SLA assessment area 58
Crimple Valley SLA assessment area 60

For the Spring Lane application submitted by a private developer outside the Local Plan but on PN17, the PC noted and endorsed the SLA Group's objections here:
SL 48 house application objection
Smeeden Foreman Landscape Report Nov 18
Exigo Transport report Nov 18 

Final Reminder and Guide

Revised and simplified information for residents yet to comment on the local plan.

The PC's submissions are now in.

For your information, the combined submissions are included in this single PDF - Combined Local Plan submissions.

On behalf of the Parish Council, can we thank all residents who submitted comments as well as those who took part in the efforts to spread the word, fathom out the submission process, and who helped at the drop in day and draft comments. We wait and see.

The final specialist consultants reports are now uploaded below and residents might like to view the three key reports: Arrowsmith's, BWB's traffic analysis (in two parts) and Smeeden Foreman's Landscape review


There are four ways to comment and templates for each are included alongside the description below:

On the Portal – see the instructions and follow this format. “How to access the portal” (with thanks to Steve Phillip) and Guidance for HBC Portal Access and “Step by step guide to commenting” (with thanks to Ryan Dall): Step by Step Guide to Commenting - both of these are in the section below.
Using a Word document –  HBC Word based response form - Word Based Response form. Use this document and then send it to Planning Policy by email at copying it to
By an email message – send as above, in your own words, but try to follow the format for either the Portal or the Word Document.
Or by post. Using the Word document, hand write or do it electronically and print off and deliver by hand to the Council’s offices (advice at this stage not to risk the post) – address of the new offices is: Harrogate Borough Council, Civic Centre, St Lukes Avenue, Harrogate, HG1 2AE. Make a copy of your submission if you can.

Below, we’ve provided examples of each format:
Portal Response. Follow the guides above for commenting using the portal. An example of how a form might look is here PC Portal Response PN17
Word based response. The form is here Word Based Response form. You can find an example of how this might look filled in here for PN17: HBC Response Form Example - PN17 and with a continuation sheet for box 6 (which has limited space for commenting) HBC Response Form Example - PN17 continuation sheet. For PN19, the response can be similar though you need to adapt your comments to any specific features of PN 19 that differ from those of PN17.
For PN18, use the same format but the allocation is DM2 not DM1 and read the Arrowsmith report on Employment Land Calculation (in sources below)
Email formatExample of email text Local Plan PN19

Rules to follow:
Make sure you make a separate comment for each of the sites – PN17, PN 18 and PN19
Use the sources of information below.
Do not directly copy other reports – try to make some variations even between separate comments from the same household
Try to link your comments to the Council’s proposals.

Sources. The sources are quite varied and they are worth a read through to select the material to suit you. They include:
The reports from the PC’s consultants – Arrowsmith Associates (final report) Arrowsmith final report. BWB for traffic (final report now attached - see the conclusions on pages 44-45) - BWB report part 1 - and with appendices - BWB report part 2 - and Smeeden Foreman for Landscape and Visual Impact Assessment (LVIA) 
The PN 18 report Employment Land Calculation
Save Crimple Valley document – mainly authored by Denis Kaye - SCV response
Spring Lane Group's response is now posted on the portal and is here: Spring Lane Group response

The PC will upload its comments onto the HBC Portal on Friday after the Parish Council meeting on Thursday evening. 

You may also wish to revisit the comments made in 2017 in the reference documents section. The arguments are still the same and HBC have not changed their  proposals. PN17 responsePN18 responsePN19 and PN20 response.

HAPARA documents – useful to get a feel for the opposition from the areas to the west and north of our Parish.  Portal response - HAPARA draft and Addendum to HAPARA response

Hampsthwaite documents - there are several worth viewing but go to the HAG website - or download their presentation here: HAG presentation

The PC will be completing a collective response on behalf of all residents who are on the PC’s newsletter list. If you’re not on but want to be included in our collective response, please advise the Parish Clerk.

The Local Plan - How the Parish Council is responding

The page will be updated as we go through the consultation process (see the section at the bottom of the page for helpful reference documents)


The preliminary report is now ready. You can view it here: local response guide v4
It is not yet complete but we wanted to provide it in its current form to give you food for thought. Our advice is not to comment yet as we'll be providing a more information and comprehensive guide on "how to" in the next few days.
We will warn everyone through Facebook and the Parish Newsletter of updates.

Supporting documents you may wish to view to help formulate your responses:
The Arrowsmith Preliminary reportPreliminary Report
The BWB traffic survey commissioned by Arrowsmith on the PC's behalf - first draft: Draft Transport Assessment. Compare this with the Borough wide Jacobs UK Ltd report commissioned by the Council - Jacobs Ltd traffic modelling report for HBC - Not all of this applies to our Parish area but looking at Table 10 on page 18 shows that even they predict some of the junctions close to us as at or over 100% capacity (anything above 85% should not be accepted). BWB will highlight these and other aspects in their final reports.

Further reports will be with us on Wednesday for publication here on Thursday. these include: the updated BWB traffic survey, the Landscape and Visual Impact Assessment (LVIA) and the PN18 Economic needs report. These should be useful source documents that you might want to use in conjunction with other materials on this page.Keep watching this page.

The PC will be pulling together its full response from Monday 5th March - it will be posted on the site when it is complete.

Commenting on the plan.
Here we provide some guides for accessing the portal - the recommended method for commenting - and some content that you may wish to use to populate your responses. Don't forget that you can also draw on the content of our 2017 responses (there are links to these below). The guides and contents documents are shown below but we will be adding more information in the next few days to help you:

How to access the portal (with thanks to Steve Phillip): Guidance for HBC Portal Access
Step by step guide to commenting (with thanks to Ryan Dall): Step by Step Guide to Commenting
Content that you might find useful explaining what "legal compliance" and "soundness" are and how to make relevant comments on these points (with thanks to Denis Kaye for pulling together such a clear document): Comments on the final consultation - Denis Kaye.
Additional content with direct paragraph references to the local plan, pulled together for the SCV group courtesy of Denis Kaye - SCV responses to Draft Local Plan
Remember to make sure that when using the portal, you prepare your answers in a Word document or draft email format as the portal only allows you to be logged in for an hour before you have to log in again.
For those wishing only to email their comments to HBC, please do so in a format that reflects the format of the portal response and contains material similar to the content of Denis Kaye's guide or other source documents of which there are many.

The PC's full reports will be published as soon as is feasible but you may wish to view these in addition:
HAPARA response to the Jacobs traffic report
HAPARA comment on lack of representation
Hampsthwaite SEA directive paper

You can also use a Word document (that you can either download from the HBC website here: or use this version (now that HBC has reformatted it): HBC Word based response form. We hjave included a template guide here: Example Portal Response and you can find an example of how this might look filled in here: HBC Response Form Example - PN17 and HBC Response Form Example - PN17 continuation sheet. Feel free to use these to help complete your comments - remembering to do separate comments for PN18 and 19. Email these comments to but PLEASE, COPY TO - - so that we’ve a record of the response.

For those of you that have tired of wrestling with the portal, you can submit your comments by email but PLEASE, COPY ME - - so that we’ve a record of the response.

You should all have received your leaflets (please advise the Parish Clerk if you have not). This leaflet should help you review the plans and procedures and make sense of the results of the initial consultancy that we have commissioned to be available on this site shortly.

A copy of the leaflet distributed to all householders is here: Local Plan leaflet
You might also find the leaflet by HAPARA (Harlow and Pannal ash Residents Association) of value as it covers the area to the West and north of our Parish: HAPARA Leaflet

And a date for your diary: the PC will be running an open information session in Pannal Village Hall on Saturday 24th February to advise residents on the best way to comment on the Local Plan. We will have paper copy examples of how to comment and there will be an online demonstration set up available.
Please put this date in your diary, circulate the details and come along between 10.00 am and 4.00 pm. 

If you can help at the 

open information session o

n 24th, please contact Andrew on or 07802460789


As of 26th January 2018 the "Public Consultation" phase of the local plan began. In outline this means that from now to 9th March HBC will conduct a public consultation of the proposals - to which, unless they have changed significantly - the PC, on behalf of the residents, will object.

For reference, these were our responses to the last Consultation

To help us prepare our response to this public consultation, the PC put out to tender for professional consultancy support. The tender action was approved at the 14th December PC Meeting and the tender document is shown here: Tender Document (The process for the Local Plan is explained in the Tender document for those interested in reading it in outline). The companies that responded were considered and appointed according to the rules laid down in the PC's standing orders.

The PC has appointed a Local Plan Sub-Committee consisting of the PC's Chairman (Howard West) and Deputy Chairman (Dave Oswin) to consider the proposals submitted. The Sub-Committee appointed Arrowsmith Associates as the Project Planning consultancy.

Responding to the Local Plan proposals during the Consultation Phase 
(for a Word version of the website copy below, click here - Responding to the Local Plan)

All residents should have received correspondence from the Borough Council on the “District Local Plan Publication Draft Consultation 26 January - 9 March 2018”. You can read it here - District Local Plan Draft Consultation. This is worth reading carefully and it is also explained in more detail at this link -

Essential points to note about this process:
· The Consultation Period is the final chance that we all have to comment to the Borough Council on their proposals.
· None of the comments to the local plan proposals made by the PC or residents to previous consultations will be considered.
· Only comments made during this consultation period will be included in the documents considered by the Planning Inspector.
· Irrespective of the outcome of the Consultation Phase (in other words, whatever the Borough Council takes from the consultation responses), the Local Plan will be submitted to the Planning Inspectorate - possibly by the end of this year, if not in early in 2019. At this point, the Plan will be tested for “soundness” against four measures:
- Positively prepared –i.e. based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development.
- Justified – i.e. the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
- Effective – i.e. be deliverable over its period and based on effective joint working on cross-boundary strategic priorities.
- Consistent with national policy –i.e. be consistent with the National Planning Policy Framework - the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

What the PC is doing. To help build our case, the PC will be taking advice from its appointed professional advisors on how best to respond to the proposals and reinforcing its objections made in earlier consultations. The professional advisors acting for the PC and the parish are:
· Arrowsmith Associates – project planning and overall consultancy support.
· Smeeden Foreman – Landscape and visual impact assessment.
· BWB - traffic analysis.
And you may see their representatives working in our area in the next few weeks.

What we plan to put forward are specific objections on the basis of:
· Process/policy.
· The housing need numbers.
· Infrastructure and traffic issues.
· Environmental.
· Landscape and visual assessment.
· The lack of consultation and consistency.
· In addition, we will look carefully and use the arguments as to why the developments at, for instance, Rossett Green Lane, Cornwall Road and other applications have been rejected.

What residents should do.
· Once sufficient professional advice has been received to provide a sound basis for residents to comment or object, we will provide a guide on this site in good time for you to comment before 9th March.
· Nevertheless, this should not stop residents starting the objection process straight away (see the Council’s consultation paper for how to comment).
· We advise you to use the portal – links to our areas are shown below and remember that you have to log in to comment:
- PN 17 and 19 -
- PN 18 -
- PN 20 (the potential expansion of Pannal School should development take place) -
· Or, if you wish, you can use this form they’ve provided - HBC's consultation form  
· You can always add to your comments later once you have seen the specialist consultancy reports.
· Remember – it is important to gather as many comments as we can.

We therefore recommend strongly to residents to proceed as follows:
· Read up on the Local Plan Proposals – use the links above – with an eye on the eventual tests of "soundness” that will be applied – and if possible highlight which of the “soundness” measures you think the plans contradict.
· Consider holding back on your objections until the PC has received advice from its consultancy as to how best to do this. The results of our preliminary findings will be available here by 14th February – we will advise you by newsletter and place a reminder on our Facebook page when these findings are in.
·  Make sure you come along to our information session on Saturday 24th February.

For more information on the Examination Phase and what we will be doing after the Consultation Phase is over, please download the full document - Responding to the Local Plan - full document

Everyone who is on the PC's newsletter list will receive updates when appropriate with links from our Facebook site. If you are still not on the newsletter list, please let the parish clerk know.

For any further information please contact the Parish Clerk.


Planning - a quick guide to the process

A simple guide to the planning process

We’ve tried to simplify what is a complicated and often confusing process. We'll update this section as needed.

The first things to understand are that:
The Parish Council has no planning powers. It is a statutory consultee along with members of the public.
The Parish Council can and will comment on applications when sent to them by the Borough Council.
However it can, like any member of the public, comment on applications outside the Parish boundary. In reality, the PC would only do this if there was a potential effect on the Parish – such as increased traffic, strain on the infrastructure etc.
Within this Parish Council, all planning applications when received are considered by the Planning Committee which normally meets before the monthly Parish Council meeting. Applications are included on agenda, published at least three working days in advance and the planning reference is public available for all to see, either on the Parish Council Notice Board or on line in the agenda and minutes section of the website. Residents can look at the agenda to view the applications under consideration and are free to attend the meetings.

Prior to the meeting, on receipt of the Agenda, the Planning Committee members will review the application using the link on the Agenda item to familiarise themselves with the details of the application and in particular to review any neighbour comments.

Once the Committee has made a recommendation, the Parish Clerk then reports to the Borough Council their comments which can be one of:
A. The Parish Council has no objections
B. The Parish Council objects on the planning grounds set out overleaf [here, we provide a statement as to why the Parish Council objects – and I has to be on “planning” grounds]
C The Parish Council does not object to or support the application but wishes to make comments or seek safeguards as set out overleaf [here we provide a statement to supporting this choice]
D. The Parish Council supports the application.

These comments are filed on the planning portal by the Borough Council's Planners.

Subsequently, we receive notification of the decision by the planners – this is then published on the planning portal.

The Borough Council works in a slightly different way.
Small applications – from household improvements, small scale developments and matters such as commercial signage – are dealt with by the planning officers who seek comments as described above.
Larger applications – such as Dunlopillo or the Rossett Green Lane application go through the same process (where the Parish Council has a voice along with members of the public) but the application is scrutinised by the Borough Council’s Planning committee.

The Borough Council’s Planning committee function is to either approve or reject planning applications in excess of 49 dwellings made to the Council by landowners or householders or if the development is deemed to be of such importance that the planners feel it should be considered by the committee. The best example of this is the Dunlopillo development where the threshold of 50 dwellings is exceeded.

The Local Plan is very different. The Local Plan process is about earmarking land allocations for housing and employment sites for the next 20 years and the Borough Council’s Planning Committee does not have any say in the development of the plan.

The Borough Council’s website give an indication of the various levels of consultations and consideration that goes into the Local Plan process – here:

For more general planning advice, there are some good reference sites:
For information on whether planning permission is required, this site provides a simple and easy to use guide -
The Borough Council website provides its own guide to planning applications -
To view the details of an application, you need the reference number (typically 17/12345 [year/with five digits] and put this into the search box on the applications portals here:

We hope that this guide will help to clarify what is a complex and often confusing process. If in doubt, contact the Parish Clerk for more information.

Reference Documents

Below you'll find downloadable documents that were used to help comment or make your objections to the initial consultation phase of the Local Plan. We'll keep them here but add new information for when the next phase of consultation opens in January 2018.

The old documents below

Planning Response Leaflet that we delivered to all resident of the Parish. Please ensure you have responded by 11th August.
How to comment explains the three ways to respond to the proposals (in Word for you to copy and paste as needed). We have included below examples of objection letters and text that should be useful for you to download, use as a template and stimulate your ideas for objections. Please do not simply copy and paste the contents but use them to help you create your own arguments.
Please also read the two site assessments in the links below that help to understand whether the planned development sites are suitable or not - these documents will help you frame your arguments. They are quite long and complicated, but worth reading both of them carefully. Draft sustainability appraisal and Built and Natural Environment Assessments. Look at the Council's traffic light system in the first one which shows the effects of various criteria to help you to formulate and reinforce your objections - look for categories that are red or orange rather than green - focus your attention of the red and orange ones. HBC decided on these ratings so should abide by them. The following examples (which download as Word documents) should be useful especially when you've read the HBC assessments above.
Example A- general letter of objection PN19 Example B - environmental grounds Example C - testing the soundness of the local plan Example D - building a strong argument
We will keep adding to the list.

The effects on our community (in Word for you to use as you wish).
On line Portal guide The guide to Harrogate BC's on line portal.
Parish Map with proposed sites included and an illustration of the same area overlayed on an air photograph Air photo with overlay of PN18-19-20

As an additional source of information you might like to have a look at some other sites, shown below. Note: these are not endorsed by the Parish Council but they do provide a great deal of supporting information in a well presented way should you decide to object to the proposals. where there is a useful response guide. Contains very useful PN 17 (Spring Lane) specific information.