Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18130
Received: 22/03/2021
Respondent: Karen Gardner
No rationale for the use of Green Belt land, given the large number of available brownfield sites in the district. Distances between settlements will be eroded.
Will impact on town’s unique character particularly its entrance as well as traffic and parking – making this worse, impacting on quality of life.
Flooding is a recurring issue along the Wharfe Valley. Development will increase run-off, leading to more flooding. All sites classed as having a flood risk of 2/3.
Will have numerous environmental impacts – on wildlife (including curlew feeding), proximity to the Moor (a SSSI), loss of open space, numerous TPO designated trees on site – reducing the developable area.
Sewage systems at capacity.
Schools are at capacity especially Ilkley Grammar School. No sensible alternatives available and few options for expansion. Ben Rhydding primary is unlikely to be able absorb increased demand for places. Also no scope for expansion. No solution in the Plan. Need to consider the wider catchment as well.
Area is already congested whilst increased traffic will impact on road safety. Parking is also an issue, whilst development elsewhere will add to traffic in the area.
Plan does not consider ongoing infill development (c. 30 homes p.a.)
Congestion on A65 corridor is a problem - has got worse with increased housing building along it with no improvements. Rail network is at capacity. Proposed development will make congestion worse. Cannot consider proposed Ilkley development in isolation.
No evidence that disadvantages above will be compensated by any improvement in housing affordability.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18218
Received: 22/03/2021
Respondent: Lynda & Andrew Raddings
Number of people: 2
•Ben Rhydding Drive is unadopted and not maintained by the council. Increasing its use is not sensible.
•The site is Green Belt and is supposed to be protected by the NPPF with Brownfield sites being use before green belt. There are many Brownfield sites in Bradford.
•The site is adjacent to an urban common, SSSI, SPA.
•Heather moorland is a rare habitat supporting a range of wildlife.
•Site Specific Green Belt Assessment indicates that development would have a major impact on purpose 3.
•The SA concludes there will be a major adverse effect on land/buildings due to the loss of greenfield land.
•Schools will be negatively affected. Schools generate more journeys than anything else.
•Provision of new employment is questioned – most new residents would have to travel to most forms of work.
•Major adverse effect on biodiversity/geodiversity. Within the 2.5km HRA zone, borders priority habitat, contains a copse and ancient trees, bird species.
•Area has been used by walkers in lockdown. Plan has not allowed for Brexit or the pandemic to be taken into account in terms of need for housing and working from home arrangements.
•Contradiction of proposals with the Ilkley Neighbourhood Plan’s principles.
•Increase in dwellings will see an increase in vehicles exacerbating the existing problems of pedestrian access in this area. Issues with the single file railway bridge and access along the Drive.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18257
Received: 24/03/2021
Respondent: Hannah Walton
I would like to add my objections to the current proposed home building strategy in Ilkley.
I am very concerned that local infrastructure is not sufficient to deal with the proposed additional number of people. Ilkley Grammar school has already expanded recently and I understand that it is now operating at capacity and how will the additional need for health services be met?
There will be a significant increase in heavy traffic along the A65 and along Wheatley Road train bridge and junction with Valley Road - already subject to congestion.
97% of the proposed homes will be built on green belt land. Whilst I accept there is a need for more affordable housing, the destruction of green belt land should come when there are no other options available. What is the justification for choosing green belt land over other available areas?
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18271
Received: 24/03/2021
Respondent: Mr David Hughes
This huge development would severely compromise the nature of Ilkley as being (to use the council’s own wording) “set within a scenic and sensitive natural landscape”; it would be likely to lead to future requests to extend the planned built up area further westwards and down around Wheatley Grange to the boundary of the A65. There would also be significant additional problems for traffic passing through the new traffic light controlled system at the railway bridge, causing back-ups into Ben Rhydding and down to the A65 junction.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18289
Received: 24/03/2021
Respondent: Tim Ashelford
Will significantly erode the Ilkley green belt, leading to a corridor of development between Ilkley and Burley. This is especially important given the recent approval of a 500 houses to be built at Sun Lane Burley.
Given the number of brownfield sites available in the Bradford district, building on the green belt can not be justified.
The proposals would significantly change the character of Ilkley and the surrounding areas.
Impact on Ilkley’s character is defined by it’s natural setting amongst the countryside.
Ilkley Moor is part of the South Pennine Moors SSSI
Both sites are in the SSSI Risk buffer zone for the SSSI.
Coutances Way is a nationally significant area for curlew.
Ilkley Grammar is already operating at capacity. It is unable to expand any further.
Road Safety – The two main sites in Ben Rhydding will directly and significantly increase traffic through the Wheatley Road train bridge and the junction with valley drive. These are two areas of congestion are already at high risk of accidents.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18339
Received: 22/03/2021
Respondent: Mrs Elaine Thornton
•Rail and road infrastructure are already inadequate. Commuter train are overcrowded and commuting by car takes a disproportionate amount of time – with congestion on the A65.
•There is a need for a bypass but the funding keeping being withdrawn. One of the housing sites sits within the proposed bypass routes and would put a stop to those plans.
•Schools are already oversubscribed.
•Developments at Ben Rhydding and Burley-in-Wharfedale will erode the green belt which separates them, with the Wharfedale valley becoming one massive conurbation – changing the nature and character of the area.
•The Green Belt should be preserved for future generations to enhance Ilkley and the Wharfe valley.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18486
Received: 23/03/2021
Respondent: Nick Thompson
The building of new homes within the greenbelt area should not be allowed to go ahead.
Ilkley has a sensitive natural landscape - the surrounding areas within and bordering the greenbelt have become even more important to the wildlife seeking sanctuary.
Adding so many new houses, taking up the greenbelt area, would significantly detract from the character and 'feel' of the town, decreasing its attractiveness and popularity with visitors.
Concerns about the increase in traffic on the many narrow roads and know full well that the school capacity both in primary and secondary schools in the area is already extremely limited.
Having over 300 new homes will bring approximately 1200 new people living in the town; over 600 additional cars and 600 additional pupils to the schools; all putting additional strain on the environment, infrastructure and increasing traffic.
Increasing building in these areas risks further flooding problems with water catchment.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18494
Received: 22/03/2021
Respondent: Andy Stuart
•Report states that there is a major impact of the Green Belt. In the climate emergency the Green Belt should be protected not developed. Proposals go against government/council policy.
•No evidence that flood risk has been properly analysed. Water flows off the moor and down Wheatley Lane flooding front gardens. Proposals will increase flood risk of the properties lower down Wheatley Lane.
•Regular flooding occurs on/around Coutances Way. The A65 has been closed due to flooding. Trees should be planted to provide ground stability and absorb carbon/water.
•No mention of the risk to the stability of the railway line.
•Proposals go against the local plan to protect Ilkley’s environment.
•Wheatley Grove site falls within the buffer zone for the moor (SSSI). Development should be avoided.
•Sites will have a major impact on an already busy road network, adversely affecting the safety of existing and proposed residents and air quality.
•Use of the site for park and ride is not required. The pandemic has change the way people work and reduced rail journeys.
•Ilkley Grammar is at capacity and unable to expand further, already limiting the catchment area to manage numbers.
•No additional secondary school capacity proposed.
•Sewage sites at capacity and regularly overflow their storm-surge capacity, polluting the Wharfe.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18551
Received: 23/03/2021
Respondent: William & Noemy Ellis Martin
Number of people: 2
Environment impact: These are green-belt sites - development would severely detract from the environment around Ilkley.
IL3/H will severely detract from the aesthetic around the regionally important Cow and Calf rocks and Ilkley Moor.
Building plans should make use of post-industrial sites in the first instance.
The character of Ilkley is that of a small town in the countryside - it is one of the jewels of West Yorkshire, enjoyed not just by its residents but by lots of tourists
Pressure on sewage works
Pressure on secondary schools and medical practices: Ilkley Grammar School is already bursting at the seams.
IL1/H and IL3/H will lead to increased numbers of cars on the road - they're not within walking distance of the town centre.
Pressure on the junction at the end of valley drive will increase - this is a dangerous junction already.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18708
Received: 23/03/2021
Respondent: Rachel Ashelford
97% of the proposed housing allocation within Ilkley is in the green belt - disproportionate as district wide the figure is 20%. The Council has not demonstrated the exceptional circumstances required.
There are brownfield sites within the Bradford district which could be developed.
The proposals would significantly change the character of Ben Rhydding.
Increased surface run off and the risk of flooding - no account taken of climate change which is likely to increase these risks.
S Pennine Moors SPS - Fields within IL3/H are regularly used as a foraging area by Curlew, a red list, IUCN Near Threatened species. Development of this site will both directly remove this habitat and increase disturbance.
No additional school capacity is proposed to accommodate the cumulative developments in Ilkley, Addingham, Burley and the old hospital site (North Yorkshire).
Increase traffic through the Wheatley Lane railway bridge and at the junction with Valley Drive.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18711
Received: 18/03/2021
Respondent: Mr John Saltmarshe
Inadequate infrastructure
- Ilkley grammar school is already oversubscribed
- the local sewage treatment plant is already unable to cope in conditions of heavy rain,
- several of the roads are already at capacity.
There are alternative brownfield sites available in Bradford which should be prioritsed over Green Belt in the Wharfe Valley.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18742
Received: 23/03/2021
Respondent: Helen Friedrichsen
•This is green belt land and development of this site and at Burley-in-Wharfedale will significantly impinge on the space between the two villages. The space adds to the aesthetic appeal of Ilkley and surrounding hamlets, contribute to the sense of wellbeing and is used by walkers.
•The houses will be unaffordable for families.
•Already pressure on schools, GPs and amenities (parking/train capacity).
•Council will not secure developer contributions for local services as developers evade these.
•Development should be in areas that need regenerating – Ilkley is not one of these.
•Developers are looking for a quick return and do not add anything to the local area but detract from it.
•The more green belt that is built on the more this will undermine the returns to the Council from businesses/tourists from people who want to come to this historic town.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18761
Received: 23/03/2021
Respondent: Matthew, Jonathan & Robert Brooksbank
Number of people: 3
Site IL/3H Coutance Way.
1. This site appears to significantly reduce the gap between Ilkley and Burley in Wharfedale and protrudes into the valley in an easterly direction.
2. The site does not have defensible boundaries and is overlooked by quite a number of existing properties.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18763
Received: 23/03/2021
Respondent: Josephine Wallace
Both areas are within the Green belt and would result in the loss of beautiful outside space that is within a few hundred metres of an area of outstanding natural beauty.
Lack of sufficient infrastructure in the area, specifically schools. The local Primary school in Ben Rhydding is single class entry and does not have the space for any expansion. Ilkley Grammar School is already at its capacity and has already expanded to its maximum.
My major concern however is with the road access to these two proposed sites, especially IL3/H, the junction on Coutances way is often extremely busy with regular ques at the traffic lights to leave Ben Rhydding, the addition of over 300 cars in the local area would make the situation worse. The Toll bridge to Denton / Askwith is unable to take any additional traffic with regular traffic jams building there at peak times and a number of accidents have occurred.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18765
Received: 23/03/2021
Respondent: Stuart Moore
All brown field sites throughout the district should be developed ahead of any green belt area.
Close proximity to Ilkley moor / in the buffer zone of the area classified as being of special scientific interest.
Burley-in-Wharfedale/Ilkley/Addingham in danger of being extended so close together that their identities are at risk of being lost.
Schools are already maximum capacity
Both Wheatley Grove and Ben Rhydding Drive the two roads lying either side of the development are unsuitable for at least an additional 500 (minimum) vehicle movements per day.
Drainage and waste water treatment is already at capacity.
Ilkley already has a steady annual increase in new development homes which should be taken into account
Bradford council should utilise the empty properties currently available throughout the district circa 4000.
Make use of unwanted office space before green belt - more people now working from home.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18769
Received: 23/03/2021
Respondent: Matthew Archer
I object for the following reasons:
1) Loss of green belt / plenty of brownfield sites and empty buildings in Bradford. Ratings for these sites are moderate or major impact.
2) Loss of Ilkley's historic character, impact on parking which is already a problem and reduced tourism;
3) Flooding - these proposals will increase flooding;
4) Impact on the environment - Ilkley Moor SSSI and buffer zone, impact on wildlife, curlews etc, loss of mature trees, increased problems with sewerage capacity.
5) School capacity - Ilkley Grammar school already full. No additional places have been provided despite planning approvals here and neighbouring villages;
6) Road safety - The additional traffic will increase those using the Wheatley Lane railway bridge, it is already busy, it will increase traffic along Bolling Road -which situates a primary school. The junction to Valley Drive is awful whether you are a pedestrian, or driver.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18774
Received: 23/03/2021
Respondent: Jenna Holmes
I’m writing to include my objections to the building proposals for the above sites.
Of particular concern are the proposals for IL3/H and IL1/H. These will have significant impact on green belt and the rural character of Ben Rhydding and would infringe onto the buffer zone for Ilkley moor, changing this landscape forever. It has not been made clear why these sites have been selected over many other brownfield options. I am also concerned about the additional impact that building in these areas would have on wider infrastructure in the town (schools, services).
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18778
Received: 23/03/2021
Respondent: Claire Emmott
• Impact on local schools, NHS and traffic, and the increased risk of road accidents and potential fatalities.
• No traffic assessment has been carried out.
• Impact from the building phase of danger from lorries and other heavy vehicles.
• Pollution from increased traffic
• Ilkley already lacks sewage processing capacity. Given the new protected ‘beach’ status of the Wharfe at Ilkley, it is hard to legally reconcile this extent of further development.
• Several of the sites appear to be in flood risk areas. As flooding is only going to worsen, this appears problematic.
• The two main development sites – making up 97% of the proposed homes – are on green belt land.
• The Countances Way site in particular, if developed, would further disintegrate the space between Ilkley and Burley and lead to a built-up corridor;
• Loss of Ilkley's historic character – impact on tourism
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18784
Received: 23/03/2021
Respondent: Melanie Scott
Greenbelt land - there appears to be no evidence of exceptional circumstances to justify these two sites.
Development at both sites will serve to increase ‘unrestricted sprawl of large built up areas’ as well as continue the gradual increase of ribbon development between Ilkley and neighbouring villages.
Flooding - Both these proposed sites have a history of flooding/excess water.
School/infrastructure capacity - Both Ilkley Grammar School and all local primary schools are full.
Other amenities (e.g. doctors surgeries, Post Office etc) do not have the capacity to cope with the increase in population.
Destruction of environment - Ilkley Moor SSSI / mature trees.
In summary, there is no justification for these plans. Ilkley’s housing has been growing at approx 30 houses per year for the past few years. This incremental growth is sufficient for a town the size of Ilkley, without additional green belt land being taken or destroying the character and beauty of the town.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18862
Received: 23/03/2021
Respondent: Nicola Thompson
The building of new homes within the greenbelt area should not be allowed to go ahead.
Ilkley has a sensitive natural landscape important to the wildlife seeking sanctuary.
This scenic area attracts visitors from all over the UK. Adding so many new houses, taking up the greenbelt area, would significantly detract from the character and 'feel' of the town, and would be damaging for the local hospitality, bars, restaurants and pubs that enjoy such good trade.
I have significant concerns about the increase in traffic on the many narrow roads.
School capacity both in primary and secondary schools in the area is already extremely limited.
Over the last few years, the incident and severity of significant flooding to most of the proposed areas for building has been very evident. Increasing building in these areas risks further problems and flooding of homes.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18865
Received: 23/03/2021
Respondent: Tim Stevenson
97% of the proposal in Ilkley is on green belt land.
The two sites contribute to all 5 green belt purposes particularly the merging of neighboring towns. With the permission at Burley added the current gap between the settlements of 2km would be reduced to 750M.
A significant number of developments have been completed in the last few years in Ilkley, and these have not been considered when considering what number of houses to propose. What the council have not been able to demonstrate is that other brownfield sites, outside of Ilkley, have been selected.
The council's own review stated that these proposals would have either a moderate or major impact on the green belt.
Impact on wildlife / Ilkley Moor / TPO woodlands
Ilkley Grammar School is already operating at capacity and has expanded to it's possible limit
Increased flood risk and road safety concerns.
Impact on the scenic beauty of Ben Rhydding
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18867
Received: 23/03/2021
Respondent: Lucinda Warnes
• This is green belt land protecting Ilkley from sprawling and merging into Burley and defining Ilkley as a beautiful town.
• The quantity of houses proposed is not in keeping with the surrounding area. The density would put increased strain on the infrastructure of Ilkley incl sewerage works and schools.
• Jeopardises soak up land - increasing flooding potential.
• Increases traffic to Wheatley Road - every week night many families attend the scout hut below the bridge crossing an already busy and dangerous road.
• Loss of green areas - the public footpath running through the proposed site offers a rural breathing space to residents.
• Ilkley has had many residencies built in recent years ‘doing their bit’ for the district including social housing resulting in anti social behaviour in Ben Rhydding.
• Many brown field sites exist across Bradford Council. Ilkley has seen minimal investment from the council over the last decade.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18897
Received: 23/03/2021
Respondent: Richard Jones
Visual impact - an important green belt site that is at the gateway into Ilkley and the Yorkshire Dales.
Character of the neighbourhood - Part of the character of the town is linked with the beauty and aesthetics of the area. Development would adversely affected the character of the town.
Possible noise and disturbance - There are already significant traffic issues in the area.
Adverse affects on the residential amenities of neighbouring owners - development would adversely affect the existing views of some of the neighbouring properties.
Urban sprawl - detrimental to the identity of Ilkley as it would become merged with Burley and other neighbouring areas, creating one big ‘concrete jungle’
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18906
Received: 23/03/2021
Respondent: Mrs Zoe Whittaker
The plans would ruin Ilkley and its beautiful surroundings and force current residents who have worked hard to live in such an area to move out. It would put pressure on local schools and services.
Having spent 40 minutes on your planning website I could not figure out how to register my views - I imagine you have made this so incredibly difficult to navigate that you hope people give up! I will not be deterred by your complicated and impossible website.
We contribute a huge amount of council tax to Bradford City Council but are so often ignored. It’s obvious this ‘affluent’ area supports other ‘less affluent’ areas under the Bradford umbrella, it’s about time our voices were heard. We are not communists, we don’t all have the same things in life sadly.
Why not regenerate areas elsewhere rather than build on green belt.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18912
Received: 23/03/2021
Respondent: Jill Ferguson
I object to the proposals to build an excessive number of houses in this area on unsuitable sites. The 314 houses, 97% on green belt land, would have too great a detrimental impact on many aspects of life.
No justification for building on important green belt, when there is plenty of brown belt land available across the district.
My main concerns are around traffic, drainage and flooding issues and school places. We have one secondary school here in Ilkley that also serves Addingham and Burley (where excessive insensitive developments are also proposed) and that school is at full capacity with no room for expansion
For users of the roads and pavements in Ben Rhydding, between the two largest proposed development sites IL1/H and IL3/H, it is obvious there would be issues of congestion for traffic and safety for pedestrians and cyclists.
The two large sites at Ben Rhydding are both regularly saturated and as such are important natural drains for rain water.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 18958
Received: 23/03/2021
Respondent: Alison Hartley
The site is on green belt land. This should absolutely NOT be built on.
It be would spoil the character of the area, Ilkley and Ben Rhydding are part of a small town, not an urban sprawl.
There is not the infrastructure to support these 2 large housing projects, particularly in terms of local first and second schools.
There is also not the need. There are plenty of vacant spaces and properties within city areas that can be developed without spoiling this lovely town.
Ilkley already has enough problems with anti social behaviour in the summer months without increasing it's population significantly.
Both of the sites are too large for this small town and I am strongly opposed to them.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 19181
Received: 23/03/2021
Respondent: Oliver Wilson
These proposals are inappropriate for the character of the area, ill-conceived for their irreversible effects on the local environment including flood risk and the destruction of green belt land and are presented without any contingency or mitigation for already stretched local transport infrastructure and schooling.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 19185
Received: 23/03/2021
Respondent: Tom Chappell
Green belt - in combination with the Sun Lane Burley approval, these developments in Ben Rhydding edge the two settlements ever closer together. I understand there are many brownfield sites in the Bradford Local Authority area which have not been earmarked in the plans
The sites in question contribute significantly to the character of Ben Rhydding.
This valley struggles every year with flooding. The amount of water that comes off the moor with even moderate rain fall frequently leads to sewage overflowing into the River Wharf – something recently well publicised by the Ilkley Clean River Campaign. It’s clear that the current infrastructure is just not up to the job, even before you add 300 plus houses.
A transport assessment is not due to be completed until after this consultation has closed. How is this not considered a vital part of the information that is shared with stakeholders for this consultation. I fear this indicates a disregard for local impact.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 19218
Received: 23/03/2021
Respondent: Lucy Whittaker
This will put a tremendous amount of strain on;
Our Green Belt site. Awarded Green Belt for a reason, this must be protected at all costs.
Some of these plans are on flood lines ranging from 1-3. This is ridiculous and not sustainable long term, especially with climate change and the effects it has had on our weather even over the last 15 years!
Increased pollution and strain on current roads and side streets surrounding the proposed sites.
Parking is already an issue in and around ilkley.
Facilities such as schools, doctors and dentists. All the above as under pressure to maintain the current amount of residents, adding to this could be a fatal mistake.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 19246
Received: 23/03/2021
Respondent: Sandy MacPherson
The Council has more than a planning interest in this land as owner of the land.
Little has changed from the Inspector's decision into the UDP adopted in 1998 - "I do not find the circumstances justify the deletion of the land from the Green Belt and its allocation for housing purposes"
Also runs contrary to the views expressed by the Secretary of state in multiple occasions 1985, 1988, 1998 and 1972.
Contradicts the long term plan for a park and ride site in this area
Conflicts with governments revised PPF on green belt policy, sustainable development and conservation and enhancement pf the natural environment.
The site does meet the housing needs of those covered by pars 59, 61. 68 and 70
Would result in urban sprawl and the loss of the best and most versatile farmland.