Consultation Question 121

Object

Representation ID: 25625

Received: 24/03/2021

Respondent: Matthew and Rachel Twigger

Number of people: 2

No demonstrated need for additional housing, particularly 3/4/5 bed “executive”
No prospect of an increase in job availability in the town which would connote additional need.
It directly contravenes Bradford’s own green belt policies, the loss of these spaces has a “major” impact
The infrastructure, schools, roads, rail, cannot be mitigated for the increasing numbers of
households in Ilkley. When Addingham and Burley numbers are added to the mix, the
situation is even worse.
The Wheatley Grove site covered by WPOs and TPOs.
Construction on the site would mean removing a large section of the WPO boundary.
BMDC’s stringent approach to locally enforcing the WPOs and TPOs is in clear
contradiction of the local plan proposals. BMDC cannot objectively determine significant
valuable amenity value of the woodland character while simultaneously attributing little
significance to the same Green Belt land.
The traffic problems associated with servicing these sites would be severe; the Wheatley
Grove junctions are impossible to improve due to topography.
Significant ecological impact which cannot be mitigated including loss of nationally significant Curlew breeding grounds at Coutances Way and diverse habitat on Wheatley Grove.

Object

Representation ID: 26315

Received: 22/03/2021

Respondent: Mark Lawrence

Pushing more people into Principal towns would not be in the best interests of the residents, nor the localised town economy.

This plan represents a significant external influence on that organic balance, and a threat to the green space which helps to drive the attractiveness of the area in terms of visitation.

Loss of open spaces/vistas.

Increasing residential traffic.

The siting of additional housing may well have a positive effect, when located in areas surrounding "principal District towns", as there exists an opportunity
to boost revenues in other sectors important to the locality.

Bradford Council's parking strategy doesn't work.

There is no guarantee of driving the prosperity of a town's High Street, by putting more people on the periphery of that town, owing to the rise of eCommerce (e.g., Amazon) and the ability to travel to major commercial centres (e.g., Leeds and Harrogate).

The proposed plans will devalue existing properties.

Need for parking, or school places.

This plan is risky and based upon assumptions that amount to a false economy.

Object

Representation ID: 26468

Received: 24/03/2021

Respondent: Barrie & Celia Sinton

IL1/H and IL3/H COMBINED

The impact of nearly 300 new properties in the small suburb of Ben Rhydding would have a major impact on the area and it is essential that if this were to happen then the infrastructure of the area must be upgraded in advance, including schools, medical facilities, retail provision and road improvements, including replacement of the railway arch by a bridge capable of two-way traffic and of a height to accommodate commercial vehicles.

Object

Representation ID: 27463

Received: 24/03/2021

Respondent: Richard & Marilyn Babb

Just to advise that we are completely against the suggested housing on green belt land and Stourton Road in Ilkley.
How can the area cope with so many extra schools places and people commuting to work. There has been so much in filling already.

Object

Representation ID: 27552

Received: 24/03/2021

Respondent: Craig Duerden

I am writing to object against the plans for new houses to be built on green belt land in the Ilkley and Ben Rhydding area.

I live and work in Ilkley and have previously worked in Leeds City centre. The reason for me opposing these plans are firstly the resources in the area, such as roads and highways, trains and transport links, will 100% not be able to cope with the increase in population in the area.

Secondly one of the beautiful aspects of living in this town is it's green fields and countryside. The proposed plan takes us one step closer to becoming another concrete jungle!

Therefore I firmly object these plans.

Object

Representation ID: 27763

Received: 24/03/2021

Respondent: Sally Shelton

The site off Wheatley Grove, will destroy Green Belt land, make drainage issues much worse, as well as destroying places for wildlife, cutting down trees etc.

Both recommended sites for housing in Ben Rhydding will cause massive future traffic problems around the single lane railway bridge at Ben Rhydding Station, and the junction of Valley Drive with Wheatley Lane, along with a new entrance for the new development planned.

Infrastructure cannot cope with an extra 300+ houses. Each house will likely have 2 cars. And 2 children. Schools - Ben Rhydding Primary is a small school with 30 intake. Some Ben Rhydding children have to go to Ashlands instead of their local school, which is not walkable on a daily basis, from Upper Ben Rhydding.

They will all need places at doctors surgeries, dentists, etc..
We need more affordable houses but Ilkley is not the place. House prices in Ilkley are higher than other areas. Building the same number of houses elsewhere will open up more opportunities to people worse off. What will be the selling prices of the properties?

Comment

Representation ID: 28081

Received: 24/03/2021

Respondent: Emma Williams

The allocation of green belt sites when other brown field sites are available is in contravention of national planning policy.
Furthermore, if the Council has undertaken sequential testing correctly, it is wholly inconceivable that the above sites would have been prioritised or even deemed appropriate for residential development on this scale.
Of particular concern, the drainage infrastructure (flooding), impact on green belt environment, highway network (including safety) and schooling provision within Ben Rhydding and Ilkley undermine the allocations.
I request that the Council promote alternative sites that are more sustainable and accord with national planning policy.

Object

Representation ID: 28313

Received: 13/03/2021

Respondent: David Storer

I am strongly opposed to the housing developments on Green Belt land in Wharfedale, particularly those on Wheatley Grove, Ilkley. That piece of land is a valuable local amenity and building housing on it will destroy the quality of life in Ben Rhydding.

The A65 is already clogged to capacity and further housing will increase traffic. Ilkley Grammar school is already over-subscribed and other infrastructure in Ilkley is inadequate.

Council policy is to improve the environment for cycling and walking. All of these developments will do the opposite.

Object

Representation ID: 28381

Received: 25/03/2021

Respondent: David Blackburn

The Plan acknowledges that smaller infill sites will appear but would have expected because of 5.0.1 and 5.0.2 to have seen a commitment to analyse in detail empty/unused space in the town centre identifying potential changes in usage over time, because of the acknowledged geographical and environmental designations around the town.

Object

Representation ID: 28434

Received: 13/03/2021

Respondent: Hilda Bryson

Green belts were specifically designated to prevent development on precious areas of green land.

Given climate change concerns and the fact that we are supposed to be increasing green areas where possible to combat the effect of carbon emissions and to give our threatened wild life some respite from loss of habitat it seems impossible to justify building houses on these sites.

The A65 into Ilkley is a bottle neck already and we now have a garden centre opposite the proposed sites which will increase the flow of traffic and add to the problem of tail backs.

The Grammar School is stretched for space. Are there plans for a new school or for the sewage system and for the health provision? Increased housing with no thought for the infrastructure is negligent to say the least.

Merging Burley and Ilkley into one amorphous mass destroys the community feel of both places.

Object

Representation ID: 28438

Received: 13/03/2021

Respondent: Nadine Wharton

I am very disappointed and shocked at your proposal to build so many new homes in Ilkley

Have you not thought of the already over crowded schools, where is everyone going to park there cars, dentists and doctors are already over crowded.

And worst of all where is the sewage going to go. We need to keep are river Wharfe CLEAN. How can we, if more and more houses are to be built. Just where will it go?

Please consider somewhere else to build houses

Comment

Representation ID: 28485

Received: 24/03/2021

Respondent: Mr Colm McCann

COMMENT
In relation to possible alternative sites for housing I would like to suggest the land between 162 Skipton road and the proposed site at IL2H. This land is above the flood plain and already considered within the town boundaries. Therefore would have a lesser impact on Ilkley's rural character and traffic flows than either of the Ben Rhydding proposals.

Another option within town boundaries could be development of flood resistant housing on the field between the river Wharfe and Langbar Road.

Object

Representation ID: 28496

Received: 25/02/2021

Respondent: Dr Ros Brown

Sustainability Assessment(s) – significant inaccuracies between reports which misrepresent this beautiful and much used site:- E.g. IL1/H Site Proforma and IL/009 in the SA report - not accurately assessed and should b e removed from PO.

-No GB exceptional circumstances
-The level of habitat, landscape character and surface water flood risk/drainage mitigation plus the need for replacement of an area of open space of high visual amenity and biodiversity and tree cover with compensatory Green Belt enhancement and a new area to replace that which would be unnecessarily destroyed in order to achieve a development with limited accessibility to local services and a need to depend on cars begs the question as to why this site has been included.

Inaccuracies and points to address in SA for the site:
7. The negative impact of housing development on the high visual amenity of this area has been underestimated and should be seen as a major negative.

8. Ben Rhydding Drive has listed buildings/ heritage assets.

9 - References ‘new employment premises’ (?) yet 130 residential dwellings proposed with associated air pollution within the SSSI Risk Zone (above)

10 –Ben Rhydding Drive is a private not an access road therefore access required via narrow/poor sight lines Wheatley Grove/Wheatley Lane junction increasing the hazards to this junction (which would need re-modelling). It would also direct more traffic up Wheatley Grove round to the narrow/poor sight lines junction with High Wheatleyand then on to the blind corner junction of High Wheatley/Ben Rhydding Road. This increase in car traffic would endanger walkers and cyclists and therefore not supporting national and local active travel policies. The Wheatley Grove access increases the distance from rail station and no frequent buses this is a major negative with a declining baseline.

11 –Building at 18dpha does not meet the density requirements meaning this development, or one of any increased density does not represent a significant enough contribution to Bradford’s housing numbers and tenure mix to warrant the negative impact of destroying the functionality of this site within a SSSI Impact Risk Zone. This is a major negative.

12 – The distance from accessible services does not support the Local Plans ’15 Minute Neighbourhood approach’

13 – Overstretched infrastructure and services. This is a major negative.

16 – The area is in regular use and benefits local residents - would have a major negative impact on the wellbeing of existing residents and PROW users due to destruction of natural habitats.

17 – Both the local primary and secondary school are beyond the target distances.

19 – The history and scale of the proposed development show construction is likely to be by a larger developer not smaller local builders. The level of disruption and extra construction traffic could also be a negative for local businesses therefore suggesting a positive/negative effect.

Object

Representation ID: 29684

Received: 24/03/2021

Respondent: Redrow Homes

Agent: Johnson Mowat

The site (IL/013) is on the edge of Ben Rhydding suburb of Ilkley, a Principal Town and important urban area of Wharfedale.

The 35% uplift to the housing requirement should apply to Ilkley.

This site lies in a sustainable location, it is available and suitable and is a deliverable site that should be included within the Local Plan.

The site credentials are better than those of site IL3/H to the immediate south, which has been included as a Preferred Allocation. The SLA reason for the rejection of the site is Heritage. Adjoining Site IL/014 (Preferred Allocation IL3/H) receives the same ‘Less than Substantial Harm (Unacceptable)’ across the whole site, yet the site is included as a preferred allocation.

We disagree with the Council’s overall conclusion in the Heritage Impact Assessment which refers to the site not being capable of mitigation to achieve a less harmful impact on heritage significance (for details see document submission).

The Green Belt site specific assessment concludes that Site IL/013 is located in a ‘moderate’ green belt parcel and the site has a ‘moderate’ potential impact on the Green Belt, yet site IL/014, a preferred housing site, has a ‘major’ potential impact on the Green Belt.

The 2013 Bradford Growth Assessment concluded that there may be some potential for Green Belt development to the east and west of Ilkley, where landscaping could contribute to providing a settlement boundary.
The SHLAA3 (July 2015) site summary in relation to the Green Belt stated that:
“Development would probably not be damaging to the openness of the green belt in this location.”

The development of this site provides the opportunity to secure a stronger, defensible boundary, to the settlement.

There is logic in extending the size of Preferred Site IL3/H to the immediate south of IL/013, to incorporate IL/013 and deliver the sites together comprehensively. This will allow more scope via design, to address the heritage constraints associated with the setting of Wheatley Grange, as well as provide an opportunity for creating a scheme to form an important gateway development, when entering into Ilkley from the east.

Comment

Representation ID: 29774

Received: 25/03/2021

Respondent: Ilkley Town Council

If Ilkley is to be a well-balanced town in population terms it needs more housing suitable for young families, single people, people with special needs, etc.

Ilkley is a town with a high proportion of large and expensive housing, whereas a large proportion of the paid employment is in the low paid sector (retail, hospitality, care work). The housing need therefore is for modestly priced accommodation, not ‘executive homes’.

Object

Representation ID: 29775

Received: 25/03/2021

Respondent: Ilkley Town Council

In the Local Plan, Bradford specifies two projected housing densities. For sites near main transport hubs, 50 dwellings per hectare and for other sites 35 dwellings per hectare.

The housing densities proposed for the sites identified by Bradford, in the Local Plan are very low indeed and much lower than those proposed by Bradford in the Plan.

By way of illustration Ilkley is planned to have 314 dwellings on the four sites.

For example
Only IL4/H approaches 50 dwellings per hectare (at that density it could take 11 dwellings rather than the 9 planned)

IL2/H, 1.18ha is planned to take 20 dwellings. At 50 per hectare it could take 59

IL1/H 7.18ha is planned to take 130, at an astonishingly low density of 18 dwellings per hectare. At 50 per ha it could take 359

IL3/H, 7.41ha is planned to take 155 dwellings (21 per hectare) whereas it could take 370. N.B. this number comes down to 350 if 0.4ha is allocated to a park and ride carpark

Given that three of these sites are on green belt, it seems impossible to justify building at a rate as low as between 18 and 21 dwellings per ha. These densities can only imply the building of large detached houses.

Comment

Representation ID: 29777

Received: 25/03/2021

Respondent: Ilkley Town Council

The sites identified by Bradford, with two exceptions, do not seem unreasonable.

The one wholly objectionable site is IL1/H (Wheatley Grove). Site IL4/H (Stockeld Road) is also of concern as it is within the Ilkley Conservation Area and Flood Zone 2.

The only areas left are then site IL/3H, Coutances Way and IL2/H, Skipton Road east which are both in Green Belt and would need exceptional circumstances to be proved for their release.

In addition

1. Development should be at, at least 50 dwellings per ha.

2. There should be a mix of housing types and tenures (including social housing).

3. Included in the design should be green play areas, trees (and if possible allotments) etc.

3. To be in conformity with Bradford’s zero carbon policy, the dwellings must be built to the highest insulation standards with electric car charging points etc. The danger of flooding must be mitigated by the use of permeable surfaces wherever possible, rain water collection from houses, etc.

4. The site should be screened from the A65 by the planting of a shelter belt of substantial native trees (oak, ash etc.)

5. The wetland area below the site should be converted into a wetland nature reserve. This would complement the Ben Rhydding Nature Reserve on the opposite side of the A65.

Comment

Representation ID: 29781

Received: 25/03/2021

Respondent: Ilkley Town Council

All site development proposals should be scrutinised for their internal adherence to INDP policies and BMDC Local Plan policies for traffic, transport, sustainability, walking and cycling. This includes such issues as parking, charging for electric vehicles, designs to promote biodiversity and other matters, within specific sites.

Object

Representation ID: 29789

Received: 23/03/2021

Respondent: Ilkley Civic Society

POLICY CONFLICT
Concerning the sites selected for development in Ilkley there is a direct conflict with the policies, for example:-
protecting the green belt
minimising travel to work
providing adequate infrastructure
creating the South Pennines Regional Park
maximising the benefit of YWCA funds to support brownfield development
all of the changes arising from the Leeds City Region and Transport for the North.

No account has been paid to the Planning White Paper which specifically protects green belt and conservation areas.

Comment

Representation ID: 29792

Received: 23/03/2021

Respondent: Ilkley Civic Society

ALTERNATIVE GREEN BELT SITES.

It is not possible to indicate alternative green belt sites to protect Ilkley from over development. The town sits close to the North Yorkshire boundary wherein lies the Nidderdale AONB. To the South is Ilkley Moor, already an SPA and SSSI. Further northwest, but within sight of Ilkley, is the Yorkshire Dales National Park. There is no undesignated greenfield land which could be designated green belt to provide adequate extra protection to Ilkley.

Object

Representation ID: 29984

Received: 24/03/2021

Respondent: Ilkley Town Council

In SP5 you state that the Government attaches great importance to the Green Belt areas and yet you are proposing to build over 285 houses on the Green belt in Ilkley.

It seems to me that there has not been enough planning to identify the future needs of Ilkley. We do need some new houses in Ilkley , but these should not be built on any land that is available for building. It seems that not enough thought has gone into proposing the number of houses required.

Object

Representation ID: 30025

Received: 14/03/2021

Respondent: Mrs Judy Hutton

1. I am against development in Green Belt. My own property is within the green belt and I adhered to strict rules when applying for planning permission.
2. The Bradford district has 6,142 empty properties in the district. The Council should use its powers to encourage owners to dispose of their assets or rent out.
3. Of these 6,142 empty properties, 186 are in Ilkley. Comment above applies.
4. Houses planned for Ilkley and Addingham are unlikely to be affordable to the people who are really looking to get on the property ladder.

Comment

Representation ID: 30107

Received: 10/03/2021

Respondent: SDS Land Ltd

submit evidence in terms of the specific site IL/012 and request a modification to the Boundary, revision IL/012B, which yields benefits for Green Infrastructure, PROW linking the Dales Way with the high level Millennium Way and a stronger permanent Green Belt external Boundary. (see attached submission)

Object

Representation ID: 30131

Received: 24/03/2021

Respondent: Clive Brook Planning

Rejected Site IL/016.

Comprehensive proposals including a masterplan and other information has been prepared for the site as well as sites IL/011A, IL/011B & IL/032, as part of earlier consultations and discussions.

Concerned that there are a number of substantial mis-appraisals in the supported evidence, and that site has been treated as part of wider comprehensive approach. No logical reason for disaggregated approach.

Considered that the site (as part of comprehensive masterplan area) is connected with urban area.

Development could be achieved withouth significant impact on the functions of the Green Belt.

Proposals will create sustainable mixed use development, meeting all three sustainability objectives in the NPPF. No sites within the urban area are capable of delivering these benefits. The scale of the landholding enables the delivery of beneficial environmental enhancements.

Major positive opportunity to deliver market and affordable housing, meeting social objectives. Site can deliver integrated environmental benefits and recreation provision for the benefit of the community.

Request that the Council review their decision to exclude this site.

Comment

Representation ID: 30361

Received: 24/03/2021

Respondent: Mr Alastair Sim

Agent: Clive Brook Planning

The proposals for my client’s large landholdings at Ben Rhydding to the east of Ilkley are much more extensive than those contained in the SHLAA ref site IL/020B.

This response is made on the totality of the landholdings contained in our outline master plan for our mixed land use environmental proposals with potential discrete areas of enabling residential development at three sites:- A. A much reduced development on part of SHLAA site IL/020B; B Proposed redevelopment of redundant farm buildings at Newstead and C -a small development at Saxon Lodge fronting onto the A65.

The proposals for IL/020B have been much reduced from circa 75-100 dwellings to circa 30 dwellings. Each of the proposed enabling dwelling sites needs to be considered separately given the different locations and scales of the potential development. These revised proposals now major on the provision of substantial areas for habitat creation and enhancement, new recreation space and associated green infrastructure and landscaping. My client has already demonstrated his strong environmental intent by planting in excess of 7,000 trees on the main northern land parcel. The whole concept proposals are in the form of a future managed country park. These proposals can provide habitat and recreation provision for developments in the wider locality which are not able to accommodate the necessary provisions on their own land.

The March 2020 promotion document and master plan presents the planning and environmental proposals for what we consider could constitute the eastern ‘bookend’ country park conceived as part of the landscape and greenspace strategy contained in the Ilkley Area Plan document. The eastern and western country parks proposed and being promoted by my clients can be linked into the greenspace, ecological and landscape corridors running alongside the River Wharfe and through the town of Ilkley. The current land ownership extends to some 60.7 hectares (150 acres). The largest of the two main parcels lies to the immediate north /north east of Ben Rhydding Drive and the smaller southern parcel is located just to the north of the Moor Road.

We request that each of the three enabling development sites is considered separately as well as cumulatively. If the Council still conclude that IL/020B should not be allocated we request their stated support and positive planning approach towards the development proposals at Newstead and Saxon Lodge. The Newstead replacement housing development could proceed within the retained Green Belt on the basis that there will be enhancements to the openness of the Green Belt.