Obviously, most people will know that outline planning was given for the whole site along with full planning to put I the new road system. However, each building will need to go through planning to ensure it meets all the usual requirements. This sounds great and ERYC did put 81 requirements onto ABP which they must meet for this to keep moving forward. This may change with the site now also gaining a Tax-Free Zone status. The government intends to remove all planning requirements for industrial unit within Tax-Free Zones. They will still however have to meet building regulations etc.

We understand that this could be a major blow for the Council and PADEL. Item 81 on the requirements stated that ABP must have regular meetings with a residents committee to discuss plans and ways too move forward. This is now in process, and we still have the following concerns.

• East Ridings of Yorkshire Strategy Plan 2016 the Council Commitment to maintain clear space between Saltend & Paull.
• The Local Road Network including the A63, A1033 and Paull Road even after the proposed work will not be able to cope with the amount of traffic suggested by ABP.
• The Potential of a major incident/accident on the site or adjacent site that could threaten the Village of Paull and its inhabitants.
• It is completely different to the LDO that was issued in 2013 where it was stated that the total footprint of the area should not exceed 30% of the Paull LDO site unless otherwise agreed in writing by the planning authority.
• No building should exceed 22m in height.
• There is no buffer zone between the village and the proposed Industrial Estate.
• The amount of traffic into the East of Hull will increase dramatically if we expect 7600 jobs the number of cars and lorries will cause traffic delays up and down Hedon Road and cause delays to traffic coming west from outlying village of Thorngumbald, Ryhill, Patrington, Keyingham, Ottringham, Roos, etc
• The bird population of Curlews and other species will be affected
• The ancient village of Paull views across the country side will be adversely affected,
• A strategic landscaping plan has to be put forward and there should be agreed planting plans, we will require much more than the odd sapling that has 20 years to grow.
• Atmospheric Pollution must be addressed… Noise, dust, vibration etc.
• This application (and the previous one) specified manufacturing defined under classification B2 of the Town & Country Planning Regulations when in fact ABP have stated that 80% of this development will be Warehousing and Distribution which is a completely different category, B8 under the same regulations. The latest application defines a significant change of use to the previous application and as such should require a that completely new application is require rather than renew the previous one which was for an entirely different development.
• The Integrated Environmental Assessment (IEIA) submitted by ABP as part of this application is based on the building footprint and orientation of the previous application. This latest application has more, and bigger buildings located much closer to the SSSI mudflats and the village hence the noise and other nuisance surveys carried out in the original IEIA are not applicable to the new development.
• The latest application should therefore be subject to a new and comprehensive IEIA that reflects the scale and nature of the development rather than a rehash of the existing one that is irrelevant to the latest application.
• The erection and operation of the large building shown immediately adjacent to the mudflats SSSI will inevitably impact on the birds and perhaps destroy it entirely as a SSSI. It is tempting to suggest that this may be the intention as the longer-term development plan shows a new jetty across the mudflats which would never be approved for a SSSI site.
• Light Pollution will affect the village
• Noise throughout the development and once completed will affect the village
• It was stated in the original LDO that the land would be exclusively used for B2 use specifically related to renewables and low carbon industries.
• No development shall take place until a Construction Traffic Management Plan for that plot has been submitted and agreed in writing.
• The development of this land is in opposition to ERYC’s Community Plan principle to ‘value and care for the diverse character of the area’ as it will destroy many of the key characteristics that form the character of this location as identified in ERYC Landscape Character Assessment Type 21. Development of this land directly contravenes the strategy outlined in this document, including to ‘conserve the unique character of this landscape’ and ‘maintain the valued open characteristics’ and ‘vertical structures should be avoided in this landscape to limit impact on the characteristic openness.’
• Development of this land is in opposition to ERYC’s Strategy Document Place Statement for Hedon:
• The Place Statement states that Hedon’s ‘unique identity and character’ must be maintained and that future development ‘will [have] protected the continued separation of Hedon and the surrounding villages.’ Development of this land will degrade Hedon’s identity and destroy separation from Paull and Hull. Whilst a minimal ‘key open area’ is retained along some of the boundary with Hedon, the development does meet the town at some points. There is no open area retained with the village of Paull and the Paull conservation area.
• The Place Statement states that managing flood risk is essential. Development of this land reduces the open space around Hedon that is available for flood alleviation and drainage.
• The Place Statement states that Hedon’s historic designated and non-designated assets should be protected from development, including key views towards St Augustine’s.
• The Place Statement states that development of Hedon Haven should be sensitive and safeguard biodiversity and heritage assets. Little evidence of this is included in the application.
• The development does not meet the following elements of ERYC’s Spatial Strategy:
• The allocation of this land as industrial/manufacturing/commercial fails to meet the LDP’s Spatial Strategy 4 to ‘Maintain the character of smaller settlements and rural areas’ and Spatial Strategy 18 (and Spatial Strategy 19) to ‘Value the special character of the East Riding’s settlements by ensuring that development reinforces their distinct identity, avoids coalescence and protects their landscape settings and natural assets.’ As above, I refer Landscape Character Assessment Zone 21 for an assessment of this location’s character. This character will be destroyed by development and the planning proposal.
• A comprehensive transport assessment and travel plan and improvements need to be carried out to meet LDP Policies 8 and EC4. The capacity of the highway network of the East-West Multi-Modal Transport Corridor at this eastern extent and through the city of Hull appears already at capacity and predicted transport volume seems flawed and does not take into account other development in the East Riding and at the port. I suggest that there limited improvements to this part of the route are proposed (upgrade of Castle Street, Hull being the only one) and that the road network cannot be improved to provide the required capacity for development of this size and type. (See 4.28 and 5.26 of the Local Plan Strategy Document for proposed network upgrades at other Key Employment Sites – there is no similar development proposed for the network connecting to the sites at Hedon Haven and Saltend.) The traffic flow issue is particularly acute in central Hull and will have a detrimental effect on commuting and social travel for all residents of the East Riding travelling from the east of the city and for travel within the city.
• This proposal does not provide material benefits to the village of Paull and contradicts LP Strategy Document section 4.37 as it will draw significant numbers of people from elsewhere.
• LP Strategy Document section 5.9 identifies serious flood risk and drainage concerns ‘in and around Hedon’ and advises that housing development is suspended until ‘detailed hydraulic modelling work’ is required that may require ‘a partial review of the Local Plan.’ The industrial/commercial development of land around Hedon should be subject to the same level of scrutiny.
• The current planning proposal fails to meet LP Strategy Document Policy S6 Delivering Employment Land requirements for Hedon Haven and Habitats Regulations. The following need to be included: 39 hectares of enhanced habitat that are required to mitigate the impact of the development on the Humber Estuary Special Protection Area and Ramsar Site; due consideration to the Humber Estuary Special Area of Conservation; proposals to preserve or enhance the elements that contribute to the significance of the designated heritage assets in the area. An Ecological Management Plan needs to be created and shared.

• There is no evidence to show that development of this land as proposed meets Policy ENV3, and there is no evidence of proposals to minimise the potential risk of harm to the significance of the designated assets in this locality. Fundamentally development of this land will harm the significance of the conservation areas of Hedon and Paull, the scheduled monuments of the medieval harbour and port of Hedon, and the Grade I Listed churches of St Augustine’s Hedon and St Andrew’s Paull. The character of this area is historic and includes characteristics such as open-fields, long views and ‘big skies.’ It is not possible to mitigate for the harm that this development will cause to the character of the area as introducing development, including hedge-screening, enhanced habitats, buildings and additional infrastructure is fundamentally counter to the landscape character. The character and form of the land at Hedon Haven is fundamental to understanding the scheduled monuments of the medieval harbour and port of Hedon. Similarly physical access to the Haven is imperative to understanding and enjoyment of the monuments, and the views of the listed buildings and conservation areas and this access will be entirely denied. The land forms an integral part of the setting of the aforementioned assets and this will ultimately be destroyed by development on this land in a way that cannot be mitigated, thereby causing significant and irreversible harm to significance.
• An extended Heritage Impact Assessment is required. When this has been completed mitigation measures must be proposed, approved and if appropriate carried out in advance of any development.
• As discussed above, there is little evidence of compliance with most of the requirements of this policy. I am particularly concerned that there is no landscaped buffer zone along the boundary with Paull. As I have also noted, it is not possible to mitigate the harm of this development with measures appropriate to the landscape character of the area.
• Similarly, the proposal shows no buffer zone in some locations between the development and Paull or Hedon, thereby making Hedon, Saltend/the city of Hull, and Paull contiguous. The scale of the development (c.70-80% use of the land) is far greater than the limit of 30% land use set in Local Development Order 2013.
• This LDO follows the Local Development Plan 2016. The LDP was not subject to proper public scrutiny as Historic England was not consulted and is a statutory consultee. (See Historic England’s letter of 19 July 2018.) This also fails to comply with the Localism Act (2011) which requires the Council to cooperate with Historic England and the planning application does not give any consideration to heritage assets.
• There will be a significant loss of amenity and recreational value following the development of the land. This impacts the residents of Paull and significant numbers of visitors, including dog-walkers, walkers, runners, etc.
• A development on this scale will create substantial air, light and noise pollution that will harm residents of Paull and Hedon.