LOCAL PLAN FOR THE BRADFORD DISTRICT – ALLOCATIONS DEVELOPMENT PLAN DOCUMENT

As you will know the Council is in the process of producing a new Local Plan for the District which will eventually replace the current statutory development plan (the Replacement Unitary Development Plan). You may also be aware that the Local Plan comprises several separate documents which are at different stages of preparation.

I am now writing to inform you that work has commenced on another Local Plan document, the Allocations Development Plan Document (DPD), and the Council are beginning a period of ‘Issues and Options’ consultation on Tuesday the 10th May.

The Allocations DPD is a key planning document as it will identify and allocate sites which will meet the district’s needs for new homes, jobs and infrastructure. It will also designate key areas of amenity and environmental value such as green spaces and wildlife areas so that they are protected and enhanced. The Allocations DPD will cover the majority of the district but please note it does not cover or include policies or allocations for the Bradford City Centre or Shipley & Canal Road Corridor areas which are the subject of separate Plans.

When adopted, the Allocations DPD, will contribute towards decisions on individual planning applications.

The Allocations DPD is required to implement the policies of the Council’s Core Strategy and accord with the Government’s National Planning Policy Framework. The Council are therefore not consulting or inviting comments on matters which are the subject of the Core Strategy such as how many homes are needed and should be built in each settlement.

Aim of this consultation

The Council welcomes the submission of comments on any matters but at this early stage are particularly keen to receive comments on:

  • The intended scope of the plan – what it will cover;
  • The sites which should be allocated to meet development needs and targets;
  • The greenspaces and environmental areas which should be protected; and
  • Any information, evidence, studies or data which the Council should consider.

A range of supporting material has been published on the Council’s website to inform this process. In particular documents and maps have been produced to show the current list of potential development sites on an area by area basis. There is an interactive map of the district on the website which shows the sites in more detail.

The Council welcome comments on the suitability, or otherwise, of these sites for development and what type of development would be appropriate. However it has also issued a ‘Call For Sites’ which means it would welcome the submission of additional site options. Such sites should be deliverable and be a minimum of 0.2ha in size.

The main documents which you will find online include:

  • A ‘Background and Scope’ paper which indicates the things the Plan will cover;
  • Background papers which include lists and maps both of possible sites and also currently designated green spaces;
  • A ‘Call For Sites Suggestion Form’ – the Council encourage those suggesting additional sites to use this as it ensures that the Council have the right information to begin assessing them;
  • A ‘Call For Evidence’ paper;

The material for the Allocations DPD can be viewed from Tuesday 10th May at: http://www.bradford.gov.uk/bmdc/the_environment/planning_service/local_development_framework/development_plan_documents.htm

Deposit Locations

The key consultation documents are available for inspection at the following deposit locations:

  • Principal Planning Office: at Jacob’s Well, Bradford. Please note the service is due to re-locate to Britannia House in June so materials will be transferred there;
  • Main libraries: Bradford Local Studies Library, Bradford City Library, Shipley, Bingley, Keighley and Ilkley.
  • Town Halls & One Stop Shops: at Shipley1, Keighley and Ilkley

People are free to download and print their own copies of the consultation documents and supporting documents as they require.

How You Can Comment

There are several ways in which comments can be submitted. This includes a standard form which can be downloaded or via the Interactive map which has a facility to make comments. Comments can be submitted by post or by e-mail. The Council strongly encourages the use of electronic and online methods of submission as it makes the processing and response to them quicker and more efficient.

Representations should be submitted to:

planning.policy@bradford.gov.uk or in writing to:

Local Plans Group, 2nd Floor South, Jacobs Well, Manchester Road, Bradford, BD1 5RW.

Comments and responses must be received by 5pm on Tuesday 19th July 2016

The Council appreciates that the Local Planning process is complex so please feel free to contact the Council’s staff at the contact details below if you require any information or wish to receive advice or assistance on how to submit your comments or use the online interactive map.

Please note – submitted comments including names and postal addresses cannot be kept confidential as the Council are required by law to make these available. However your telephone number, e-mail address and signature will not be published. Further details of the data protection exemptions which the Council has to follow under planning legislation is included on the comment forms.

Any comments submitted may be accompanied by a request to be notified of forthcoming stages including:

  • when the Allocations DPD is submitted for independent examination by the Planning Inspectorate and
  • of the publication of the recommendations of the person appointed to carry out the examination; and
  • on the adoption of the DPD.

Group Responses

Where there are groups who share a common view on how they wish to see the Plan changed, it would be very helpful for that group to submit a single representation which represents the view of the group, rather than separate individual representations which repeat the same points.  In such cases the group should indicate how many people it is representing and how the representation has been authorised.

What Happens Next?

Following the period for representations the Council will record and consider each of the comments, assess the issues raised, gather evidence and assess all site options. It will then prepare a preliminary draft Plan for further consultation.

Should you have any further queries about the Plan or the forthcoming process please contact my colleague Simon Latimer at simon.latimer@bradford.gov.uk

or by telephone (01274) 434606.

Should you require assistance in accessing the online material or using the online maps and questionnaire please feel free to contact my colleague Leah Midgley at (01274) 434461 or by e-mail to leah.midgley@bradford.gov.uk

Yours faithfully,

Andrew Marshall

Planning & Transport Strategy Manager

FLOODING – a novel solution

Author Dr Steve Ellams

A public meeting is to be held at Kirklands, Menston at 7.30pm

on

Tuesday 26th April 2016 

Professor David Rhodes CBE, FRS, FR Eng will illustrate, explain and answer questions on his novel solution to Flooding reduction, for which he has submitted a patent application!

All are welcome.

This will be an opportunity for all concerned with FLOODING to hear at first hand some of the solutions.

A new cost-effective technique is proposed for the management of water flow from the upper rainfall catchment areas which has a minimal effect upon water capture into reservoirs whilst increasing the daily baseline flow of water into the rivers. By achieving this objective, when prolonged rainfall events occur, the peak flows both overland and in the rivers will be reduced.

Such a solution will be described with supporting evidence to illustrate why it will achieve the desired objectives.

The presentation will be of interest to environmental technical officers, politicians and the public alike.

Please circulate this invitation widely.

An email confirming your attendance would help in the organisation and be appreciated.

This meeting is being held under the auspices of Menston Parish Council.

Prevention is better than cure

Letter printed in the local press Author Dr. Steve Ellams

Sir

I refer to the front pages of both the Ilkley Gazette and the Wharfedale Observer dated March 31 2016.

An up to date publication regarding flooding and drainage issues from Bradford MDC has just been published (Local Flood Risk Management Strategy).

I would like to point out from Addingham to Menston various groups from Parish Councils to Action Groups have been pointing out serious concerns about the lack of joined up thinking when it comes to flood risk.

There are examples in the District of serious shortfalls in planning controls leading to developments being blighted. In addition where there are old Victorian combined sewers, in some circumstances these cannot cope now and most certainly will not be able to cope with proposed large scale developments.

I quote from this latest document:

 “National Flood Management has previously been managed in a disjointed way.  Flooding from rivers (fluvial) has passed between successive Government agencies, whilst land drainage and sewer flooding has been managed in a variety of combinations on Local Authorities and public and private water companies.  The blurring of boundaries for responsibilities and uncoordinated actions of different risk management authorities has resulted in a failure to provide consistent and coordinated actions in response to local flooding events.”

I have, with many others, been in dialogue with all of the agencies who are likely to have some input regarding flooding and drainage. The buck passing is quite extraordinary!  Is it not time for someone to get a grip, particularly on the health risks regarding sewer flooding which is now becoming a regular event.

It is a well-known fact the pollution in our streams occurs on a regular basis and that the odd failure at a treatment plant is no longer the reason. According to an OFWAT report on New Housing Developments they voiced concerns about additional new housing without making provision for suitable drains and making sure existing sewerage systems could deal with the extra load.  They also pointed out problems have become worse since new developments have been built and overloaded the sewerage system and concluded that sewerage flooding had been a problem for the past 10 years and was probably due to extra building of houses in an area.

Just like any other problem in life, prevention is better than cure. This means that considerable re-plumbing of sewer systems to allow for large scale developments must be a priority and thereby reduce the risk.  The infrastructure must be able to withstand large scale developments which is certainly, in my opinion, not the case in the Bradford district.

Ilkley housing increase could be overturned at new hearings

Amanda Greaves Ilkley Gazette.

MASIVE increases in house building figures for Ilkley and its neighbouring communities are to come under the scrutiny of a Government planning inspector in what is believed to be an unprecedented move.

Wharfedale-based campaigners are hopeful hundreds of additional new homes written into the yet-to-be-approved Local Development Plan Core Strategy could be dropped as the result of a fresh set of hearings in May.

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The surprise announcement comes a year on from hearings about Bradford Council’s development strategy for the district.

Planning inspector Stephen Pratt, who examined the initial Core Strategy document last May, has called further hearings on May 17 to 20 to examine new issues not discussed in detail the first time around.

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Dr Steve Ellams, of campaign group Wharfedale and Airedale Review Development (WARD), said: “I couldn’t believe it when it came out.

“To me, it’s unheard of to have an inspector call it back.”

A debate last year between Bradford Council planners and legal representatives of a consortium of developers saw the local authority agree to revise its 15-year housing strategy figures for Ilkley, Burley-in-Wharfedale and Menston.

Subsequent modifications saw Ilkley’s housing allocation increase from 800 to 1,000, Burley’s from 200 to 700 and Menston from 400 to 600. Burley and Menston were also re-designated as Local Growth Centres – something organisations, including WARD, have since argued are not feasible.

WARD has continued to send evidence to the inspector opposing the new figures, citing strain on the local infrastructure, including Victorian sewers currently struggling to cope with surface water during heavy rain, as demonstrated during the Boxing Day floods.

“You can’t force a pint into a half-pint pot,” added Dr Ellams.

He believes the inspector now has concerns about the housing increases, resulting in the unusual move of holding further hearings.

Dr Ellams added: “We think it probably is to do with what we’ve put forward.

“We’re very hopeful he’s going to see through some of the developers’ statements. This isn’t a development centre – people aren’t going to move here from the centre of Bradford to go back into Bradford for work.”

However, he also warned developers may take the opportunity to defend the current figures or even press for greater scope to build yet more homes.

Meanwhile, Ilkley ward councillor, Martin Smith (Con, Ilkley), attacked Bradford Council regarding its handling of the “flawed” Core Strategy.

He said: “The figure of 42,000 homes was based on 4,200 new jobs, now downgraded to 3,600 in the latest deposit to the inspector.

“If I was responsible for the Core Strategy, I would be looking at any options to reduce these 42,000 new homes and to places that need the homes, recognising the basis upon which it was calculated was flawed.”

He went on to call for affordable homes on brownfield sites instead of new development in the greenbelt.

“Affordable homes are needed where work is, and the developers should not reduce the affordable numbers on the back of over-priced greenbelt land,” Cllr Smith added.

“Use the brownfield Government grants before they are taken up by other authorities. Already councils are buying up older houses, upgrading them and selling them on at a profit, so why is Bradford doing nothing?”

LEEDS MPs CONTINUE TO GIVE US INVALUABLE SUPPORT!

Two of Leeds MPs who have consistently supported Wharfedale & Airedale Review Development in our efforts to defend Green Belt from predatory housebuilders and, also, in our campaign for planning reform have once again demonstrated their willingness to work with this organisation. Stuart Andrew MP for Pudsey, at our request, has managed to secure us a face-to-face meeting with four of Leeds CC’s chief decision-makers; on the 23rd May we will be meeting with Leeds CEO Tom Riordan, Council Leader Judith Blake, Chief Planning Officer Tim Hill and the councillor i/c Housing Richard Lewis. This meeting, which will be at the Civic Hall, will give us the opportunity of posing some hard questions about housing targets, the SAP & Green Belt loss, transport & infrastructure. Rest assured we will not be ‘pulling any punches’ and we will be fighting strongly on behalf of all who wish to preserve our precious open spaces, improve our environmental infrastructure and retain quality of life for future generations.

In the course of a major debate at Westminster on the 9th February this year, the member for Leeds North West, Greg Mulholland MP, referred once again to the important work being done by this organisation and, having done this, has ensured that Wharfedale & Airedale Review Development has now received three mentions in Hansard – the official record of the UK parliament. This clearly demonstrates we are getting something right and, again, that we are the only community networking organisation to have had regular contact with several of our local MPs since our formation some 5 & 1/2 years ago. See Greg’s letter and the Hansard reference below:

greg h

Transcript of Greg Mulholland’s debate input from Hansard.

Greg Mulholland: Thank you, Madam Deputy Speaker. I welcome the intervention from the hon. Lady, and indeed anything that will get Leeds City Council building more and using its powers. We need to learn from best practice everywhere and from councils of any colour.

My final point is that the planning system is not set up to deliver the solution to the housing crisis. Deregulating and making it easier for developers to build on green belt and greenfield sites will not help.

I share the criticism of the housing targets and the fact that Leeds City Council will not revise its target.

I have campaigned with my neighbouring MPs and with Wharfedale and Airedale Review Development, which highlighted the flaws in the council’s case. At the same time, WARD is very clear that there need to be changes in the planning system. It feels that, because of the planning system and the way that developers are able to exploit it, Leeds City Council will not stand in the way of developers.

I again ask the Minister to look at my National Planning Policy Framework (Community Involvement) Bill, which came up with a number of solutions last year on how we can give more specific powers to communities and councils; look at housing targets not on a council but on a regional level; allow co-operation; and do more to put into practice the words from the Minister about ensuring that we incentivise development on brownfield sites.

The balance is not right on either the planning system or housing. Until the Government accept that and stop hiding behind the dangerous gimmick of the right to buy, it will leave many sections of our society with no way out of this housing crisis.

Obviously to facilitate and maintain our work WARD needs to retain and increase the support it already receives from individual community groups across the region.

Accordingly, I invite any individual or group wishing to join us, or to comment on any of the above, to do so through this website. All are welcome! We really need to work together and stand united in our campaign for planning reform if we are to succeed in saving our environment.

The old adage is true: UNITED WE STAND; DIVIDED WE FALL!

Dr David Ingham

Chairman

 

Giving away the greenbelt – A critique of Bradford’s Local Plan

Author JA Thompson

‘We have got some money from the Government over the next three years to build affordable housing in the area [Bradford]. The issue in Bradford is that some of the private developers do not want to build houses where the Council wants them to. They would like to build on greenfield areas in Airedale and Wharfedale instead.’

Councillor Val Slater (Deputy Leader of Bradford Council) Telegraph and Argus 22/09/2015

The trouble with this is that Mrs Slater isn’t exactly telling the whole truth. Far from discouraging developers from targeting sites here, and elsewhere in the greenbelt, the Council has actively assisted them. Under the NPPF deleting bits of the greenbelt to open it up to development should only be considered in ‘exceptional circumstances’ which generally means having too many households and not enough other land to put them on. Bradford doesn’t have the exceptional circumstances the NPPF calls for so the Council has resorted to telling fibs. Not just one fib or a couple but a whole string of them and across a number of years. There isn’t space here to include all of them so let’s just look at three of the whoppers.

First off how about having too many households? The Council claims that by 2030 over 42,000 new homes will be needed to house its growing population. This isn’t true. Department of Communities and Local Government (DCLG) and ONS projections show that the number of households is likely to grow by just 28,000 between 2015 to 2030 (the lifetime of the Local Plan). So the Council is planning a socking 14,000 more homes than are required. Even if they argue that they need to clear a backlog because too few houses have been built since the economic crash of 2007/8 they only need to build 2,000 more to catch up so a target of 30,000 would be more realistic.

So how did they reach the figure of 42,000? Initially by telling a fib about job creation. They said that over 4,200 new jobs would be created per annum which would in turn create a need for 45,000 new homes. They argued that building houses would create many of these jobs and construction workers would flood into the District boosting the population. The number of construction jobs they posited was so large that, if one assumes an average annual salary of £26,000, the average new house would have to have yielded over £162,000 on top of materials, land and other costs (never mind any profit) just to pay the builders’ wages. When challenged the Council quietly dropped this nonsense and after a brief detour where they picked another number (2,897), seemingly out of a hat, they finally settled on 1,600 based on some actual evidence (the Regional Econometric Model – REM – data). That’s not even enough to mop up all the Bradfordians who will be of working age, the Council predicts there will be 27,000 more in 2030 than there are now but it is assuming that 15.7% will be claiming out of work benefits and many more will be economically inactive. Despite this they only dropped their housing target by 3,000.

So what about the land supply? Are there enough hectares of brownfield and urban land to take all the new homes in the Plan? This is where a disturbing symmetry creeps into the figures. The Council says that around 11,000 or more will have to be on greenbelt because there isn’t. That’s remarkably close to the 12,000 extra homes they’ve put into their plan so without those extra houses even they are saying no greenbelt deletions would be required. But the full picture is even worse. The Council hasn’t compiled a register of brownfield sites as it has been advised to by the DCLG, it is continuing to rely on sites being proposed by developers, sites that already have planning permission and sites it owns in putting together its Strategic Housing Land Availability Assessment (SHLAA). Yet the urban cores of Bradford and Keighley are riddled with vacant and derelict sites. This isn’t an opinion based on casual observation (though the extent of dereliction is striking to anyone driving through) there is clear evidence that jobs have migrated to what were, until recently, greenfield sites and that brownfield sites have been left vacant.

From 1998 to 2008 the DCLG maintained detailed records on business premises. These give year-on-year changes in the net internal area broken down by class for each Local Authority. What they show is that across the decade there was a net reduction of 559,000 square metres in Bradford. This does not reveal the full scale of abandonment though because premises were built on greenfield sites during the period (there was a boom in urban edge development, particularly retail and business parks) so an awful lot more premises were falling idle than at first appears as businesses and jobs migrated out of the urban core. And the net internal area of a typical business is only a fraction of the land it takes up. If we take the formula Bradford uses to calculate land required for employment and reverse it we can estimate that 559,000 square metres of internal space may well translate into 174.69 hectares of land. What about the rest, the gross figure?

Some of this may have been recycled for housing, some excellent developments have been completed (at Manningham Mills, Little Germany and Trident for example). But regeneration was limited. DCLG land use figures show that in recent times only around 40% of new builds here were on previously developed land and much of that was formerly occupied by houses or their gardens, not industrial premises.

And there is clear evidence that the migration of business to greenfield sites has continued apace since 2008. The 2005 Replacement Unitary Development Plan (RUDP) identified 193 hectares of employment land; land to be set aside for new build ‘B’ class premises such as warehouses and factories. Of these 100 hectares are described in the narrative as greenfield with greenfield prospects forming the bulk of the larger sites. By 2013 when a further review was conducted only 107 hectares remained, most of which were smaller (brownfield) sites. Few people would quibble about this if opening up new greenfield land had led to an increase in jobs, but it didn’t. The REM data shows that the number of jobs fell by 2,049 (FTE) from 2007 to 2013. What happened to the land those jobs had been on and what happened to the land left idle as jobs migrated to greenfield sites? The answer is, by and large, nothing. The urban core of the District (Bradford and Keighley) is being hollowed out and this isn’t sustainable either economically or environmentally. We cannot have a Mad Hatter’s tea party approach to planning where homes and jobs are pushed onto greenfield sites and into the greenbelt because developers want a clean bit. We can’t afford it.

Greenfield development requires investment in new infrastructure. Developers are supposed to contribute but they negotiate hard and the bulk of the tab falls on the public purse. They certainly don’t pay for ongoing maintenance. Meanwhile the integrity of the infrastructure that remains in areas with derelict sites needs to be maintained, generally at public expense. These are sites that contribute nothing to that maintenance: no gross domestic product, no rates and no workers’ wages circulating through the local economy to support other businesses. One way or another we pay those bills, not the developers.

One question all this raises is does the Council have some higher, public interest motive for giving the greenbelt to developers and for manipulating the evidence to enable them to do so? It doesn’t look as though they have. They certainly haven’t articulated a plan for housing, employing or training Bradford’s people that relies upon artificially inflating housing requirements, in fact some of the data published alongside the Plan shows that it is likely to be counter-productive. Let’s take meeting housing needs as an example.

To meet housing needs in full you have to make sure that new homes come at the right price for your population. The spread of prices has to link in with the spread of local wages and with underlying property prices or they won’t sell, not even to buy to let investors. And if they can’t be sold they won’t get built.

Looking at Bradford’s proposals it’s clear that they don’t reflect the economic realities of the local housing market. Bradford is a low wage economy, there are some very affluent people here but their numbers are limited. ASHE/HMRC PAYE data for 2013 shows that median incomes (full-time adult wages) ranged from £354.3 per week in Bradford West Constituency to £498.3 in Keighley (which includes Ilkley and other parts of Wharfedale). At a multiple of 3.5 people earning these salaries could raise mortgages of £64,483 and £90,691. It also has a depressed housing market. The Land Registry put mean property prices here at £95,704 in November 2015 which represents a fall of 22% from the pre-crash peak of £123,670 (February 2008). Compare these figures with the prices developers charge, below are averages for three to five bedroom properties taken from the Bradford CIL Viability Evidence Addendum (2015) which gave prices as reported by developers:

£316,000 to £539,000 in CIL Zone 1 (Wharfedale, the most expensive area)

£270,000 to £456,872 in CIL Zone 2

£229,729 to £374,996 in CIL Zone 3

£151,468 to £389,995 in CIL Zone 4

It’s impossible to give a proper estimate of what they might charge for one and two bedroom homes because the report shows figures for only one area, Zone 4, where prices for two bedroomed properties ranged from £99,995 to £117,950 (no prices were given for one bedroom properties). What seems clear from this is that developers are targeting their products at a very small section of the market consisting of the more affluent buyers. This goes a long way to explaining why they are focusing on Airedale and Wharfedale and the greenbelt but it doesn’t explain why the Council is going out of its way to enable them to do so. By facilitating building on the greenbelt when it isn’t needed it will be helping developers to pursue a high margin, low output strategy instead of encouraging them to work harder for their profits by building more houses for the less affluent people who make up the bulk of the population. It will also encourage developers to target buyers who do not rely on the economies of Bradford and its neighbouring Local Authorities for their incomes. In the case of Wharfedale, particularly Ilkley, this includes retired people from far afield who would like to live near the National Park. Ilkley has seen a massive growth in age restricted developments in the past two decades including a large retirement village with eye watering monthly fees. Drawing elderly people into an area, no matter how affluent they are, is imprudent. As they become increasingly frail they put additional and unnecessary pressure on local services and budgets, particularly those of the NHS. This is recognized as a serious problem in coastal towns which draw in retired people.

Releasing greenbelt won’t help the Council to meet local needs for market housing but its proposals for affordable housing are even worse. Its plan puts a substantial proportion into the more expensive parts of the District but given that ‘affordable’ means sold at a discount of usually just 20% below market value or under a part ownership scheme many will still cost more than the average house in the Local Authority area. Those in Wharfedale are likely to cost in the region of 75% more than their equivalents on the open market elsewhere. So they will not be addressing the needs of people who can’t access housing on the open market (which is what affordable housing is supposed to do) but of people who are almost, but not quite, well off enough to buy a house at the full market rate in a particularly desirable area. This is inappropriate to the point of being improper.

Bradford’s Local Plan is a disgrace. It will not meet local housing needs and it will be environmentally and financially costly. On these grounds alone it should be challenged. However, it should also be challenged by anyone who has an interest in maintaining probity in public life. Council Officers have misled ordinary Councillors and the public by feeding them misleading data, in doing so they have destroyed the transparency in the planning system that protects it from corruption.

For more information on the topics covered in this article, including more detailed reports showing key data, please contact Addingham Planning Scrutiny Group by e-mail at:            apsg.addingham@mail.com

“Vibrant New Rawdon Action joins force with WARD campaign for Planning Reform”.

As Chairman of WARD, I have great pleasure in introducing one of the newly formed, highly committed and efficient action groups who are dedicated to saving the last vestiges of our precious green landscape from development by unscrupulous volume builders. WARD is pleased to have RGAG on board and in support of our campaign for planning reform to the NPPF. Without further ado I will let Briony say a few words outlining RGAG’s aims & objectives.

David Ingham

Rawdon Greenbelt Action Group

Rawdon Greenbelt Action Group’s aim is to retain the unique and special landscape character of Rawdon and Aireborough. To label us or others who campaign to save their greenbelt as ‘Nimbys’ (not in our back yard) is to do so without knowing the FACTS and the Law.

We are committed to this aim because we know that planning Law is being manipulated for ulterior motives to the detriment of Aireborough. Our campaign is rooted in the knowledge that the Council’s plan is unsound because they have not done a genuine comprehensive greenbelt review. But it is about so much more.

It’s about raising awareness amongst the community and beyond about what is being planned for them in a clear and evidenced manner.

It’s about questioning how the Council allowed the ‘big five’ housing developers to cherry pick the most profitable sites years ago and met frequently with them. It’s about questioning the absence of true democracy, of LCC not engaging regularly with its communities to help shape where they live. The citizens of Leeds have had just 8 weeks in the last TWO years to have their say in the city’s plan. Just 64 days! Oh, and 28 days in 2013 at an initial consultation when a tiny fraction of the Leeds population had the vaguest idea of the fact that the Council even had a plan.

When the government decided to respond with such vigour to the undoubted need for countrywide new homes, why wasn’t a Minister appointed to ensure that aesthetic control and long-term vision for the Country’s urban design and town planning challenges that would inevitably ensue? At such a pivotal moment in England’s rapid physical expansion – the biggest since post WWII – why? The design of the legacy this would inevitably leave behind was not a top priority. Why did aspirational and ambitious LCC not engage with its creative community – the architects and designers – to seize the singular golden opportunity to draw up a truly innovative, visionary and aesthetics-led plan for the urban growth of the city beyond the inner ring road?

Our campaign is about raising awareness of the fact that there are DEFINITELY 90+ brownfield sites previously allocated for housing being sieved out of the plan because they weren’t going to make developers More than ENOUGH profits.

It’s about raising awareness about the Public Consultation so that the public actually KNOW it’s happening. If we had a £1 for every person that has told us they’d no idea there was a public consultation, nor how drastic the Council’s plans were for Rawdon, Aireborough and Horsforth’s greenbelt we’d have a very healthy bank account. Yet the Council frequently reach every home in the city to provide well written reminders about which day their bins are going to be emptied.

It’s about challenging the flawed system which allows developers to hold Council’s to ransom, paying for roads and desperately needed improvements, as long as they can get the option to build houses on the land that’s freed up around the roads, causing MORE congestion – not less (the supposéd ‘Airport Link Road’ being a prime example).

It’s about challenging LCC’s aspirational a housing target which is way in excess of the far bigger conurbations of Manchester, Birmingham, Liverpool. This target has been the root cause of the problems the plan has thrown up, flawed from day one when old ONS stats were used to reach a target of 70,000 dwellings for what can only be ulterior motives. The Law is clear about one thing – Council’s must use the most up-to-date figures when calculating housing targets. 70,000 homes will generate a great deal of Council Tax.

It’s about a plan which exclude the interests of its communities – a ‘plan’ that has NOT been planned.

If there remain any doubters, those who will smile smugly and throw the label of ‘Nimby’ at anyone daring to challenge this plan, I’d be curious to hear what you have to say. The FACTS are the FACTS and the Law is the Law (albeit one that is open to interpretation).

It’s not so wrong to expect the right sort of houses for people’s real needs, in the right places, at a fair price, in fair volume… is it?

Briony Sloan
Chair
Rawdon Greenbelt Action Group

www.rgag.org.uk

 

“Final WARD Response to Leeds Site Allocations”

WARD’S RESPONSE TO LEEDS SITE ALLOCATIONS PLAN

(For the attention of the Planning Inspector appointed to decide on the soundness of the current Leeds Site Allocations Plan)

Greenbelt

The Leeds SAP document makes clear that 42% of sites allocated across the whole of Leeds are to be on greenbelt/greenfield land. This is directly contrary to the directions in Chapter 9 of the NPPF, which states in para 79:

“The Government attaches great importance to Green Belt. The fundamental aim of greenbelt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.”

In para 80 the NPPF outlines the five purposes of Green Belts:

  • To check the unrestricted sprawl of built-up areas;
  • To prevent neighbouring towns merging into one another
  • To assist in safeguarding the countryside from encroachment;
  • To preserve the setting and special character of historic towns;
  • To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

Paras 81, 82 and 83 of the NPPF make it abundantly clear that Green Belts, once established, should “only be altered in exceptional circumstances” (Para 83). Recently the Government, through the DCLG, has emphasised that the use of Green Belt land to accommodate local authority housing targets does NOT constitute exceptional circumstances. Leeds is clearly in contravention of this ruling guidance as it is claiming the housing target as an exceptional circumstance justifying its inclusion of so much Green Belt land in the SAP. This clearly makes the Plan unsound as it is not consistence with national policy.
An example of inconsistency with national policy in Rawdon is site HG2-12 (4254) Woodlands Drive. Para 126 of the NPPF requires local plans to set out a positive strategy for the conservation and enjoyment of the historic environment. The Council has a statutory duty, under the provisions of S72 of the Planning Act (Listed Buildings and Conservation Areas) 1990, to pay special attention to the desirability of preserving character or appearance of Conservation Areas. The Council has not taken account of the fact that this site adjoins the boundary of the Rawdon Cragg Wood Conservation Area and Leeds Council has not carried out any assessment of the harm which the use of this site might cause to the Conservation Area and this is another example of what makes the Plan unsound and inconsistent with National Policy.

Other sites which can be considered unsound on conservation grounds are:
HG2-1 New Birks Farm, Guiseley
HG2-2 Wills Gyll, Guiseley
HG2-5 Coach Road/Park Road, Guiseley
HG2-9 Land at Victoria Avenue, Yeadon
HG2-10 Gill Lane, Yeadon

Paras 132, 133 and 134 of the NPPF deal with conservation matters in detail. Furthermore, there are obvious access issues which mitigate against the use of site HG2-12 (4254) for its designated 130 dwellings.

Merging of Communities

The combined use of sites HG2-41, HG2-12, HG3-2 and HG3-3, given that the intervening space consists only of Rawdon Crematorium, would serve to merge Horsforth and Rawdon. Also the combined use of sites HG2-1 New Birks Farm, Guiseley and HG2-2 Wills Gyll, Guiseley will serve to join the townships of Guiseley and Menston. This is inconsistent with both the NPPF and Leeds Core Strategy. Site HG2-41 in particular is a matter for grave concern. This site is in Green Belt, as identified within the Leeds Core Strategy; it was also identified in the Leeds UDP as a ‘Special Landscape’. It is also shown in Leeds Core Strategy as ‘Strategic Green Infrastructure’.

A further matter of concern regarding site HG2-41 for 777 homes is the chaos that will be caused to traffic congestion on the A65 and the A6120 (the outer ring road). As long ago as December 2011 WARD commissioned a special study by specialist traffic engineers Met Engineers of Hunslet, Leeds on traffic on the A65/A658. Even at that early stage and before a significant number of dwellings were constructed in the area (550 at Riverside and Clariant) and before the current Site Allocation Plan, the A65 was designated by this report as being:

“….. simply unfit for the volume of traffic now using it, whether on weekdays or at weekends, and any further increase in capacity will see further reductions in traffic flow speeds, higher levels of congestion and a continuation of the practice of trying to make more rapid progress by “rat running” onto even less suitable roads through residential areas.” Para 4.11 Met Engineers A65/A658 (Leeds to Burley-in-Wharfedale) Transport Study for Wharfedale and Airedale Review Development (WARD) Revision C, December 2011

As far as WARD is aware there are no significant plans outlined in the Leeds Core Strategy for dealing with the impact of extra traffic which will be generated by the large number of dwellings proposed along the A65. The recently completed Horsforth roundabout does nothing to relieve congestion, there is still queueing in every direction at peak times. The traffic lights simply allow vehicles to ingress and egress the roundabout with a greater degree of safely than was previously experienced before their installation.

Community Consultation

In WARD’s opinion there has been inadequate community consultation regarding the SAP. Leeds City Council has made no provision to communicate with the 35% of its population who are not online and, consequently, have no access to the necessary documentation and information which would enable them to make a reasonable response. Unlike the neighbouring authorities of York and Wakefield, Leeds has also failed to record incoming responses to the SAP Consultation on its website. Commentators, therefore, have no means of inspecting incoming responses (during the eight week consultation period) as one may do with planning applications; where responses to these applications are available online during the entire consultation period. When challenged on this matter, a senior planning officer stated “We have insufficient money to do this” – a remarkable statement coming from a representative of a City wishing to be “the number one City in the UK”. This makes the Plan legally non-compliant and therefore unsound.

Co-operation with Neighbouring Authorities

To WARD’s knowledge there has been inadequate consultation with the neighbouring authority of Bradford. Leeds and Bradford have held one or two meetings in early 2015 (??). This needs confirmation but one or two meetings is hardly meaningful co-operation. It is safe to assume from this that co-operation with the neighbouring authority of Bradford on matters of infrastructure necessary to accommodate proposed developments from both cities is grossly inadequate. This contradicts government instructions detailed in the NPPF (paras 178, 179, 180 and 181).

Housing Density

The Strategic Housing Land Available Assessment Practice Guidance Document (July 2007) from the DCLG suggests approaches which can be taken to estimating the housing potential of each site. It clearly indicates a proposed methodology and a formula for calculating site capacity. This is as follows:

SITE SIZE X DENSITY MULTIPLIER X NET/GROSS RATIO
(HA)    (FROM TABLE 1)    (FROM TABLE 2)

To understand these tables it is necessary to refer to the full DCLG document.

Using this methodology it can be seen that the average number of dwellings for all the sites in the SAP document is much smaller than the average we should expect had Leeds adhered to the guidance methodology proposed for determining site capacity. This is a good indicator that affordable housing will suffer as sites able to accommodate an average of 35 houses per hectare will be accommodating only 25 – 28 units (developer favoured executive style). Furthermore, had Leeds allowed for the larger average it would not have been necessary to use any Green Belt in the Site Allocations Plan.

Cumulative Effects on Infrastructure

The Site Allocations Plan, apart from proposing a large number of sites for development which contribute to the heritage assets of Leeds, will also have a devastating cumulative effect upon transport and social infrastructure. Para 2.52 of Section 2 of the Plan makes clear “establishing that the site is suitable for use” should be part of a prime consideration for site selection. It is obvious from the Plan that there has been no real evaluation of what impact the inclusion of many sites will have upon the environment. This also makes the Plan unsound as it contravenes section 12 in the NPPF, which in para 126 states:

“Local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment ….”

The principals and policies set out in this section apply to the heritage-related consent regimes for which local planning authorities are responsible under the Planning Act 1990, as well as to plan-making and decision-taking.

Site Allocation Process re Core Strategy

In view of the fact that Leeds has admitted its Core Strategy housing target of 70,000 by 2028 is based upon flawed figures and that it proposes to review the figure, why can it not do so before the Site Allocation Plan is submitted for public examination to an Inspector? Why must it delay for three years? If the SAP were to be based upon the latest OMS 2011 Census figures then Leeds would not require to use any Green Belt in order to maintain a five year land supply.

It is interesting that Inspector Harold Stephens rejected the Plan for Durham on three major points, namely:

  • An over ambitious housing target;
  • A highly aspirational job growth target;
  • The inclusion of too much Green Belt to accommodate the first two points.

This Durham decision sets an important precedent as the similarity with Leeds is unmistakable. Surely an Inspector must take account of the fact that the inclusion of so much Green Belt land in the Site Allocations Plan for this City is a direct result of a target based on flawed statistics. To consider this Plan before revising the target is surely “putting the cart before the horse” and inviting devastating environmental consequences for future generations. It is also making it impossible for designated bodies (ie Parish/Town Councils and designated forums) to prepare and complete Neighbourhood Plans as they will have no say whatsoever in deciding sites upon which to build houses to meet assessed housing needs for their areas as the sites will already have been predetermined. This mitigates directly against the true spirit of localism and makes a mockery of Neighbourhood Planning; it becomes a pointless exercise – paras 183, 184 and 185 on Neighbourhood Plans of the NPPF.
As and when an independent inspector is appointed to declare whether or not the Site Allocations Plan is sound (as required by para 182 of the NPPF), WARD would like the opportunity to outline in greater detail and to present, at the Examination in Public, yet further evidence to support WARD’s assertion that the Plan has:

  • Not been positively prepared (there is no provision for impact or improvement to social or transport infrastructure)
  • Not been justified (the housing target is based on flawed statistics)
  • Has not been shown to be effective (housing numbers delivered are already well behind where they should be in terms of meeting the 70,000 target – thus the target will not be met by 2028)
  • Has not been shown to be consistent with national policy (its use of Green Belt land is inconsistent with the whole of Section 9 of the NPPF Protecting Green Belt.) It therefore contravenes all of the five purposes of Green Belt outlined in para 80 of the NPPF.

It should be noted also that Leeds has failed to carry out a full and comprehensive review of Green Belt as advised by Inspector Thickett in October 2013. The Site Allocations Plan must be considered unsound in light of all of the above.

 
Dr David Ingham
Chairman
Wharfedale & Airedale Review Development
(WARD)

Five years on in Menston

Author Dr Steve Ellams

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The campaign groups representing the Menston community against inappropriate development have steered them towards the end of 2015. It is hard to think their efforts now span over 5 years. Please find an update on the current planning decision making in and around Menston, in addition see website: menstonactiongroup.wordpress.com
A lot of water has gone under the bridge (excuse the pun) and time has taken its toll in many different ways, particularly financing such a protracted campaign. If it were not for the pro bono arrangements with their accountancy and legal team and the stoical work done by members of the community, none of the current actions they are taking would be possible.
However they believe they are nearing the finishing line and with continued help from the community they can stop the proposed developments at Bingley Road and Derry Hill.

Currently a Judicial Review on the Chartford Homes development site (Bingley Road) will start at the High Court in Leeds on 12 October 2015.

In addition, due to a refusal of planning permission on 10 February 2015 (13/04897/MAF) the developer has made an appeal at the last minute to the Planning Inspectorate for the main Bingley Road site.
“The applicant has failed to demonstrate that the submitted drainage scheme will be adequate to prevent the increased likelihood of flooding of properties off the site.”
A date has not yet been finalised but watch this space!

As regards Derry Hill, even though they were not successful in the middle of July with the Judicial Review their legal team is still optimistic as to the outcome of this process.

The group are not against housing in and around their community, that’s progress, but developments of the magnitude proposed will on strong evidence bring sustainability problems but above all, flooding and drainage issues. There is a substantial risk that many Menston households, not just those adjacent to the developments, will suffer flooding and both new and older properties would be rendered uninsurable.
Historically Menston’s whole reason for existence has been strongly linked and based on water. It is just about everywhere. Their team has mapped approximately 23 unidentified culverted water courses in and around the village over the past 5 years.
Development at the proposed sites will, according to the expert report published in December 2014, exacerbate the situation. What they do know is 35% of the 2,000 letters of objection mentioned a flooding and drainage issue. They believe these issues can only get worse and affect more households.

Dr Steve Ellams
Projects Manager WARD