Planning for 86 Stakesby Road : Our Comments

GREEN SPACE

NPPF 103 states “… Planning policies should be based on robust and up-to-date assessments (qualitative and quantitative) of the need for open space, sport and recreation facilities. …”).

We firstly state that North Yorkshire Council (NYC) do not possess a robust and up-to-date assessment of the green space of Whitby parish. The most recent green space audit was performed in 2014 by the now defunct Scarborough Borough Council.

The SBC (2014) assessment report was not robust, in that it contained various errors – incorrect per person scaling of secondary school sports space, double accounting for Helredale Playing field, inadequate allowance for the “accessibility” of a green space, and so on. The report simply treated “accessibility” as the distance to get to it, and not how accessible it was, for example to elderly / disabled people. With respect to accessibility, the Whitby parish has double the national average of over 65 residents, so ask yourself the question – would a 10ha portion of green space on a cliff at an incline of 40 degrees be of the same value as a 10ha gently rolling country park?

The SBC (2014) assessment is not up-to-date in that several bits of green space have been built on by NYC in the intervening years, yet the report has never been updated to take account of this.

NPPF 104 requires that any designated green space not have its use changed or built on, unless the robust, up-to-date assessment mentioned above shows that it is surplus to requirements. The only robust, up-to-date assessment of Whitby green space is provided by Whitby Community Network CIC and not NYC. Even ignoring accessibility of green space (as mentioned above) this clearly shows a net DEFICIT of 9.9ha of green space (deficit of 5.4ha of Natural, 6.2ha of Urban Parks, and 1.0ha of Sports with surplus of 2.7ha of Amenity), relative to the minimum standard. Once we take in to account accessibility for the resident and visitor, this shows a net DEFICIT of 21.9ha of green space (deficit of 10.9ha of Natural, 6.2ha of Urban Parks, and 7.5ha of Sports, with surplus of 2.7ha of Amenity).

If we look at other recognised assessment mechanisms for green space, on the Natural England “Green Infrastructure”

• There are several areas in Whitby that fail the AGst Doorstep standard (0.5ha within 200m) – notably large parts of Stakesby, Castle Park, Mayfield, Railway, Eskdale.

• The majority of the residential areas in Whitby fail the AGst Local standard (2.0ha within 300m).

• All of the Whitby urban area fails the AGst Neighbourhood standard (10.0ha within 1km).

Similarly for the Fields In Trust “Green Space Index” (broadly similar to the AGst Doorstep standard) the majority of Whitby urban area is below the minimum standard.

We have thus demonstrated that this green space is NOT SURPLUS TO REQUIREMENTS.

NYC has recognised in many reports the benefit that can be obtained from access to green space, and the NYC Director of Public Health has stated “There have been positive impacts from having accessible, local green spaces, which have supported both physical and mental health and wellbeing”. Whitby has some of the lowest health outcomes in the whole of the county, with a widely publicised “coastal health crisis”. Life expectancies of both Whitby NYC divisions are in the lower reaches for the whole county. It is essential that green space in such areas be both protected and enhanced to benefit the health and well-being of the community.

NYC have no published plan for how they aim to get Whitby parish up to the minimum standard (quantity as well as quality) of green space, as a result they cannot offer a viable alternate site in a nearby accessible location that would replace the green space being proposed to be disposed of.

As a consequence Local Plan Rule HC 14 prevents any such change of use of this green space, and any ignoring of such would be the subject to legal challenge.

Policy ENV 8 states “The value and strategic role of the Green Infrastructure corridors within the Local Plan area will be protected and enhanced …”. The green corridor where this proposed disposal is located consists of one of the very few collections of mature trees in the parish. It provides a habitat for significant amount of species. It is also a critical access route from the Stakesby residential area, through to West Cliff, leisure centre, as well as a connection to the town centre. As such it is of significant value locally, and to dispose of a significant part of it would devalue it. It provides areas for local children to play, as well as providing a tranquil environment to walk away from cars. Such areas should be enhanced, not diminished, and removal of an area for private use only as well as providing vehicular ingress further into this area would significantly diminish it for the local community.

ACTIVE TRAVEL

Local Plan Policy INF1 (e) states “promoting sustainable modes of transport other than the private car”. This proposal fails to respect this requirement., and indeeds promotes the use of the car by provisioning the ingress of motor vehicles into a tranquil green corridor which is heavily used by local people as well as children from the local primary school. It has a children’s play area at one end and so is a focal point and safe space for children.

NYC have a declared climate target of modest increase in levels of walking, along with a 900% increase in levels of cycling by 2030. Whitby & district currently has very low levels of cycling due to the lack of infrastructure (cf UK Active Lives Survey). As a result it is essential that all existing active travel infrastructure is both protected and enhanced so as to actively encourage uptake of such modes of transport.

The Whitby LCWIP document, adopted by NYC in May 2025, has an active travel corridor along Stakesby Road and, as a result, this green corridor is critical in providing safe access to that corridor from the substantial Stakesby residential area. The Department for Transport have established that around 70% of the public would not contemplate cycling around vehicles. Policy INF 1 (g) states that any development should be “protecting, managing and enhancing an integrated network of routes for those without access to a car”. Increasing vehicle access would increase danger to all users of this area, and inhibit active travel not promote it.

The NPPF states

117. Within this context, applications for development should:

(c) create places that are safe, secure and attractive – which minimise the scope for conflicts between pedestrians, cyclists and vehicles, avoid unnecessary street clutter, and respond to local character and design standards;

This proposal would result in the ingress of vehicles in the centre of the active travel path and, as such fails to respect NPPF 117(c), making the green corridor less attractive, less safe for use with active travel, and increasing the conflict between vehicles and pedestrians / cyclists.

ADDITIONAL

The property proposing this change-of-use already has parking facilities, with 1 garage, and 1-2 car parking space(s) on the pavement outside the gates; this should be adequate for a house of the size in question and, additionally, Stakesby Road has on-street car parking available. Should the garage not be considered suitable for parking the owner should firstly re-purpose that space for suitable car parking before promoting further ingress of vehicles into a designated green space area.

This green space is additionally an historic thoroughfare, being the drive for the former Harrowing Hall. It should be preserved for the heritage.

SUMMARY

We hereby request that the change of use of this land is refused. Moreover, we also request that NYC arrange for bollards to be installed at the Stakesby Road end of the green corridor (like there are at the Byland Road end), so that no vehicles can spoil this tranquil area, and so that it can be a safe space for active travel.