WARD’s Response to Leeds City Council’s Site Allocation Consultation

Comments of the WARD organisation are as follows:

Protecting Green Belt
The WARD organisation is concerned that so much green belt appears to have been placed in this site allocations exercise and too much brownfield land has been ignored.  Approximately 60% of the sites across the city (whatever their colour grading) appears to be drawn from greenbelt land and this goes directly against government policy outlined in para 79 of the National Planning Policy Framework:

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

Para 80 follows with:
“Green Belt serves five purposes:

  • To check the unrestricted sprawl of large 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;  and
  • To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.”

Para 87 goes on to state:
“As with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.”

And finally Para 89 is quite clear:
“A local planning authority should regard the construction of new buildings as inappropriate in Green Belt.  Exceptions to this are:

  • Buildings for agriculture and forestry;
  • Provision of appropriate facilities for outdoor sport, outdoor recreation and for cemeteries, as long as it preserves the openness of the Green Belt and does not conflict with the purposes of including land within it;
  • The extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building;
  • The replacement of a building, provided the new building is in the same use and not materially larger than the one it replaces;
  • Limited infilling in villages, and limited affordable housing for local community needs under policies set out in the Local Plan;  or
  • Limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development.”

The proposals outlined in the entire Leeds City Site Allocations Programme are in direct contravention of the above NPPF guidelines on protecting greenbelt land.  As such, the WARD organisation strongly objects to the inclusion of so much greenbelt land in the Site Allocations Plan.  Naturally we understand that inclusion in the SHLAA does not necessarily mean that all the sites will be developed but, given the composition of the SHLAA Group and the current trend for developers to claim that brownfield sites are non-deliverable it comes as no surprise to find so much greenbelt included in the proposals.  This, of course, readily identifies land likely to produce the greatest profits for developers and under current planning legislation, makes the greenfield sites extremely attractive targets.

Public perception of the SHLAA partnership is such that house builders and local property agents are seen as paying more attention to profit margins.  The argument that house builders and local property agents provide expertise and knowledge to help the SHLAA take a view on the deliverability of sites and how market conditions may affect economic viability only strengthens this public perception.  The current SHLAA group comprising:

  • Leeds City Councillor (Chair)
    • LCC Planning Officer
    • LCC Planning Officer
    • LCC Planning Officer
    • Community representative
    • Campaign for Protection of Rural England representative
    • Renew representative
    • Homes and Communities Agency representative
    • Leeds Property Forum representative
    • Leeds City Region representative
    • Barratt David Wilson Homes representative
    • Persimmon Homes representative
    • Ben Bailey Homes representative

can hardly be said to be unbiased.  There is little doubt that the house builder input has had an inpact on sites selection evident in this Site Allocations Plan.  The SHLAA partnership needs drastic revision and a more open and transparent way of proceeding with its business.

Infrastructure Problems

Traffic Congestion
The Leeds City Council Site Allocations Plan and, indeed, the Core Strategy with its housing targets of 66,000 over the next 15 years which predicates the need for the identification of so many sites appears to pay little heed to the vast amount of evidence which clearly demonstrates lack of  both transport and social infrastructure.  A recent study (Tom Tom Congestion-Index for Europe

2013) shows that the Leeds/Bradford area is the 8th most congested conurbation in Europe and also the most congested in the UK – London ranks 10th.  Public transport issues (see below) are responsible for the A65 and A660 being the two most heavily congested roads in Leeds and this is directly related to an increase in vehicle numbers on many minor roads (eg Burley Road) by ‘rat running’ car drivers.

Public Transport Issues
Public transport, at peak times, struggles to cope with commuters from dormitory areas such as Aireborough, as buses can take up to 50 minutes to reach the city centre from Menston and Guiseley and trains, at peak times, are jammed to capacity (standing room only) and commuters from places like Otley and Guiseley itself drive cars to Menston causing congestion and blocking village roads in their attempts to board trains and find a seat.

The parking at Guiseley railway station and in Guiseley generally is totally inadequate and this too forces drivers to commute further out to board trains.  Any further plans to increase populations in these dormitory areas can only exacerbate these problems.  There is an urgent need for these transport infrastructure problems to be addressed before any further development is even considered in areas such as Aireborough.

Social Infrastructure
Again, as evidenced by recent meetings in Guiseley, there are major problems associated with the availability of school places, doctors, dentists, recreational areas and other social requirements demanded by an increase in population due to new development.

Hospitals in Leeds are already over-stretched illustrated by the maternity situation where two hospitals were closed for admissions for about 100 days last year and expectant mothers were forced to travel to Bradford and other health authorities to give birth with consequent post natal care issues.

Schools are now very much over capacity and recent meetings concerning the expansion of two Guiseley infant and primary schools caused a furore from irate parents who demanded to know why there was land available to build 2,300 houses in Aireborough yet no land available upon which to build a new school.  Education representatives stated quite clearly that for every 100 houses built there would be a demand for 25 primary school places and 10 secondary places.  This equates (in Aireborough) to 575 primary school places and 230 secondary school places, when all the proposed 2,300 extra houses are built, clearly indicating the need for new schools and not extensions to old ones.  Indeed, proposed extensions to all schools will cause further infrastructure problems by adding to existing traffic congestion and depriving our children of playing space when temporary classrooms are sited in their outdoor areas.

Patient lists for doctors and dentists, especially in the outer dormitory areas, are already over-subscribed and it is almost impossible to gain early appointments to these medical practitioners.

Drainage, sewerage, flooding, waste collection, again it appears that impact on these facilities has not been carefully considered.  Existing sewerage and drainage infrastructure is currently not coping with the heavy rainfall we have experienced over the last few months.  Most drains were  constructed in Victorian times and are certainly not able to cope with extra demand due to excessive development.

These problems of transport and social infrastructure appear not to be addressed in the Leeds LDF Core Strategy and it would seem sensible that some careful thought should be afforded to having infrastructure improvements in place before any further large scale development is even considered.

Conservation Issues and Heritage
Of particular concern to the WARD organisation in addition to the potential loss of greenbelt land, are the green spaces in Nether Yeadon and Rawdon around the Warm Lane area which are local landmarks and give the place character and distinctiveness.  These sites offer an open recreational space for the community and the Highfold hamlet dates back to the mid-1700’s and is acknowledged as an important historical area in the Ordnance Survey of 1851.

In particular WARD considers that the following sites in Aireborough should be protected:

Ref 3033        Highfold Farm                      214 houses
Ref 1104        Greenside Farm                     58 houses
Ref 2162        Warm Lane                             72 houses
Ref 1221        Gill Lane                                155 houses
Ref 1308        Green Lane                           125 houses

The above sites are all within half a mile of at least 10 Grade Two listed buildings and major development on the above sites will impact adversely on the character and distinctiveness of this area.  Has discussion about the inclusion of these sites in the Site Allocation Plan taken place between planners and the Leeds Conservation Department?  If not, why not?

Further sites of concern in Aireborough are as follows:

Ref 4043        Ings Lane                                94
Ref 3026        Ings Lane                              535

These sites are most unsuitable and are subject to flooding.  The old English word ‘Ings’ means marshland and obviously will pose problems for both developers and residents if built upon.  They also have no access to public transport and they are attractive greenbelt landscape protecting us from urban sprawl and providing an important boundary between Guiseley and Menston.Thus they fulfill the purposes of greenbelt as outlined in the NPPF.

In conclusion, the WARD organisation strongly objects to Leeds City Council’s decision to include so much greenbelt in the proposed Site Allocations Plan.  It urges LCC to reconsider this decision as it directly contravenes the NPPF’s guidance notes on the protection of greenbelt land.  These greenbelt sites should be withdrawn forthwith and Leeds should carefully consider how best to utilise the many brownfield sites currently considered ‘undeliverable’.  It is obvious that LCC have felt the need to include greenbelt sites in order to meet their somewhat over-ambitious LDF Core Strategy numbers and this is to be strongly deprecated.  The WARD organisation does not accept these aspirational LDF figures and will continue to contest them.

In the meantime, WARD would also urge LCC to concentrate on persuading house builders to complete the thousands of planning permissions already granted on sites where not a single brick has been laid.  They should also concentrate on renovation of the 15,000 or so empty properties and consider ways of following NPPF policy of brownfield first.

Footnote:       Please note all the above comments are evidence based as a result of responses to questionnaires issued to gather evidence for Neighbourhood Development Plans by the Aireborough Neighbourhood Forum and by Rawdon Parish Council whose comments can be seen here.  There was a consensus that infrastructure issues needed addressing before any further development takes place in Guiseley and Rawdon.  There was common agreement that traffic and congestion issues and school places, doctors, dentists etc need addressing.  Another common concern was the loss of greenspace and recreational opportunities on open ground.  The following is a quote from the concluding paragraphs of Rawdon Parish Council’s analysis of questionnaire responses:

Other Overarching Comments

 Within the survey work participants were asked to identify their three pre-requisites for any development to occur. Overwhelmingly these were to ensure traffic and transport related infrastructure was addressed, adequate school provision was available and that medical facilities had their capacity increased.

The Parish Council has observed a significant body of opinion that is opposed to any development within the parish until such time as the infrastructure issues are addressed.

The Parish Council has struggled to understand how some of the assessments have been carried out and conclusions reached. The Parish Council also has concerns about the impact that development of sites outside the parish boundary may have on congestion and use of facilities and resources within the parish. The Parish Council would be grateful for more detail on how conclusions are reached in future.

The Parish Council is aware that it will continue to collect valuable data and views from residents through the Neighbourhood Planning process and may discover other improvements and requirements may be necessary to support future development within and adjacent to the Parish.”

Please note, the WARD organisation wishes to support and fully endorse the comments of Aireborough Civic Society relating to other sites in Aireborough.