Consultation Question 6

Object

Representation ID: 29162

Received: 25/03/2021

Respondent: Ilkley Town Council

Cross-boundary approaches – concerns re development near district boundary (Old Middleton Hospital site). Without SCG there is no recognition of the impact on Ilkley’s infrastructure should development go ahead/SIL/S106

SP5 (B) Exceptional circumstance have not been met for
-IL1/H - Ben Rhydding Drive, Wheatley Grove, Ilkley
-IL2/H - Skipton Road East
-IL3/H - Coutances Way

The Local Plan should carry out the assessment detailed in NPPF para 137 before concluding that exceptional circumstances exist to justify changes to green belt boundaries.

Exceptional circumstances not demonstrated as site yields have been dictated by the developers / the SLA and the 50dph density requirement has not been applied to sites.

Exceptional circumstances not demonstrated as the approach to housing distribution has applied the settlement hierarchy first before the NPPF para 137 tests

SP5 (E) reasonable alternative:
“Where land is released from the Green Belt for development the Council will identify compensatory improvements to the environment quality and accessibility of remaining Green Belt that produce a measurable net improvement to the beneficial use of the Green Belt in the same locality as the Green Belts release. This may include inclusion of additional land in the Green Belt in those localities, and/or Local Green Space Designations to protect green spaces within settlements.”

Object

Representation ID: 29209

Received: 23/03/2021

Respondent: Rachel Wood

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 29562

Received: 23/03/2021

Respondent: Harvey Bosomworth

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 29602

Received: 17/03/2021

Respondent: Mr Mark Summerson

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Comment

Representation ID: 29658

Received: 24/03/2021

Respondent: Leeds City Council

The proposed allocations around the Holmewood area, encroaching into the green belt to the south of Tyersal and to the west of Drighlington, raises concerns.

Firstly, concerning the general encroachment and reduction of the strategic green belt gap between Leeds and Bradford; secondly the significant amount of green belt land that is required for release for 5 proposed housing sites for 1,447 new homes. The sites are SE45, 31, 13, 18/H and SE46, 47, 48/H and non-green belt site SE19/H and thirdly the overall impact of these sites and significant housing numbers on infrastructure provision in Leeds.

In setting exceptional circumstances for the release of these sites Leeds City Council would wish to see justification that all other options have been exhausted for housing in other locations within the settlement hierarchy.

It is also understood that Bradford City Council’s position is that the highway improvements as shown on the interactive map for Wakefield and Tong Road are sufficient to support the number of houses proposed. We wish to reserve our position on this until further evidence / information is provided through further consultation and duty to cooperate discussions.

Object

Representation ID: 29703

Received: 24/03/2021

Respondent: Keyland Developments Ltd

Agent: Barton Wilmore

Our Client supports the Council’s conclusions that exceptional circumstances exist to release land from the Green Belt to meet their housing requirements, as outlined in the supporting text for the proposals. However, our Client objects to the omission of their residential site in Esholt as a proposed housing allocation (site ref: NE/053).

The Site re-uses previously developed land, which means it would be sequentially preferable when considering which land should be released from the Green Belt, as per paragraph 138 of the NPPF.

The fact that the site falls outside of the Bradford North East boundary should not prohibit the site from being allocated, indeed, the Council are allocating the employment element of the Esholt site, which also falls outside the boundary.

Given the above, there is no procedural reason as to why the Esholt residential site cannot be allocated and included within the Bradford North East sub-area, in the context of the employment site being allocated. The Esholt development has always been viewed holistically, and the Council have encouraged the landowners to approach the design of the site in a joined-up manner and we strongly believe it should be allocated as one to ensure the holistic approach is maintained.

Support

Representation ID: 29704

Received: 24/03/2021

Respondent: Keyland Developments Ltd

Agent: Barton Wilmore

Our Client fully supports the Council’s position that ‘exceptional circumstances’ have been demonstrated to warrant to release of land from the Green Belt to meet the Council’s employment needs and we fully support the allocation of NE23/E as an employment site.

The Council’s existing employment land supply is generally of poor quality and small in scale meaning that indigenous businesses wishing to scale up their operations may have to leave the District due to lack of choice in the market. The Esholt development is large in scale and offers a unique location in terms of site characteristics (flat topography; development platforms in situ; previously developed land; attractive landscape surrounds) and well as being highly sustainable due to the proximity of Apperley Bridge railway station, bus routes and the local road network.

The Esholt development is hugely important to the Council and it is essential that it is allocated in order for the Council to meet their employment targets over the plan period.

We note that the proposed allocation does not included the land which is currently being proposed for the vehicular access to serve NE23/E and we would advise that the boundary is revised to safeguard an area around the proposed access route, as without this, it could be argued that the land which his allocated is not achievable as there is no suitable access within the confines of the Site.

Support

Representation ID: 29717

Received: 24/03/2021

Respondent: Bellway Homes Limited

Agent: Barton Wilmore

Our Client supports the Council’s conclusions that exceptional circumstances exist to release land from the Green Belt in order to meet their housing requirements, as outlined in the supporting text for the proposals. In addition, they fully support the Council’s proposals to allocate site SW33/H for residential development of up to 175 dwellings.

The site sits within adjacent to the settlement of Clayton but due to the form of the village, which extends northwards at its eastern and western extent, the site would in effect fall within the built form of the village, which limits the extent of encroachment and minimise sprawl. Also, it would not lead to the coalescence of settlements. In summary, it would represent a sound and logical rounding-off of the settlement and its release from the Green Belt would be acceptable as it no longer serves the five Green Belt purposes.

Object

Representation ID: 29791

Received: 23/03/2021

Respondent: Ilkley Civic Society

We have been repeatedly reassured that Green Belt is safeguarded against development by government ministers in person, through the national press and television.

A great deal of emphasis is being placed on ‘weak boundaries’ to green belt. This term is meaningless and barely relevant. The boundaries are not weak. They have lasted for several decades. Using up the two indicated areas of green belt in Ben Rhydding does not in any way safeguard or make stronger the adjacent areas. It reduces the greenbelt between Burley in Wharfedale and Ben Rhydding. Describing the boundaries as weak appears to mean that the council wants to develop the sites they enclose. Describing boundaries as less durable is equally specious; they have lasted for at least 25 years and there is no case to change them. The intention of green belt is that it remains in perpetuity.

Green belt is not necessarily of high landscape value. In this case, however the landscape value of Wharfedale, including the two areas to the east of Ben Rhydding, are of particular landscape value as they provide the setting to the town and the important distant vistas, as far as Beamsley Beacon, for travellers arriving in rural Wharfedale, whether by road or train. Views of the green belt area east of Ben Rhydding from across the valley around Denton and Askwith reinforce this attractive, sylvan, rural nature.

Green belt has the purpose of preventing urban sprawl. There is precious little open countryside between Ben Rhydding and Burley in Wharfedale. Because Ilkley is constrained by the moor to the south and the Nidderdale AONB to the north, the only ‘spare land for development’ in Ilkley is to the east and west of the town which creates an elongated ‘sausage’ shape with the extremities in semi-detached ghettoes at considerable distance from services and infrastructure.

In order to release green belt, there needs to be a ‘net gain for bio diversity’. There is no mention of how this can be demonstrated for any of the three impacted sites in Ilkley.

The Green Belt Review (undertaken by consultants for BMDC) and potential changes/allocations should have been fully consulted upon and put before an Inspector prior to the overall composite/allocation process. As this has not happened, the Green Belt review needs public examination at this stage of the process and brought before the Inspector for examination as the next stage in the overall process, before the specific sites are scrutinised and the plan completed in 2023.

Support

Representation ID: 29950

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

We agree with the Council’s conclusions that exceptional circumstances do exist which justify and require a change to the general extent of the Green Belt as set out in the Plan.

Comment

Representation ID: 29951

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

We agree with the Council’s conclusions that exceptional circumstances do exist which justify and require a change to the general extent of the Green Belt as set out in the Plan.

In the interests of effective planning the Local Plan will need to retain flexibility now within its strategic policies and in order to respond to potential housing land supply shortfalls over the plan period. It may be that more advantageous, sustainable sites exist for example where the five purposes of the Green Belt is weak as opposed to poor performing countryside and brownfield sites.

Object

Representation ID: 29952

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

We welcome mention of the South East Bradford Access Road (SEBAR), however note that this is only included within the pretext and not within the policy itself. The policy should be more explicit to mention the committed South East Bradford Access Road and given it is still an aim of Bradford further detail provided on the projected route.

Object

Representation ID: 29953

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

Safeguarded land

We would recommend the inclusion of Safeguarded Land within Policy SP5 or as a dedicated policy on Safeguarded Land, as detailed as a reasonable alternative. Safeguarded land is essential, particularly in BMDC where the Green Belt boundaries once set are to be of permanence in accordance with NPPF paragraph 136. Again, Bradford is a heavily contained Green Belt authority with 66% coverage.

While we note BMDC’s conclusions that there is not sufficient evidence to include safeguarded land it is important to have an effective mechanism to allow development in accordance with the link road, as was originally envisaged. This is fundamental given the revised standard methodology requiring 2,300 dpa (see comments in respect of recommendation 4) which counter’s the council’s own evidence base on the need to allocate sufficient, flexible land.

By not including safeguard land associated with the committed SEBAR there creates inflexibility in the plan constraining development which would alongside the SEBAR provide regeneration to the Holme Wood area as set out within the Vision Document at Appendix 2. The piecemeal allocation of c. 297 new homes without allocating or, as a minimum, safeguarding the wider site misses the opportunity for comprehensive regeneration.

Recommendation 3: Include Safeguarded Land in respect of the SEBAR and Holme Wood urban extension, setting a boundary across the entire site to build in flexibility over delivery over potentially multiple plan periods in the interests of effectiveness and positive plan making.

Object

Representation ID: 30001

Received: 23/03/2021

Respondent: Daniel Spencer

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 30082

Received: 23/03/2021

Respondent: Mrs Savia Lorain Hughes

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Support

Representation ID: 30134

Received: 22/03/2021

Respondent: Robbie Feather

Agent: ID Planning

We support the proposed Green Belt releases to provide sustainable sites to deliver the current identified housing requirement.

Support

Representation ID: 30141

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We support the Council’s position that exceptional circumstances exist to release land from the Green Belt.

Object

Representation ID: 30165

Received: 23/03/2021

Respondent: Catherine Terry

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 30200

Received: 24/03/2021

Respondent: CPRE West Yorkshire

We do not accept that the economic growth proposals set out in policy SP6 robustly justify the allocation of Green Belt sites for employment, and therefore do not consider the exceptional circumstances have been adequately demonstrated for Green Belt change to supply employment land.

Object

Representation ID: 30201

Received: 24/03/2021

Respondent: CPRE West Yorkshire

SP5E describes an approach to compensatory improvements to the Green Belt. In line with our comments about net gain it is essential that the net effect of releasing land from the Green Belt is a measurable net benefit to the function of the Green Belt. We suggest a rewording of SP5 along the following lines: Where land is released from the Green Belt for development the Council will identify compensatory improvements to the environment quality and accessibility of remaining Green Belt that produce a measurable net improvement to the beneficial use of the Green Belt in the same locality as the Green Belts release. This may include inclusion of additional land in the Green Belt in those localities, and/or Local Green Space Designations to protect green spaces within settlements.

Object

Representation ID: 30264

Received: 24/03/2021

Respondent: Ms Rachel Belk

I disagree with SP5’s stated incontrovertible case for loss of this amount of greenbelt, citing ‘exceptional circumstances’ (NPPF paragraph138). The pandemic must have increased brownfield site availability through altered working patterns and business changes: this should be revisited and the Valley Road site considered.

Object

Representation ID: 30286

Received: 23/03/2021

Respondent: Barry Hopkinson

Whilst some Green Belt release for development is accepted, it is essential that this takes place in sustainable locations. Addingham has a significant number of sites (5) coming forward as Green Belt release sites. The sites on the western side of Addingham are particularly unsustainable, being distant from services in the village and therefore likely to encourage the use of private cars even for short trips to local services. Moreover, these sites on the western edge will not bring forward many houses for the amount of land they lose to Green Belt - 67 houses on 2.93ha of Green Belt. Addingham should have a lower level of provision, as set out in SP3, and this should exclude a number of Green Belt sites including AD1/H, AD6/H and AD7/H.

Object

Representation ID: 30294

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Conservative)

Planning Policy states that Green Belt should only be released for housing in exceptional circumstances. Policy SP5 –Green Belt and SP8 –Housing Growth are narrative statements which are subjective and are no justification for releasing Green Belt siteS for housing.