1.1 The National Planning Policy Framework (NPPF) states that effective and on-going joint working between strategic policy-making authorities and relevant bodies is integral to the production of a positively prepared and justified strategy. To demonstrate effective and on-going joint working, paragraph 27 of the NPPF requires local authorities to prepare a statement of common ground documenting the cross-boundary matters being addressed and progress in cooperating to address these.

1.2 This statement of common ground has been prepared to meet the requirements of the NPPF, in line with national planning practice guidance, and to form part of the evidence required to demonstrate that East Riding of Yorkshire Council have complied with the Duty to Cooperate[1]. The duty requires local planning authorities to:

· engage constructively, actively and on an ongoing basis; and

· have regard to the activities of other bodies

1.3 This statement of common ground has been prepared ahead of the council’s submission of the Local Plan Update to the Secretary of State.

2. Relevant Parties and Signatories

2.1 East Riding of Yorkshire Council share a direct land boundary with the following Local Planning Authorities who are signatories to this statement:

Unitary Authorities:

City of York Council

Doncaster Council

Hull City Council

North Lincolnshire Council

Two-tier Authorities:

North Yorkshire County Council (upper tier authority)

Ryedale District Council

Selby District Council

Scarborough Borough Council

2.2 One further authority (North East Lincolnshire Council) is separated by the Humber Estuary but is included as a signatory to this statement for completeness.

2.3 Following the government consultation on reorganisation it was announced in July 2021 that the current county, district and borough councils would be replaced by a new single council for North Yorkshire in April 2023. The new council will be the largest geographically in the country. Councils affected are Craven District Council, North Yorkshire County Council, Hambleton District Council, Harrogate Borough Council, Richmondshire District Council, Ryedale District Council, Selby District Council and Scarborough Borough Council. York City Council will continue to operate as it is. This statement will be updated in due course to reflect the new governance arrangements.

2.4 Joint working has been ongoing with neighbouring authorities through the plan making process, and this has identified a number of strategic issues which are set out in section 3. Figure 1 below shows the East Riding and its wider context.

Figure 1: The East Riding and its wider context

2.5 Table 1 (overleaf) notes the agreements relevant to each individual neighbouring Local Planning Authority. The following signatories confirm there is common ground on the relevant agreements and that the strategic matters are agreed.

Table 1: Relevant Neighbouring Local Authorities

Organisation	Relevant Agreement(s)	Signatory
Local Authority
City of York Council	1,2,3,6,7,8,9	Signed: Date: Name: Position:
Doncaster Council	1,2,4,5,,8,9	Signed: Date: Name: Position:
Hull City Council	1,2,3,4,5,6,7,8,9	Signed: Date: Name: Position:
North East Lincolnshire Council	1,2,4,5, ,8,9	Signed: Date: Name: Position:
North Lincolnshire Council	1,2,3,4,6,7,8	Signed: Date: Name: Position
North Yorkshire County Council	1,2,3,4,5,7,8,9	Signed: Date: Name: Position:
Ryedale District Council	1,2,4,5,,8,9	Signed: Date: Name: Position:
Scarborough Borough Council	1,2,4,5,,8,9	Signed: Date: Name: Position:
Selby District Council	1,2,3, , ,7,8,9	Signed: Date: Name: Position:

3. Strategic Matters

3.1 Section 2 of the Local Plan Strategy Document Update (Key Spatial Issues) sets out the principal cross boundary interactions between East Riding and neighbouring authorities. This recognises that the East Riding is a large, predominately rural, unitary authority and contains several economic and housing markets.

3.2 Joint working throughout the plan-making process has focussed on strategic matters that have the potential to raise cross boundary issues. The Consultation Statement accompanying the Local Plan Update sets out how the council has consulted with relevant parties including neighbouring authorities.

3.3 The strategic matters have been identified as:

· The Scale and Location of Housing Development

· Travelling Communities

· The Scale and Location of Employment Development

· Minerals and Waste

· The Scale and Location of Retail Development

· Strategic Transport Infrastructure

· The Natural Environment

· Flood Risk, Coastal Change and Water Quality

3.4 There are no unresolved strategic issues. The position on each of these issues is outlined below.

Scale and Location of Housing Development

3.5 The Local Housing Need Assessment (LHNA) (2022) concludes the East Riding is broadly a self-contained housing market area albeit there are strong levels of migration into and out of urban centres, particularly Hull and to a lesser extent, York. Migration out of Hull is notably higher than in-migration. There is also a strong need and demand from housing generated from within the East Riding as a consequence of changing household size and the difficulty in accessing affordable properties.

3.6 The standard methodology for determining local housing need (LHN) set out in the NPPF results in a figure of 909 dpa for East Riding (base date at April 2020). Reflecting on past levels of delivery and the need to further boost affordable housing, a requirement of 20,900 net additional dwellings over the plan period is set out. This translates to 1,100 dwellings per annum from 2020. The council is therefore meeting in full (and exceeding) the identified LHN for the authority area. The Local Plan Update is not required to meet the unmet needs of any other authority nor has any other authority requested their housing needs to be addressed through the preparation of the Local Plan Update.

3.7 Setting a local plan requirement higher than the LHN will support the delivery of affordable housing which is a key challenge for the East Riding as evidenced through the LHNA and is consistent with the level of housebuilding the market is capable of delivering over the long-term.

3.8 Delivering the full identified need for affordable housing as set out in the LHNA (2022) is not considered to be a realistic policy option. Based on the current affordable housing policy, and taking viability issues into consideration, the amount of overall housing required would need to be close to 3,700 dwellings per annum. As recognised previously by the Local Plan Inspector for the Adopted Local Plan (2016), such an approach would result in a scale of development that would significantly exceed the LHN and would undermine the aim of sustainable growth and have serious implications for the delivery of housing in the City of Hull.

3.9 The distribution of development set out across the Settlement Network reflects individual needs and challenges of each settlement, taking a view of what can be delivered in different locations. Over 75% of residential development will take place in the Major Haltemprice Settlements[2], Principal Towns and Towns. The scale of development planned for the Major Haltemprice Settlements is commensurate with their size and role alongside the City of Hull, recognising the need to support the regeneration interventions and development proposals within the city.

Agreement 1

Local planning authority signatories agree that their respective plans are committed to meeting or exceeding their Local Housing Need (LHN) within their respective planning authority areas and that the East Riding Local Plan Update is not required to accommodate any unmet housing requirements from neighbouring local authorities. There are no unresolved strategic issues relating to housing.

Travelling Communities

3.10 An updated Gypsy and Traveller and Travelling Showperson Accommodation Assessment (GTAA) (2022) has been prepared to support the Local Plan Update. A range of stakeholders, including neighbouring local authorities, were contacted to obtain feedback on Gypsy, Traveller and Travelling Showperson matters. The GTAA has taken into consideration the travel patterns and motivations of traveller communities and their potential future locational preferences. The assessment concludes there is a need for 29 permanent pitches over the plan period and that this need can be met through turnover on existing sites.

3.11 A full assessment of transit site accommodation took place as part of the GTAA. Drawing on evidence of unauthorised encampment activity, the GTAA recommends the council prepare a negotiated stopping policy to help manage any future need for transit provision. Such a policy which would be prepared outside the Local Plan process but would be prepared in consultation with relevant neighbouring authorities. This is a more flexible option and is supported by stakeholder feedback which indicated that transit provision must be in an appropriate location preferred by the travelling community, otherwise it would not be used. Although the study does not identify a shortfall in the provision of transit pitches, it is recommended the council engages further with potential private site owners to consider whether additional transit provision can be provided in suitable locations.

Agreement 2

Local planning authority signatories are committed to meeting identified needs for Gypsy, Traveller and Travelling Showpersons Accommodation within their own area insofar as this is practicable. There are no unresolved strategic issues relating to travelling communities.

The Scale and Location of Employment Development

3.12 The business base of the East Riding is diverse. The East Riding Economic Strategy (2018-22) and the Hull and East Yorkshire Local Enterprise Partnerships Economic Growth and Workforce Wellbeing Strategy (2021-26) seek to build and strengthen the area’s unique economic identity through supporting energy, port, engineering and manufacturing sectors, increasing productivity and developing new specialisms. Alongside this the East Riding Rural Strategy (2022-27) highlights the significance of the rural economy, in particular agriculture, in supporting towns and villages.

3.13 The East Riding’s Economic Strategy (2018-22) identifies the East-West Multi-Modal Transport Corridor as the most attractive location for inward investment and indigenous growth companies, with links to the Humber Ports of Hull and Goole as well as smaller wharf facilities at Howdendyke, and to the rest of the country via the Estuary, rail and highways. Key Employment Sites at Hedon Haven, Humber Bridgehead, Melton and the junction 36 of the M62 at Goole make the most of the locational advantages as well as providing employment opportunities for residents within the City of Hull.

3.14 At least 208 hectares of land is allocated for employment uses in the East Riding, which reflects the high growth scenario of the Employment Land Review (2020) and subsequent Demand Update (2022). This approach reflects the long term past trend of economic growth and considers the potential of planned economic growth and potential future policy interventions. The availability of large sites in the East Riding supports growth across the local authority area as well as for the City of Hull. There is a separate allocation at Hedon Haven for 179 hectares which represents a significant sub-regional opportunity. Yorkshire Energy Park is also identified as a nearby allocation. Both sites benefit from planning permission supported by a range of evidence and studies to consider the impact of development.

3.15 The Demand Update (2022) identifies strong historic take up in the Hull and Goole & Selby Functional Economic Area (FEA)s. The higher growth scenario suggests that most new employment land will be required in these FEAs. All of the East Riding’s Key Employment Sites are located within these two FEAs. The Hull FEA has an important role in the overall economy of the East Riding and is centred mainly on sites in and around Hull, the Major Haltemprice Settlements, Beverley and along the East-West Multi-Modal Transport Corridor at Elloughton-cum-Brough, Melton and Salt End/Hedon. The Goole & Selby FEA has seen over half of the historic land take up since 2012 and incorporates key inward investment locations in Goole and Howden.

3.16 Hull is the regional centre for the Humber, with a city centre office market which it is important to encourage for Grade A space for office uses. In contrast East Riding provides an out-of-town location offering choice to business support and service sectors. The Local Plan Update provides for this, supporting office uses which cater for a separate target market or support the role of Town and District Centres.

Agreement 3

Local planning authority signatories agree that their respective plans will meet or exceed employment requirements within their respective planning authority areas and that there are no outstanding unresolved strategic issues relating to employment development.

Minerals and Waste

3.17 The council is a Waste Planning Authority (WPA) and work on a Waste Local Plan is underway. This will replace the existing Joint Waste Plan (2004) and will draw on up to date projections for the amount of waste within all the different waste streams (including non-municipal) which need to be managed. It will allocate land for a sufficient number and type of facilities to manage waste accordingly. The movement of waste from and to neighbouring waste planning authorities and the need for new waste facilities will be considered through the preparation of the Plan.

3.18 A Joint Minerals Local Plan (JMLP) for East Riding of Yorkshire Council and Kingston upon Hull has been prepared jointly by the two councils in their role as Mineral Planning Authorities (MPA). It sets out the vision, objectives, spatial approach, planning policies and allocations for mineral development within the Plan Area. Preparation of the JMLP has involved active engagement with the Yorkshire and Humber Aggregate Working Party, ongoing Annual Aggregate Monitoring surveys and commissioning a Marine Aggregates Study (January 2014). The Humber Area Local Aggregates Assessment and Aggregates Apportionment: Background paper for the Plan area has been produced jointly between the four Humber MPAs, which also include North and North East Lincolnshire Councils.

3.19 Mineral and waste sites can be located within and in close proximity to the East Riding and the City of Hull administrative boundaries. In these circumstances, the council remains committed to working with its neighbouring authorities to ensure that these sites continue to be suitably safeguarded.

Agreement 4

Local planning authority signatories agree that there are no outstanding unresolved strategic issues relating to minerals matters. These have been addressed through the preparation of the adopted East Riding of Yorkshire and Kingston upon Hull Joint Minerals Local Plan (2019). The council will continue to engage / liaise with adjacent and other relevant authorities as and when required.

Agreement 5

Local planning authority signatories agree that work is underway on an East Riding Waste Local Plan. Waste planning evidence, including a Waste Needs and Capacity Assessment, will highlight any strategic issues that the Plan will need to help address. The councilwill continue to engage / liaise with adjacent and other relevant authorities as and when required as part of developing the East Riding Waste Local Plan.

The Scale and Location of Retail Development

3.20 Retail development is focussed around a hierarchy of Centres informed by the Town Centres, Retail and Leisure Study (2019). Many Centres serve a large rural catchment, and the regional-scale city centres of York and Hull have extensive catchment areas which extend into significant parts of the East Riding. There are fewer movements between the East Riding and York than there are between Hull and the East Riding, but they are still influential. The Local Plan Update seeks to balance promoting economic growth with the need to protect and promote existing centres. New retail development to respond to local demand will follow the sequential approach. This should include consideration of relevant neighbouring Centres where the scale and type of development reflects that Centre’s size, role and function and its capacity for new development. Depending on the scale and location applicants are also required to ensure that the vitality and viability of identified Centres (including Centres in neighbouring authorities) is not undermined. Neighbouring local authorities may be consulted on certain relevant planning applications. Hull City Centre is most likely to be impacted by development in the East Riding. As such, Hull City Council will be consulted on all relevant planning applications.

3.21 A site in Bridlington (known as BRID-K in the Local Plan Update) has been allocated to meet the retail requirement identified in the Town Centres, Retail and Leisure Study (2019). In this location it is recommended that the provision of new floorspace should be in the form of larger shop formats to fill a gap in current provision. Provision for retail floorspace has also been made as part of the following mixed use allocations (it has not been considered necessary in light of assessed need to allocate sites in the Hull retail catchment area):

· Driffield (DRF-M) – a retail led mixed use development allocated to meet the identified need for 900 to 1,500 sqm convenience retail floorspace to 2033.

· Elloughton-cum-Brough (ECB-C) – part of the permitted site has been completed and permission includes 9,985 sqm of retail floorspace overall.

· Howden (HOW-G) – retail element provided as part of mixed housing, employment, community and open space uses.

· Market Weighton (MW-F) – site allocated for retail and employment uses. The amount of floorspace provided should be guided by the latest evidence on need and consider the potential impact on the vitality and viability of the town centre.

Agreement 6

Local planning authority signatories agree that there are no outstanding unresolved strategic issues relating retail development.

Strategic Transport Infrastructure

3.22 The Local Transport Plan (2021-2329) provides a strategy for delivering and improving transport services across the East Riding. There is a high reliance on the private car, particularly in rural parts of the East Riding, and congestion is a particular issue in specific settlements such as Bridlington, Beverley and Goole.

3.23 The Local Plan Update defines the Strategic Road Network (SRN) to include the council’s ‘A’ road network as well as all of National Highway’s SRN in the East Riding (M62, M18, A63, and A1033). This network is critical for connecting the area’s Major Haltemprice Settlements, Principal Towns, and Towns together and into the cities of Hull and York, as well as the National Motorway Network. National Highways advise on requirements for specific developments that may impact on the SRN. A separate statement of common ground will be prepared with National Highways.

3.24 The East Riding Infrastructure Study (2022) highlights a number of routes predicted to be under stress at the end of the plan period. Those which are likely to be of cross boundary interest include:

· A164 between Humber Bridge and Beverley;

· A1079 east of Market Weighton;

· A1174 Hull Bridge Road (Beverley) to Dunswell roundabout;

· Northern section of M18;

· M62 between junctions 34 and 36;

· A64 between A1036 and A1079 (outside of the East Riding);

· All sections of the A63 between North Cave and Mount Pleasant (Hull);

· A1033 between Mount Pleasant and Salt End; and

· A166 at Stamford Bridge.

3.25 A Highway Junctions Study has also been prepared which has highlighted capacity challenges, mitigation schemes and future assessment for the following junctions of relevance to this document:

· M62 Junction 36 Goole

· M62 Junction 37 Howden

· M62 Junction 38 North Cave

· A63 Junction Welton

· A63 Junction Melton

· A63/A15/A164 western interchange (Hessle/Humber Bridge)

· A1174/A1079 Dunswell Roundabout[3]; and

· A64/A1079 Grimston Bar (outside of the East Riding)

3.26 The Local Plan Update supports robust sustainable travel planning alongside new development, considering location specific factors such as availability of public transport, scale of development and available road capacity. It promotes new development being designed to support and encourage sustainable alternatives to single occupancy use of the private car, in line with individual Local Cycling and Walking Infrastructure Plans developed for the Major Haltemprice Settlements, Principal Towns and Towns. The impacts of individual schemes will be considered through travel plans, transport statements and transport assessments where necessary.

3.27 Main employment allocations have been focussed close to the East-West Multi-Modal Transport Corridor, most of which is served by the SRN and offers the opportunity to transfer and transport by means other than road.

Agreement 7

Local planning authority signatories agree that there are no outstanding unresolved strategic transport issues.

The Natural Environment

3.28 The East Riding has a number of statutorily protected nature conservation sites. Many of these cross boundaries within neighbouring authorities (e.g. Lower Derwent Valley & River Derwent, Humber Estuary, and Thorne and Hatfield Moors) and include internationally important Special Areas of Conservation (SAC), Special Protection Areas (SPA), Ramsar sites, and National Nature Reserves. The Local Plan Update seeks to avoid development that would have an adverse impact on designated sites wherever possible and expects new development to optimise opportunities to safeguard biodiversity. Proportionate levels of ecological information will be required to support specific development proposals, and Natural England will advise on impacts on mitigation required. A separate statement of common ground will be prepared with Natural England.

3.29 A Habitats Regulations Assessment (HRA) has been completed to test whether developments in the Local Plan Update would impact on the integrity of the international (habitats) sites. The HRA assesses a range of potential impacts on the designated sites including recreational impacts from new households and visitor accommodation, the loss of functional land for mobile species, and the impact of air and water pollution from planned growth.

3.30 A strategic approach for the provision of avoidance and mitigation measures to address visitor impacts arising from new housing and tourism growth around the Humber Estuary European Habitats sites is being prepared. This is a precautionary approach that addresses the recreational pressure identified in the HRA. The council will work with all Humber authorities to mitigate the impacts of recreational pressure on the Humber Estuary. This will include preparation of an Important Biodiversity Sites Supplementary Planning Document (SPD).

3.31 The Local Plan Update requires development proposals located within 10km of the Humber Estuary or Lower Derwent Valley international (habitats) sites to consider whether development results in the loss of ‘functionally linked land’ for mobile species associated with the international (habitats) site. A 5km zone of influence, measured from the Lower Derwent Valley international (habitats) sites, is also identified as the core area within which development proposals could impact on the Lower Derwent Valley. In this area, the guidance in the Lower Derwent Valley Supplementary Planning Document (SPD) (January 2018) is particularly important. The SPD was prepared jointly with Natural England, City of York Council, North Yorkshire County Council and Selby District Council. The council is committed to reviewing the SPD, working alongside neighbouring authorities.

3.32 The council has worked with Natural England to map the area’s blue/green infrastructure corridors at a strategic scale. The corridors represent locations where opportunities to improve the functioning and connectivity of blue/green infrastructure may be greatest. These corridors incorporate a broad range of assets/ functions e.g. biodiversity, landscape, heritage, and recreational assets. There are corridors which are of regional and sub regional importance and these cross boundaries with neighbouring authorities.

3.33 There are areas of high landscape quality that are of local importance. Some of these landscapes extend into a neighbouring local authority area:

· Yorkshire Wolds (Ryedale District Council / Scarborough Borough District Council)

· Lower Derwent Valley (City of York Council / Selby District Council)

· Thorne, Crowle and Goole Moors (Doncaster Council / North Lincolnshire Council)

· Flamborough Head (Scarborough Borough Council)

3.34 The Yorkshire Wolds are currently being considered for Area of Outstanding Natural Beauty (AONB) status. Much of the East Riding’s boundary with Ryedale District falls within the Yorkshire Wolds. If the area is designated during the lifetime of the plan, the Local Plan Update and NPPF would be used together to ensure that new development does not undermine the special qualities of the Yorkshire Wolds and its setting. If designated, it may be necessary to prepare a Supplementary Planning Document (SPD) relating to the AONB.

Agreement 8

Local planning authority signatories agree that there are no outstanding unresolved strategic issues relating to the natural environment. Relevant information will be shared on cross boundary issues related the Humber Estuary and other designated sites of environmental importance.

Flood Risk, Coastal Change and Water Quality

3.35 The Environment Agency (EA) has a strategic overview of all sources of flooding and coastal erosion. It is also responsible for flood and coastal erosion risk management activities on main rivers and the coast. The Lead Local Flood Authority (LLFA)/Unitary or County Council, in this case East Riding of Yorkshire Council, is the lead in managing local flood risks (i.e. risks of flooding from surface water, ground water and ordinary (smaller) watercourses).

3.36 The EA has prepared the Humber River Basin District Flood Risk Management Plan (2021-27), which sets out how organisations within the Humber River Basin will work together to manage flood risk. The EA has also produced many other documents that cover the East Riding and its neighbouring Authorities, including Flood Risk Management Plans, which have been prepared for each river catchment and provide a long term management plan for the catchment; and the Humber Flood Risk Management Strategy (2008), which is a long term plan for managing risk around the Humber Estuary and its main tributaries. The Strategy is currently in the process of being reviewed.

3.37 The Council, as the LLFA, has prepared the Local Flood Risk Management Strategy, which sets out how it will work with partners to manage the risk of flooding. It has also prepared a set of Flood Risk Management Plans (FRMPs) for drainage catchments, some of which extend outside the East Riding. FRMPs consider the risk of flooding posed by all sources and how this may change in the future as a result of factors such as new development and climate change and set out measures to address risks.

3.38 The main rivers and watercourses that flow through the East Riding are the River Aire, Calder, Derwent, Don, Hull, Ouse and Trent. With the exception of the River Hull, the sources of these rivers are all located outside the East Riding. The western boundary of the authority is largely bounded by the River Derwent and the southern boundary is defined by the River Humber and Humber Estuary. This has resulted in significant parts of the East Riding being identified within high flood risk zones that also extend into neighbouring authority areas.

3.39 The East Riding is also susceptible to surface water flooding, although no areas have been identified as Critical Drainage Areas by the EA. Sources of surface water flooding could impact on areas within a neighbouring authority, principally Hull.

3.40 The Major Haltemprice Settlements are at particular risk from flooding from a number of sources. The Living With Water Partnership, comprising Yorkshire Water, Environment Agency, Hull City Council and East Riding of Yorkshire Council, are working together to build cross boundary flood resilience and develop innovative water management systems. The Living With Water Area is shown at Figure 14 of the Local Plan Strategy Document Update. A separate strategy for the River Hull catchment has also been developed in partnership with the EA, Hull City Council, Beverley & North Holderness Internal Drainage Board and Yorkshire Water. The River Hull Integrated Catchment Strategy was adopted in May 2016 and sets out a number of measures such as dredging and boat removal on the river to help reduce flood risk, and upland natural flood management. Many of these measures have already been delivered. Improvements needed to the Humber frontage defences between the city centre and Hessle have recently been completed.

3.41 The Local Plan Update proactively manages flood risk through the application of the sequential approach to the location of development (i.e. direct development to sites at lowest risk of flooding) and exception test. The risk is also managed by ensuring that new developments:

· limit surface water run-off,

· do not increase flood risk within or beyond the site,

· incorporate sustainable drainage systems unless doing so would be inappropriate,

· ensure Sustainable Drainage Systems (SuDS) provide multi-functional benefits where appropriate,

· do not culvert or otherwise build over watercourses unless supported by the Risk Management Authority and an appropriate Water Framework Directive Assessment,

· have a safe access and egress route to areas at low risk of flooding now and in the future,

· are adequately set back from watercourses, and

· adhere to other Strategic Flood Risk Assessment (SFRA) recommendations.

3.42 The Local Plan Update also designates land for current and future flood risk management, supports appropriate proposals for new or improved flood risk management, and supports the removal of culverts. These more strategic decisions could impact on the future risk in neighbouring authorities, particularly Hull.

3.43 Coastal processes clearly cross local authority boundaries. Consequently the East Riding coast is covered by the Humber Estuary Coastal Authorities Group and North East Coastal Authorities Group. These groups comprise a range of agencies, including the EA, Historic England, Natural England, as well as the relevant local authorities. They are responsible for preparing Shoreline Management Plans (SMP), which consider the options for managing the coast. The SMPs consider four possible approaches: hold the existing defence line, advance the existing defence line, managed realignment and no active intervention. Two SMPs cover the East Riding. The coast north of Flamborough Head is covered by the North East Coast - River Tyne to Flamborough Head SMP. The coast south of Flamborough Head is covered by the Flamborough Head to Gibraltar Point SMP.

3.44 The Local Plan Update supports proposals for coastal change management, such a new defences or managed realignment where:

· They would not have any unacceptable adverse environmental, social or economic impacts;

· Are in line with the most up to date Shoreline Management Plan; and

· In line with the latest coastal monitoring information. The relevant Shoreline Management Plans are SMP2 The Tyne to Flamborough Head and SMP3 Flamborough Head to Gibraltar Point.

3.45 The 2009 Marine and Coastal Access Act introduced a marine planning system with requirements to produce plans to enable sustainable development of marine areas, similar to land-use plans. East Riding of Yorkshire falls within the areas covered by the East Marine Plan (2014) and the North East Marine Plan (2021) which set the policies for the use of the marine environment. The Marine Plan and Local Plan areas of jurisdiction overlap in the intertidal zone, and as such any applications for development within this area would need to refer to both. The Marine Plans may have relevance for proposals that fall outside of the coastline but could have an impact on marine activities, such as a land-based development that may eventually discharge into the sea. They cover a range of policy topics and should be considered more widely than only for coastal change.

3.46 There are a number of groundwater source protection zones (SPZ) that are located within the East Riding. Some of these zones, principally SPZ3, cross into neighbouring local authority areas. Development within the inner protection zones (SPZ1) around the Major Haltemprice Settlements has the potential to affect water quality within Hull. The Local Plan Update manages the risk of groundwater pollution by avoiding development that increases the risk of pollution in a SPZ and, where this is not possible, ensuring that appropriate mitigation measures are employed. Inappropriate uses are prevented in SPZ1 and SPZ2, unless adequate safeguards against possible contamination can be agreed. This approach is supported by the EA and Yorkshire Water.

Agreement 9

Local planning authority signatories agree that there are no outstanding unresolved strategic issues relating to flood risk, coastal change or water quality.

4. Prescribed bodies and other relevant organisations

4.1 In addition to Local Planning Authorities the other bodies prescribed for the purposes of the Duty to Cooperate[4] are:

· the Environment Agency;

· the Historic Buildings and Monuments Commission for England (known as

Historic England);

· Natural England;

· the Mayor of London;

· the Civil Aviation Authority;

· the Homes England;

· NHS Humber and North Yorkshire Integrated Care Board (from 1/7/22, formerly East Riding/Vale of York Clinical Commissioning Group);

· the Office of Rail Regulation;

· Transport for London;

· each Integrated Transport Authority;

· each highway authority within the meaning of section 1 of the Highways

Act 1980 (including the Secretary of State, where the Secretary of State is

the highways authority) e.g. National Highways;

· the Marine Management Organisation; and

· each Local Enterprise Partnership.

4.2 Further engagement has taken place with these prescribed bodies in the preparation of the Local Plan evidence base. For example:

• The preparation of the East Riding Infrastructure Study (2022) has involved the input of numerous organisations (such as Yorkshire Water and Northern Electric), prescribed bodies (such as the Environment Agency, Highways Agency and NHS) and Council services (such as the Transport Policy, Pupil Services, and Flood Management teams).

• The preparation of the Strategic Flood Risk Assessments has included substantial involvement by the Environment Agency.

• Natural England, has been heavily involved in the preparation of the Habitat Regulations Assessment. They have provided significant advice that has resulted in an agreed approach to managing recreational pressure around the Humber Estuary.

4.3 Table 2 (overleaf) provides a summary of engagement with relevant[5] prescribed bodies. These bodies have signed to confirm table 2 represents an accurate reflection of their engagement with the council on the Local Plan Update.

4.4 Engagement with the Civil Aviation Authority and Office for Rail Regulation has been ongoing since the preparation of the Local Development Framework in 2004. They have been informed of all consultation stages in the preparation of the Local Plan Update but have had no specific comments to make.

4.5 In addition to engagement with prescribed bodies there are a number of relevant non-prescribed organisations the council has engaged with. These include:

· Hull and East Yorkshire Local Nature Partnership (LNP) – The objective of the LNP is to ensure that the natural environment is better taken account of in local decision making. The LNP is working with City of York Council, North Yorkshire County Council, East Riding of Yorkshire Council and Hull City Council to develop a natural capital framework. A critical part of this is a comprehensive up-to-date habitat network map, which can support better decision making across a range of sectors and work areas, including planning. This mapping is being developed currently via remote sensing technology. The final product will support an up to date blue/green infrastructure network for the East Riding.

· Yorkshire Water (YW) – The council have consulted YW on the growth planned in the Local Plan Update. The Allocations Document Update encourages developers to work with YW where appropriate. YW have confirmed there is capacity at all of their waste water treatment works to accommodate the draft level of development proposed to 2039. Future strategic investment for water supply improvements and sewage treatment would come through YW’s 5-year investment plans. This will include consideration of hydraulic capacity issues within the sewer network in Howden to accommodate the proposed strategic urban extension.

Table 2: Engagement with Prescribed Bodies

Prescribed Body

Summary of engagement

Signatory

Environment Agency (EA)

Engagement with the EA has been ongoing since the preparation of the Local Development Framework in 2004. Consultation on the Local Plan Update has included meetings, correspondence and consultation on draft evidence base studies. This includes significant involvement in the Strategic Flood Risk Assessment (SFRA) comprising an East Riding-wide Level 1 SFRA (2019) and separate Level 2 SFRAs for Goole and Hedon (both 2020). The EA were involved in the SFRAs from inception. This included:

· Commenting on a draft scope of works

· Supporting the council and the consultants in defining the methodology

· Providing the council access/licence to EA data.

· Briefing the council on emerging data (the Upper Humber Model) and its implications for the L2 SFRA for Goole.

· Reviewing the draft mapping outputs and helped shape the Planning Recommendations in the SFRAs.

· Providing advice on how to consider new Planning Practice Guidance on the preparation of SFRAs

· Referencing the council’s SFRAs as examples of best practice.

Flood risk is an important consideration for locating new development. A number of amendments have been made to both the Strategy and Allocations Document Update (policies and supporting text) in light of engagement and detailed correspondence with the EA and to reflect evidence base. These are outlined below:

· Aligning both documents with the EA evidence and strategies.

· Making appropriate references to the Flood Maps, Catchment Flood Management Plans and River Basin Management Plans.

· Changes to the supporting text accompanying Strategy Document Update Policy ENV6. The table considering the appropriate development (up to 100 years) with the Coastal Change Management Areas has been updated which supports the Coastal Change section of Policy ENV6.

· Amendments to the Goole place statement to reflect the overall approach to managing development in the town in response to the findings of the Goole Level 2 SFRA.

The EA have also supported the preparation and application of the East Riding Site Assessment Methodology. This includes:

· applying the SFRA to apply the sequential test and direct allocations to areas of lower flood risk.

· directing housing allocations to sites outside of SPZ1.

The EA have been involved in, and provided funding for the Flood Alleviation Schemes, which have been developed around the Major Haltemprice Settlements (COPFAS, WADFAS and AEEFAS).

East Riding of Yorkshire Council, in its capacity as Lead Local Flood Authority, engages the EA in developing its Local Flood Risk Management Strategy, associated catchment studies and local investment plan for flood and coastal erosion risk management schemes. East Riding of Yorkshire Council has also been involved in the preparation of relevant EA evidence and strategies (e.g. Flood Maps and Catchment Flood Management Plans). These all form part of the Local Plan evidence base.

Proactive engagement with the EA continues on the preparation of the Local Plan Update. r5

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Historic England (HE)

Engagement with HE has been ongoing since the preparation of the Local Development Framework in 2004. Consultation on the Local Plan Update has included correspondence and consultation on draft evidence base studies (e.g. Beverley South Masterplan).

A number of amendments have been made (or proposed) to the Local Plan Update in light of engagement with HE. These are outlined below:

· A proposed modification to chapter 2 of the Strategy Document Update to reflect the latest position on the national Heritage List for England.

· Policy ENV3 has been amended to reflect the Historic England at Risk Register (2021), reflect the recommendations of Historic England and to better explain how developments will be assessed for their impact on the significance of heritage assets.

· A proposed modification to Policy S4 to remove reference to ‘enabling development’. This responds to comments from Historic England that enabling development is contrary to the development plan.

· A proposed modification to Policy ENV3 to further clarify that where there will be harm to the significance of a heritage asset, a scheme of mitigation should be prepared. This should minimise and mitigate harm and demonstrate harm is appropriately weighted against public benefits, in line with national planning policy.

· A proposed modification to paragraph 7.3 of the Strategy Document Update to reference the conservation and enhancement of the historic environment and heritage assets as an opportunity for good design.

· A proposed modification to the sub area policies to ensure those elements which contribute to the significance of the sub areas are conserved and enhanced, rather than just protected).

HE have also supported the preparation and application of the East Riding Site Assessment Methodology, and the preparation of Heritage Impact Assessments for a number of allocated sites.

Proactive engagement with HE continues on the preparation of the Local Plan Update.

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Homes England

Consultation on the Local Plan Update has taken place including correspondence, meetings and consultation. Meetings and correspondence have been focused on the delivery of larger allocated sites in the East Riding, predominantly BEV-K, BEV-J, DRF-B, BRID-A, BRID-C and BRID-E. This has included consideration around how Homes England can support the Council in accelerating housing delivery, in particular through infrastructure funding, acquisition and affordable homes grant. As part of these discussions representatives of Homes England have visited these sites. Meeting and correspondence has also taken place regarding the proposed allocation HOW-G. This has included discussions about the housing delivery required to support the workforce and a site visit.

The Council have also engaged Homes England to support the delivery of extra care accommodation required as part of the housing mix on several large sites across the East Riding, in particular around addressing viability concerns.

Key Strategic

Proactive engagement with Homes England continues on the preparation of the Local Plan Update.

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Local Enterprise Partnership (LEP)

Engagement with the LEP commenced in 2011 with the establishment of the Humber Local Enterprise Partnership (LEP). This has now been replaced by the Hull and East Yorkshire Local Enterprise Partnership (HEY LEP). The HEY LEP have been informed of all consultation stages in the preparation of the Local Plan Update.

The Strategy Document Update vision and place statements have been developed taking into account plans prepared by the LEP. Specifically the Economic Growth and Workforce Wellbeing Strategy published in Feb 2022.. Proactive engagement with HEY LEP continues on the preparation of the Local Plan Update.

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Marine Management Organisation (MMO)

The MMO was established in 2010 following the Marine and Coastal Access Act 2009. Engagement with the MMO commenced in 2011. Consultation on the Local Plan Update has included correspondence and a statutory consultee meeting attended by the MMO.

The Strategy Document reflects the implementation of the East Inshore and Offshore Marine Plans (2014) in relation to the impact on the marine environment. These cover the area from Flamborough Head to Felixstowe, including the tidal extent of and rivers within this area. The North East Marine Plan (2021) covers the area north of Flamborough Head. Whilst the Marine Plans over the marine and tidal area, they cover a wider range of policy topics and should be considered more widely than only for coastal change. A number of amendments are proposed to the Local Plan Update in light of recent engagement with the MMO. These are outlined below:

· EC1 and EC2

· Proposed modification to the Key Spatial Issues section of the Local Plan Strategy Document Update to reference the Marine Plans and recognise that the consideration of the Marine Plans is much wider than coastal change

Proactive engagement with MMO continues on the preparation of the Local Plan Update. The council will continue to actively consult the MMO to ensure conformity between the Marine Plans and the Local Plan.

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National Highways (NH)

A separate statement of common ground is being progressed with NH.

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Natural England (NE)

A separate statement of common ground is being progressed with NE.

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NHS Humber and North Yorkshire Integrated Care Board (ICS)

Engagement with the NHS has been ongoing since the preparation of the Local Development Framework in 2004. Consultation on the emerging Local Plan Update has included regular meetings, correspondence and consultation on draft evidence base studies. This has primarily involved close working with the former Clinical Commissioning Groups (CCGs) to prepare and update the Infrastructure Study supporting the Local Plan Update. The Infrastructure Study aims to ensure local needs are reflected in health infrastructure, services and facilities required to support the planned development in the Local Plan Update.

Following Royal Assent of the Health and Care Act in 2022, the previous CCGs have been abolished and replaced with Integrated Care Systems (ICSs). Until that point, the CCG was the statutory organisation responsible for receiving the national funding allocation and commissioning services to best meet the needs of their local populations, including ensuring that healthcare needs are reflected in local infrastructure studies.

The transfer of the existing statutory duties to the ICS means that the responsibility to ensure healthcare needs are reflected in local infrastructure studies will still be applicable, but that a different body now make those judgements. The following bodies are included in the ICS:

· Integrated Care Partnership (ICP) - The Humber and North Yorkshire Health and Care Partnership comprises NHS organisations, local councils, health and care providers and voluntary, community and social enterprise (VCSE) organisations. Their focus is on making the connections between health and wider issues including socio-economic development, housing, employment and the environment. The ICP have prepared an Integrated Strategy for Humber and North Yorkshire (2020).

· Integrated Care Board (ICB) - A statutory NHS organisation responsible for developing a plan for meeting the health needs of the population, managing the NHS budget and arranging for the provision of health services in the ICS area. The ICB are preparing a 5-year Joint Forward Plan which will use the Integrated Strategy as a framework and an operational delivery plan.

The ICB reviewed the Infrastructure Study and have agreed the following points to ensure the conclusions reflect the ongoing work of the ICP (at March 2023):

· The level of growth envisaged in the Local Plan Update will have a significant impact on the need for health services. The population increase is likely to have a particular impact on demand for primary care services such as General Practice and Dentists which people use on a regular basis.

· In the former Vale of York CCG area the majority of the additional capacity needed can be met through an increase in utilisation and working efficiencies at existing premises.

· In the overall East Riding CCG area analysis shows an additional 35.9 full time equivalent GPs are required by 2039 to support the increased population. Whilst an exact formula is impossible to construct, it is accepted that at least two aligned roles are equivalent to one GP. Using a standard multiplier of 300sqm per GP, this also showed the need for at least 16,589 sqm of additional health estate. In addition, ARRS recruitment to meet the differing needs of a growing population has been calculated to require an additional 30-50% of healthcare estate on top of the numbers quoted above. This suggests an additional need for 17,237 sqm of health estate.

· The impact of health services across the East Riding may differ dependent on the age demographic or level of deprivation in an area. In general, the older population and individuals living in more deprived areas have an increased risk of long-term health conditions which can put a significant strain on local GP services due to increased demand for appointments and GP time

· Additional demand on diagnostic, urgent, emergency and specialist care provided by local hospitals in Hull and Cottingham (alongside the community hospitals and accommodation located across the East Riding) is already being seen, resulting in additional workforce and the expansion of hospital estate. Given the growing and ageing population, additional provision within hospitals in and around the East Riding will be required.

· There are areas of the East Riding where access to an NHS dentist would involve a waiting list in excess of 5 years and there is no private provision either. As the future housing growth is realised, the ICB will be best placed to advise on areas where there are actual deficiencies in the delivery of NHS dental services.

An ICS estates level strategy is being prepared and this will lead to local level estates strategies. However it should be noted that even if additional estates can be provided in response to identified need, the national shortage of GPs, paramedics and trained clinical staff, attributed to issues with training and recruitment, remains a problem.

As the future housing growth is realised, the ICS will be best placed to advise on areas where there are actual deficiencies in the delivery of GP services in direct correlation to specific settlement population and resident characteristics, and how these deficiencies would be best addressed using the funding available to them. More detailed information on infrastructure requirements and mitigation needed to address potential impacts on health services will be established through consultation with the ICP through the planning application process.

The Humber and North Yorkshire ICS, receive automatic notification of relevant planning applications to help assess the impact of future development on primary care infrastructure. Relevant developments are defined as large housing developments comprising 50 or more dwellings and residential care homes or supported housing developments of any size. Where care homes are developed, especially those with an element of specialist care (for example a care home for dementia patients), there can be a further strain on local primary care provision as a more specialist input is required.

Developers are encouraged to work with infrastructure providers and consider opportunities to address infrastructure requirements as part of their proposal. However there are limits to the level of developer contribution that can be imposed on individual schemes without adversely affecting viability. Therefore, the economic viability of development is important in considering the level of contributions expected, such as for public open space, affordable housing, education and health services. This ensures that the size of any expected contribution does not put at serious risk the development of the area.

The Council continue to work proactively in partnership with the ICS to ensure local needs are reflected in health infrastructure, services and facilities required to support the planned development in the Local Plan Update.

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Appendix A

Neighbouring Local Authorities

City of York Council

· City of York Council (CYC) has a long history of joint working and cooperation with the Council. There are no specific concerns on the general extent of the Local Plan Update. The traffic impact of the Local Plan on York’s highways is likely to be fairly low. Notwithstanding this, CYC request that both the Council and developers engage with CYC for any large sites within the Vale of York sub area with regards to the transport implications. CYC would look to resolve any cross boundary issues through the detailed application process.

· The Plan recognises that there are constraints on the transport infrastructure between the Vale of York sub-region and York, specifically listing the single lane bridge at Stamford Bridge and the congested A166/A1079/A64 Grimston Interchange. Stamford Bridge is within ERYC and CYC request formal engagement in relation to plans coming forward for improvements at the bridge.

· CYC is reviewing Grimston Interchange and looking at potential mitigations required for York’s Local Plan site at Langwith. As part of this work, CYC has been and will continue to engage with ERYC and National Highways.

Doncaster Council

· No comments made.

Hull City Council

· Support expressed for of the broad approach set out in the plan and references within highlighting the important relationship that exists between the two areas, particularly within the identified central area. Whilst there have been various very positive improvements in the city in recent years, the need to manage growth around the city to support ongoing regeneration remains a key concern.

· Overall, the plan is sound particularly given the longstanding approach to developing a strategic approach between the Councils due to the tightly defined nature of the city’s administrative area and inevitable close functional and market area relationships.

· The Council has clearly considered the Duty to Cooperate through the close working relationship between the two Councils

· Support for the introduction of a Climate Change policy.

· The spatial strategy is appropriate. The approach has been developed over several years and through effective joint working between Hull and East Riding on cross boundary issues, and as evidenced through the agreed Statement of Common Ground.

· Support for focusing development in the Major Haltemprice Settlements as a highly sustainable location to support future housing growth.

· Agreement expressed with the settlement hierarchy on the focus on the Major Haltemprice Settlements as part of the urban area of the Regional City.

· The Council has always sought to reduce potentially competing housing in areas around the edge of the city, where this could draw away from attempts to rebuild housing markets and deliver new housing within city. This intent remains important for the city.

· It is recognised that a requirement figure higher than the minimum OAN is essential to the provision of affordable housing in the East Riding and to meeting these needs where they arise. The figure of 1,100 per annum reduces pressure on housing delivery in Hull.

· Even with an extended Local Plan period to 2039 it is understood that the lower housing requirement means that there is not a need to make new allocations in the areas around the city. This provides some comfort that a figure more than the Local Housing Need figure for the East Riding may be pursued without having a detrimental impact on housing delivery in Hull.

· High delivery within Hull over recent years has been achieved as a result of public investment in regeneration areas and such delivery may not continue at the same rate dependent of course on success of market turn around. So, while Hull has seen delivery above its housing requirement in the face of continued delivery in surrounding areas this may not continue.

· It remains important that a detailed framework exists that will guide decisions on the edge of and in proximity to the city to ensure its continued growth. Other than the overall policy framework, the strategic applications protocol agreed between the two authorities provides the main mechanism for responding to specific development types, particularly speculative schemes that come forward on non-allocated sites or where schemes on allocated sites potentially change the originally intended amount of development. It would be appropriate for the plan to explicitly refer to the protocol as a key mechanism for managing development not otherwise allocated within the plan.

· Support expressed for the identification of sub areas, the role of the city and for the reinforcement of approaches within other sections that aim to continue support for the significant investment in regeneration and development to stimulate demand and support sustainable communities, ensuring that growth in the city and wider sub area can benefit the sub-region.

· Support expressed for the continuing reference in Policy S3 to Key Employment Sites along the East-West Multi-Modal Transport Corridor.

· Support expressed for the current allocations around the city, particularly those that continue to bring focus to the A63 / A1033 strategic corridor which links through the city providing access, enabling key developments including Green Port Hull.

· Support expressed for the allocation of Yorkshire Energy Park at Hedon. reflecting the planning permission that now exists. Policy S3 should also reference the Yorkshire Energy Park as a key site alongside Hedon Haven, to recognise the new allocation in this location.

· It is noted that the Humber Bridgehead site is proposed to be expanded. Reference is made in the supporting text to how proposals for office premises in this location must have regard to the requirements of Policy EC3 of the Strategy Document Update. It may bring greater clarity if the policy makes reference to this link.

· Support expressed for a hierarchy of retail centres in which Hull City Centre acts as the focus for schemes that will serve the wider city region.

· It is recognised there is a need to balance the range of house types provided to ensure that the market delivers housing to meet identified needs as well as meeting market demands. The Council therefore supports the approach to specifying percentage ranges for house sizes by numbers of bedrooms.

· Support expressed for high standards to be achieved in the design of housing subject to viability.

· The Council recognises the challenge of meeting affordable housing needs purely as part of market led housing schemes and is supportive of the proposed uplift to the proposed housing requirement figure with the express purpose of increasing affordable provision. It is also recognised that a proportion of affordable housing needs to be provided through other methods and supports the balance of approaches.

· Support for an approach to meeting the needs of travellers within respective administrative areas and this approach should continue notwithstanding that identified need in East Riding is currently low (and capable of being met in existing sites). The extent to which needs for transient sites has been assessed is queried.

· Support for an area-based approach to development of wind energy but still with a criteria-based policy to allow more detailed consideration of specific impacts within areas.

· Support for renewable and low carbon energy development in the plan. Where there are specific opportunities then these should be identified through allocation of sites or designation of areas – but ultimately sites should not be precluded where new opportunities arise that could meet criteria.

· References to biodiversity net gain and nature recovery networks are appropriate within the Plan. There are likely to be instances where offsetting of biodiversity net gain may need a strategic approach where locations outside of the city can provide opportunities. It is encouraging to see reference in the suggested updates to the strategic nature of these issues.

· The inclusion of a policy approach to addressing recreational disturbance on the Humber Estuary frontage is noted. The updated Hull Local Plan will consider a similar approach to ensure consistency.

· The Council have previously put forward land bids to provide land to meet future needs within the Haltemprice area. The Council would welcome an acknowledgement that the two sites in question present positive (and sustainable) options for new housing development.

North Yorkshire County Council

· General support for policies ENV1 and ENV2.

· Support for the Important Landscape Areas designation for The Yorkshire Wolds, Heritage Coast designations at Flamborough and Spurn Head, and The Lower Derwent Valley. Request a clearer map to be provided of these areas.

· Support for locating development where there is existing public transport provision.

· Support for the use of planning gain payments to improve use of existing cross boundary public transport services.

· Support for the economic strategy and in particular the policies applying to the Goole and Humberhead Levels sub area.

· Support for the complementary approach to pursuing residential development in Goole and Howden, alongside the proposed commercial development and expansion of employment opportunities in Goole.

· The commitment in Policy A4 to expanding the area’s key economic sectors - including renewable and low carbon energy operations – presents an opportunity to strengthen and add value to the ‘Energy Corridor’ Strategic Development Zone highlighted in the York, North Yorkshire, East Riding and Hull Spatial Framework.

· Prioritising Junction 36 (M62) as a key employment site for manufacturing, storage and distribution uses aligns with the future ambitions to establish logistics-based employment sites along the M62 at Junction 34 (M62) in Selby District.

North Lincolnshire Council

· North Lincolnshire Council is committed to engaging positively and proactively with neighbouring authorities to satisfy the requirements of the Duty to Cooperate. We have no matters of soundness or legal compliance to raise.

· General support expressed for the Plan and its approach.

· Support for the Plan strategy to accommodate the area’s full objectively assessed housing and employment needs. North Lincolnshire has a relatively self-contained housing market area and acts as a single functional economic market area. Nevertheless, it is acknowledged there is still a housing market area relationship with East Riding, particularly since the Humber Bridge Tolls were halved in 2012 allowing for cheaper access across the bridge.

· Support for the Principal Towns and the Major Haltemprice Settlements as a sustainable location for future development ensuring any pressure on North Lincolnshire’s services and facilities is minimised.

· Support for Policy A1 (D1.v) which supports improvements to the A63/A15 Humber Bridgehead Interchange, including Humber Bridge roundabout.

· Maintaining an up to date Humber Area Local Aggregates Assessment will require continued collaboration between the two authorities.

· Acknowledgement that the Habitats Regulations Assessment has recognised and considered the likely significant effects on the Thorne & Hatfield Moors which is well related to both authorities.

· Figures 16 and 19 Maps imply North Lincolnshire is a District Council by the ‘North Lincolnshire DC’ label. A minor modification to these figures could remove the ‘DC’ text. NLC is a Unitary Authority.

Ryedale District Council

· The proposed submission documents present no conflicts with Ryedale’s existing Development Plan or the emerging Plan review, nor is there any signs of cross boundary issues.

· The duty to cooperate has been satisfied through your communications and engagement throughout the plan process.

Selby District Council

· No specific officer comments to make on the document but look forward to continued dialogue with the East Riding of Yorkshire.

Prescribed Bodies

Historic England

· Support expressed for reference to the incredibly rich historic environment of the East Riding and the large number of designated heritage assets which it contains.

· The figures provided on the numbers of designated heritage assets of each type does not match up with the data available on the National Heritage List for England. The information on the number of heritage assets in the East Riding should be corrected and reference made in the environmental statistics box to the number of Scheduled Monuments at risk.

· Support expressed for the Local Plan Vision.

· Support expressed for objective 19 relating to recognising, protecting, conserving and enhancing the historic environment and heritage assets.

· Policies H3, H4, EC1, EC2, EC5, ENV1 and ENV2 are supported.

· Suggest the reference under Policy S4 criterion D1. i. to enabling development is deleted. Criteria D1. does not make it clear that points i. and ii. should be applied equally to proposals to convert buildings in the countryside for economic, tourism or community uses as to those for residential use.

· Support expressed for Policy ENV3, in particular the contribution blue and green infrastructure makes to the historic environment.

· Policies H1 and H2 are considered sound. References to specialist housing and rural exception sites being of a scale and design appropriate to the role, character and appearance of the settlement are supported.

· Reference to the historic environment should be included under para 7.3.

· Support amendments to Policy ENV3 in response to previous comments there is no need for criterion C to refer to “built” non designated heritage assets as this policy criteria should be applied equally to all non-designated heritage assets.

· References within the sub area policies to protecting heritage assets are supported. However the terminology used should be amended to reflect that used in Chapter 16 of the National Planning Policy Framework.

· Amendments suggested to the following allocation site policies to ensure these can be considered sound with regards to implementing the recommendations set out in a Heritage Impact Assessment: COT-N, COT-O, HOW-G, CRA-F, NAF-D, SKG-B.

Humber and North Yorkshire Integrated Care Board

· The CCG have previously highlighted specific concerns with continued housing development in relation to the ability of existing NHS healthcare partners to cope with the associated increases in demand. The response to the consultation highlighted in particular the impact on primary care services where existing shortfalls in workforce are creating barriers to access, digital infrastructure to facilitate remote consultations and transport to and from NHS facilities where people do not meet the criteria for funded patient transport.

· During this stage it was not clear what the specific impact of developments would be until detailed proposals for areas for development were proposed. The Local Plan update does not adequately reflect these issues though it is acknowledged that there are statements relating to further discussions though it is not clear at what stage these will be.

· Furthermore, the update specifically references the loss of healthcare facilities but does not equally give attention to the pressure on these existing facilities that new populations will bring.

· The LHNA provides an excellent account of the changes in demographics within the ERY population over the coming years, specifically referencing a growing elderly population - a cohort that will have increased need for specialised housing and who will be a higher user of healthcare (and other) services. The study also reflects the need and challenges of providing for specific parts of the population with particular needs e.g. those with learning disability and dementia. The Local Plan Update does not reference or appear to take into account these pressures.

· The CCG, now the ICB, has not received any further request for consultation on specific housing developments in the context of the above and therefore cannot provide assurance that the needs of additional populations can be met as we would wish nor that existing populations will find current access remains unchanged. In addition, the statements made by colleagues within NHS England (current commissioners of dental services) have now been superceded by events. It is known that there are areas within the East Riding where access to an NHS dentist would involve a waiting list in excess of 5 years and where there is no private provision either.

· Whilst the duty to cooperate has been undertaken to an extent, it does not appear that the outputs of these discussions and revisions have been captured in the Local Plan Update, bringing into question the validity of conclusions supporting additional housing as proposed.

Natural England

A separate statement of common ground is being progressed with Natural England.

National Highways

A separate statement of common ground is being progressed with National Highways.

The Environment Agency

· General support expressed. No issues raised which could result in the plan being found unsound. There are however a number of points where greater clarity could be provided.

· Support expressed for Policy S2 subject to some amendments relating to criteria B,H,L, M and O.

· Support expressed for Policy S9 subject to some amendments relating to the incorporation of Nature Based Solutions within development proposals through utilising a natural capital approach.

· Sites for gypsies and travellers should be in mains drainage with water supply and appropriate waste disposal facilities. Holiday parks and residential developments should also be held to these standards.

· Support expressed for Policy EC5 subject to including stronger support for the development of low carbon hydrogen production.

· Amendments relating to criteria A3 and the supporting text of Policy EC1 suggested.

· Strongly advise that the wording of Policy ENV1 be enhanced regarding water resources and stronger water efficiency measures.

· Strongly suggest that wording is updated with regards to the water quality section within Policy ENV4.

· Support expressed for Policy ENV5. Support the comments made by Natural England with regard to Biodiversity Net Gain (BNG). Amendments are suggested to the supporting text regarding the Water Framework Directive and BNG.

· Amendments relating to criteria D and G of Policy ENV6 suggested.

· Against a number of sites there is reference to “applying the sequential test within the site.” The policy wording should be amended for the relevant sites to avoid built development within areas of high flood risk now, or in the future as a result of climate change.

· Comments submitted in relation to Policy ECB-C, HOR-E and HOW-G.

· Support expressed for HOW-G as favourable (from a flood risk perspective) in comparison with the de-allocation of sites in Goole.

· Comments submitted on the monitoring section of the Sustainability Appraisal.

[1] Section 110 of the Localism Act 2011 inserted section 33A (Duty to co-operate in relation to planning of sustainable development) into the Planning and Compulsory Purchase Act 2004.

[2] The Major Haltemprice Settlements comprise the villages of Anlaby, Willerby, Kirk Ella, Cottingham and Hessle

[3] The council is offering ongoing support to Hull City Council for further transport modelling around Dunswell roundabout.

[4] Section 4 of The Town and Country Planning (Local Planning) (England) Regulations 2012.

[5] For the East Riding of Yorkshire Local Plan co-operation with the Mayor of London and Transport for London was not deemed necessary. In addition, there is no Integrated Transport Authority covering the East Riding of Yorkshire.