Consultation Question 6

Object

Representation ID: 3460

Received: 22/03/2021

Respondent: Mr David Johnston

The proposal to build on FIVE areas of green belt in Addingham is in direct conflict with my previous comment .... smaller scale of development in local service centres

Object

Representation ID: 3506

Received: 22/03/2021

Respondent: NEAT

The term "Green Belt" does not appear to include all open/green spaces, yet many such spaces are important, especially for urban dwellers who are largely surrounded by brick, stone or concrete. For example, Bolton Road was once a "green corridor", yet 48 houses were built on an adjacent green field, damaging the local biodiversity and removing one of the few remaining vistas.
There is a blurring betwen the need for "housing" and "accommodation", and a lack of convincing evidence that Bradford really needs 22,000 new houses. These figures seem to be influenced by a government that is in cahoots with house-building companies. There is plenty of scope for converting former commercial premises into apartments; and there is a need to warn that population growth cannot continue unchecked without serious and irreversible environmental damage. Bradford is full: If not now, when?

Object

Representation ID: 3673

Received: 23/03/2021

Respondent: Mr Philip Sutcliffe

The green belt was set up to stop urban expansion. In the case of Bradford, to stop it becoming part of Leeds. Bradford planning office being completely undemocratic wishes to pour cement and tarmac all over the green belt in Tong. The reason I say undemocratic is as follows.

There has not been one survey, or opinion poll taken in Bradford, which agrees with Bradford councils views on building on green belt. In fact approx 90 % of population of Bradford totally disagree with Bradford councils housing and road plans. However, the council which claims represents the people is acting like a fascist state.

Your new road and housing plans directly effect my Grade II house and land. However, you have not had the decency to contact me over the last 10 years. I doubt you care less about me than the environment and
the creatures that need it.

Support

Representation ID: 3728

Received: 23/03/2021

Respondent: Ms Rachel Huxham

Supportive of the release of greenbelt areas IL1/H, IL2/H, IL3/H for sustainable housing development noting proximity to services & existing housing, and not within flood zone.

Object

Representation ID: 3775

Received: 23/03/2021

Respondent: Mr Andrew Lund

The Council has not rigorously identified and considered all non-GB sites in the district and consequently has failed to demonstrate exceptional circumstances for GB release. My main concern relates to Ilkley where 97% of the proposed housing units would be on land presently in the GB. This is a vastly disproportionate result in comparison with the other principal towns in the district - Bingley where only 8% is proposed on GB, and Keighley where the figure is 13%. Since 2013 development in Ilkley totalling 414 units has been on PDL, or to a lesser extent greenfield, and with minor exceptions only GB remains. The only GB site which should now be developed is IL2/H Skipton Road where the proposed 20 units produce a much fairer allocation of 6% for Ilkley.
SITES IL1/H AND IL3/H MUST BE REMOVED FROM POLICY SP5

Object

Representation ID: 3788

Received: 23/03/2021

Respondent: Jenny Woodward

The gradual erosion of green belt has a negative impact on nature, wildlife and human health and wellbeing. It also threatens the identity of places as they start to merge with each other. The criteria for 'exceptional circumstances' needs to be more clearly defined and set at a higher bar. I do accept homes are needed but we need to try harder to find alternatives e.g. regeneration of old industrial areas / honing down under utilised shopping areas to make new residential streets. As an example, new houses could have been built in Bingley where the Lidl now is - another supermarket (there are now 4!) adds nothing to the town but could have provided quality housing close to a park and sustainable transport. Instead green belt is being built on.

Object

Representation ID: 3900

Received: 23/03/2021

Respondent: Ms Carol Martin

The use of green field sites is irreversible in ordinary terms. The number and extent of these is very high. Their use will sometimes change the character of the countryside and residential areas significantly. In particular, the building along the Wharfedale corridor will spoil what is one of the most beautiful of the Dales.

Object

Representation ID: 3920

Received: 23/03/2021

Respondent: Mrs Susan Burn

I have carefully read the statement about the policy and I understand the reasons that you provide, however, I cannot support the irreversible loss of green belt land.
Green Belt land is such a precious commodity for our lives now and for the future.

Support

Representation ID: 3922

Received: 23/03/2021

Respondent: Mr David Smith

I support the reduction in the need to build on Green Belt, but consider that there is scope to reduce this need further. In particular, I suggest that the windfall allowance should be increased to 500/year. This should occur through an increase in the number of mills/offices/shops being converted to dwellings; increased numbers of dwellings being built in larger gardens, and situations where houses in larger gardens are demolished and small housing/flat developments become possible.

-Scope to reduce further by focusing on regeneration on brownfield sites, city and district centre regeneration and ensuring vacant properties are reused or redeveloped.
-GB releases need to be delayed as long as possible, partly to ensure that regeneration opportunities are encouraged, and partly because Government cannot continue to use the 2014 household projections indefinitely. More recent projections will need to be taken into account - the 2016 and 2018 projections would reduce Bradford's Housing Requirement to the point where the need for Green Belt release would be largely unnecessary.
-Local Plan should continue to resist the 35% uplift because it threatens the Green Belt in an unreasonable and unnecessary way.
-Questionable if uplift provides an objective, reasonable and necessary reason for justifying 'exceptional circumstance', as recent evidence on household projections show housing need is reducing rather than increasing in Bradford.

Object

Representation ID: 4156

Received: 23/03/2021

Respondent: Residents of Moor Lane, Turner Lane, Moor View and Moor Croft, Addingham

Agent: Airedon Planning and Design

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: 4275

Received: 23/03/2021

Respondent: Mr John Fox

The Campaign to Protect Rural England recently stated that there is space to build 1.1M affordable homes on reclaimed ‘brownfield’ sites across the country. Bradford is no different and could meets its set minimum annual target through developing such sites. It will also have the opportunity to access a new £100m fund launched in January 2021 by the government, giving councils across England the chance to pitch for money to support developments on public land and regeneration of council estates. The councils limited planning resources should be focused here and not even be looking at greenfield (even if of supposed low environmental value) or greenbelt to meet its needs. I would also suggest that the pandemic has changed the housing supply equation for Bradford. Our struggling High Streets and business zones should be repurposed as residential neighbourhoods. Finally, houses to facilitate downsizing is crucial to tackling the skewed housing market.

Object

Representation ID: 4468

Received: 23/03/2021

Respondent: Ms Julie Townsend

I am opposed to developing green belt land in principle. However, it is worth noting that much green belt land could be made more of, in terms of enhancing biodiversity, landscape, human health and wellbeing. Much of this land is subject to unsustainable farming practices, use of pesticides, and a range of polluting or otherwise detrimental land management practices (such as for hunting purposes). Should this policy go ahead, there is an opportunity and a need to engage with local communities to consider how net gain can be created in terms of sustainability, such as through tackling unsustainable practices on and close to remaining green belt land, enhancing biodiversity, creating wildlife corridors, reducing/preventing traffic within green spaces, increasing tree planting or better enabling natural scrub/tree regeneration. Involving local communities in this process will create added social value. I recommend consulting and involving Yorkshire Rewilding Network and Wildlife Trusts in this.

Object

Representation ID: 4520

Received: 23/03/2021

Respondent: Mrs Jillian Hargrave

Totally object to the use of existing Green Belt land, and do not believe that current circumstances are exceptional.
Existing Green Belt land has already been allocated to keep the character and appearance of our precious villages, and should not be reversed. The destruction of existing Green Belt land will significantly harm the character and appearance of Addingham, both in long distance views from key locations, but also for those accessing the village along Silsden Road, and also those using the Dales High Way route along Moor Lane.

Object

Representation ID: 4666

Received: 23/03/2021

Respondent: Menston Parish Council

Although allocation of Site ME1/H may appear reasonable in a desktop exercise, it lies within in the green belt and consists of a north-facing steep hillside, within 2.5km of the South Pennine Moors, currently being used for sheep farming, overlooking the village and it’s development would overshadow the existing settlements lower down the hillside particularly in Hargrave Crescent and Derry Lane as well as impacting on the SSSI and SPA. It conflicts with Policy SP9 Climate Change, Environmental Sustainability and Resource Use.

Object

Representation ID: 4797

Received: 24/03/2021

Respondent: J A Whitwham

Agent: WBW Surveyors Limited

My Client objects to the omission of Land between Bingley Road & Woodfield Road, Cullingworth (ref CU/008) from the preferred housing site allocations for Cullingworth, to the continued allocation of the land as Green Belt, and to the allocation of site CU/3H for housing development as development on that site would have far more landscape and Green Belt impacts than site CU/008.

Object

Representation ID: 4833

Received: 24/03/2021

Respondent: Mr Ramy Abdalla

Agent: CODA Planning Limited

Policy SP5 of the emerging plan should be amended to include SE/110 as a site to be referenced as follows:
• “SE/110/H – Land at Highfields, Huddersfield Road, Wyke.”

The local planning authority needs to plan for 2,300 dwellings per annum over the plan period of the emerging Local Plan. To do this effectively the local planning authority will need to, and has previously accepted; that substantial Green Belt land will need to be released.

Such exceptional circumstances exist to require Green Belt boundaries to be amended.

The site the subject of these representations is located within Parcel 97 – comprising just 4.8% [0.61 ha] of the total area of Parcel 97 [12.92ha]. However, it is important to re-iterate that any assessment of the appropriateness of Green Belt release should relate only to site SE/110 and not Parcel 97 as a whole.

We have provided an assessment of the site against the 5 green belt purposes. We consider the site to perform only a low function against 3 of the 5 purposes and moderate against the other 2.

The site is of low quality and is very much characterised as “urban fringe”

Object

Representation ID: 4873

Received: 24/03/2021

Respondent: Banks Property

The background text to Policy SP5 confirms that the Council considers exceptional circumstances exist which justify and require a change to the general extent of the Green Belt. There is a significant shortfall in Non-Green Belt employment land availability against need, and no potential land supply of Non-Green Belt large or strategic sites has been identified. Site BU/015 Land off Burley Bypass provides a suitable option for release of Green Belt land for employment in Wharfedale, an area which is constrained by Green Belt and where there are currently no employment allocations. The site is well contained lying between the A65 and River Wharfe, and development would not impact the function of the surrounding Green Belt through unrestricted sprawl, encroachment into open countryside or coalescence. Banks Property has submitted further information on Site BU/015 in response to the Council’s Site Assessment Update Report (Feb 2021).

Object

Representation ID: 4886

Received: 24/03/2021

Respondent: Mrs Hazel Wilmshurst

Para 3.6.15 states that for Employment Land Need and Jobs “This proposal was made before the Covid-19 pandemic.” Consequently no consideration has been made of the reduced demand for office and retail space due to increased working from home and online shopping due to the pandemic. The shortfall of 5,000 units is excessive and the Green Belt land to be built on should therefore be reduced accordingly. As a result the Plan is not in line with the National Planning Policy Framework para 11a which confirms that “plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change;” as with changes in land use resulting from the pandemic. It contravenes paragraphs 3.8.42 and 43 which require Councils to maximise use of previously developed and under-utilised land and buildings, which could be used for housing.

Object

Representation ID: 4900

Received: 25/02/2021

Respondent: Mr Alan Moody

1 Building on Green Belt before all other options have been exhausted is not acceptable or sustainable. If it’s not essential it should not happen

Object

Representation ID: 5082

Received: 24/03/2021

Respondent: Miss Alison Jack

Green Belt should never be used and should be protected. The Green Belt has been reduced in previous years and at some point it has to stop being used otherwise there will be none left. In my opinion, there are no exceptional circumstances that warrant use of Green Belt for housing. Every single bit of brown field should be used. There will be more future brownfield as old factories, mills and disused buildings are identified. There a many buildings that have been abandoned for decades. Why?! The past 12 months has proven that green space is essential to our health, both physically and mentally. Greater Manchester Council has found solutions for housing through using disused buildings and this also stops anti-social behaviour around empty properties.

Object

Representation ID: 5095

Received: 24/03/2021

Respondent: Nufarm UK Ltd

Agent: Quod North

The Green Belt boundary includes an anomalous area of land within the Nufarm UK Ltd works near Wyke. Recomendations:
1. Exclusion of this land from the Green Belt and without any designation or allocation, i.e. ‘white land’, consistent with the rest of the Nufarm UK Ltd works site. This should be reflected on the Policies Map.
2. This should be identified as a proposed change within Policy SP5.
3. Part E of draft Policy SP5, relating to compensatory improvements, should not apply to this Green Belt release.
Please refer to additional submission for further detail.

Object

Representation ID: 5122

Received: 24/03/2021

Respondent: Mr Peter Jenkins

BU1/H - Sun Lane. If this proceeds it will cast doubt on many of the more critical conditions aspired to in this document – green belt last choice for development, required infrastructure, lack of likelihood of flooding etc.

BU2/ H - Scalebor House. Burley has almost reached its original target without this large development on green belt, currently a green corridor along the railway. (Green corridors are extolled in the plan). Why must Burley take the overflow when targets elsewhere are missed?. As per answer to Q3, Bradford has 5000 unoccupied properties, many acres of land said to be 'unviable', as well as brownfield sites.

Repeated mention of green corridors begs the question whether green corridors are to be formed by developing previously undeveloped green land either side of the proposed new corridor, ie. were green before but not corridors as the whole area was green. Confirmation would be welcome.

Object

Representation ID: 5407

Received: 24/03/2021

Respondent: Mr Bernard Poulter

You produced your own evidence to explain EXACTLY why Wharfedale should be left with its original growth figures! let me refresh your memories!

Object

Representation ID: 5424

Received: 24/03/2021

Respondent: Ilkley Town Council

New housing development should be to the highest possible densities (Strategic Policy SP7, “ maximise the efficient use of land by building to highest possible densities, especially near public transport hubs and sustainable transport corridors.”)

If this is done the amount of land taken from the Green Belt for housing throughout the district would significantly decrease.

The draft Local Plan does not demonstrate the ‘exceptional circumstances’ (NPPF, para 137) to justify extensive changes to Green Belt boundaries.

Support

Representation ID: 5425

Received: 24/03/2021

Respondent: Arrowsmith Associates

Our client welcomes sensible adjustments to green belt boundaries where this is necessary, in particularly in relation to site AD7/H - Turner Lane/ Silsden Road, Addingham.

In light of the Council not having allocated enough housing land in the plan to satisfy the Government’s required 35% up lift in urban areas such as Bradford, it may be necessary for further green belt boundary adjustments.

Support

Representation ID: 5486

Received: 24/03/2021

Respondent: Mrs Jane Callaghan

3.5.23 has not considered PDL sites within the greenbelt. Whilst infill sites of 1 or 2 houses may be regarded as windfall, as will those sites which become available during the plan period (when adopted) as per NPPF guidelines, an identified site at Haven Farm, Harecroft which is available and ready (provided that it has no greater impact on the green belt than the current factory building) and which would constitute a major development of more than 10 houses should be allocated against Wilsden's housing needs and not be counted as windfall

Object

Representation ID: 5496

Received: 24/03/2021

Respondent: CPRE West Yorkshire

Para 3.5.27 comments that the government intends the 35% uplift for large urban areas to be targeted at urban centres and regeneration, not at generalized housing supply. This is a logical approach which we would support. However, this must be taken to mean that urban centre areas do in fact contain sites that the council anticipate could be brought forward for development to meet the 35% uplift; and if this is the case then the correct application of the locational policy described in SP4 would prioritise this urban land first. So it is unclear how the proposed scale of Green Belt change is needed to support the proposed housing requirement if a further 35% (10,000 dwellings) could be subsequently found within urban central areas. We infer from this that there are sufficient inner urban sites to accommodate the uplift, but that adding in the uplift would constitute a significant change to the distribution of new development such that a much larger share of the total goes into urban Bradford.

Furthermore, paragraph 3.5.6 states that the assessment of non-Green Belt land capacity takes into consideration density levels compliant with policy H02. However, our own analysis of proposed Green Belt sites indicates net densities averaging around 26 dpha – well below the HO2 minimum of 35 dpha, and even further below the 50 dpha that we consider all site allocations should be required to achieve. There is no sound rationale for releasing Green Belt land if the result will be 5,000 homes developed at non-policy compliant densities.

Since we do not accept that the strategic case for exceptional circumstances to allocate land from the Green Belt has been properly justified, then we must object to all the proposed site allocations listed in the policy.

In relation to sites NE22/E and NE23/E, we would refer you to our response to planning application 19/02504 for the Esholt site which sets out our concerns about the current proposals but recognises the need to re-use the previously developed site.

The alternatives considered at 3.5.30, as with other aspects of the Plan, do not in fact present the consideration of reasonable alternatives. They describe a different approach to how the policy is laid out, in particular by excluding sites from the policy listing, but no alternative approach is offered either for increasing the proportion of new development directed towards urban brownfield sites; or for further increases in residential and employment density as a way to reduce the amount of Green Belt land required.

Object

Representation ID: 5516

Received: 24/03/2021

Respondent: Ms Alison Neave

I understand the need for more housing and particularly affordable housing within Ilkley and don't object to all of this policy or to all of the sites proposed.
I object to site IL3/H Coutances Way becoming housing because:
-it is prone to flooding
- this green belt provides good visual benefit to the majority of people because it is so visible from major roads and the railway
- this land could be improved as green belt - nature, habitat & soaking up rainfall by adding some more plants/shrubs in hedges and a few trees.
I agree there is a need for more car parking near Ben Rhydding station and a small part of IL3/H with a safe entrance off Wheatley Lane with good visibility for cars and people could usefully do this & reduce irritation for local residents because there is no other site for a car park nearby.

Object

Representation ID: 5767

Received: 24/03/2021

Respondent: Mr Nick Jones

The Government’s policy on protection for the Green Belt (Chapter 13 of the National Planning Policy Framework - NPPF), clearly states the importance of Green Belt land and emphasises that when protecting the Green Belt, local authorities should maximise the use of suitable brownfield sites before considering changes to Green Belt boundaries. The NPPF states that there should be “exceptional circumstances” before Green Belt boundaries can be changed and states that inappropriate development is harmful to the Green Belt and should be approved only in “very special circumstances”.
1. BMDC is not maximising the use of brownfield sites & provides insufficient evidence that all options have been explored.
2. BMDC has not provided within their consultation documents sufficient justification which provides “exceptional circumstances” for why these green belt sites should be considered or detailed what the “very special circumstances” are for releasing these sites from Green Belt protection.

Object

Representation ID: 5808

Received: 24/03/2021

Respondent: Mr John McKee

I dont think the argument that there are exceptional circumstance to is well made to develop the Green Belt for housing development. There are plenty of brownfield sites witin Bradford which would suffice. Once destroyed the Green Belt will not be returned. The arguement has the feel of one of convenience rather than substance