Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

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.

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.

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: 29793

Received: 23/03/2021

Respondent: Ilkley Civic Society

Previously Developed Land

The NPPF para 138 strongly favours the use of brownfield sites over green field and green belt despoilation. Bradford Council area is substantially endowed with brown field sites, many of which are easily accessible to the city centre. The council wants to develop the city centre as part of urban regeneration. Some brownfield sites are urban waste and leaving them in that state detracts from Bradford ever becoming a commercially thriving city. Using Wharfedale green belt sites for housing in no way supports the city centre. It merely provides costly overspill housing for Leeds.

The allocation of green belt sites for housing in preference to the allocation of brown field sites contradicts the NPPF and Bradford’s own strategies for economic regeneration.

WYCA FUNDING
WYCA has recently announced funding of £167m to BMDC to support Brownfield development. While this initiative is welcome, it also reinforces the need to develop brownfield sites first. Making green belt available for housing development undermines this funding.

Object

Representation ID: 29794

Received: 23/03/2021

Respondent: Ilkley Civic Society

Components of Supply - Windfall

In Ilkley, approximately 25 dwellings per year are generated from windfall sites. These are as a result of using gardens, domestic demolition and re development. With the post-Covid changes to the High Street expected to have some impact another series of dwellings may be achieved via permitted development rights. These should all be taken into account.

SITES NOT YET AVAILABLE
When the plan lifespan was extended to 2038, consideration should have been given to sites which by that time may become available, for example, the sewage works in Ilkley.

Additional windfall sites are likely to arise from shop and office conversions to residential, which may be covered by permitted development rights. We are beginning to see commercial to residential conversions in central Ilkley as a result of the pandemic and business closures.

Comment

Representation ID: 29795

Received: 23/03/2021

Respondent: Ilkley Civic Society

CREATION OF THE SOUTH PENNINES REGIONAL PARK
This proposed regional park with near National Park status would link the Peak District and the Yorkshire Dales National Park and the Nidderdale AONB, providing protection for the West Yorkshire Green Belt area of Wharfedale. It should be a key element of the plan for Wharfedale.

Object

Representation ID: 29796

Received: 23/03/2021

Respondent: Ilkley Civic Society

THE IMPACT OF THE SUN LANE DECISION
The controversial decision to develop 500 houses at Sun Lane, Burley in Wharfedale, depleting the green belt, should be taken into account in any decision to develop any further green belt land between Burley and Ben Rhydding. There are impacts for the landscape, secondary school places, drainage, road use and public transport and infrastructure.

Object

Representation ID: 29798

Received: 23/03/2021

Respondent: Ilkley Civic Society

INFRASTRUCTURE (summarised)
•Few additional jobs planned for Ilkley. New residents will have to travel for employment. The A65 is already at capacity. Trains have been at capacity prior to the pandemic. Longer trains and infrastructure improvements will be required as passenger demand develops.
•Housing should be built close to employment to reduce commuting. To afford an average-priced house in Ilkley requires substantial savings/equity/ability to pay a mortgage. Many people will have to commute to a job that pays well enough.
•Most schools are at capacity. Those people with more than one child often have to go different schools. This is the largest cause of congestion at school time –with people who have no choice but to use a car to get their children to school on time.
•Ilkley Grammar is the only state secondary in the valley between Addingham and Menston. Recent rebuilding of the school has maximised its capacity.
•Provision should be made for a new school site for all the additional children from the proposed 1306 houses in Wharfedale. This could be in the Burley/Menston area.
•Health services are already under severe pressure.
•Existing issues of raw sewerage entering the River Wharfe from the Ilkley treatment centre in wet weather when storm drains area at full capacity. Activity which exacerbates this situation should be avoided.
•Sewerage system needs increased capacity and better processing arrangements before additional homes are built.
•A65 is the only through road in this part of Wharfedale. Increases in population will increase road traffic. Car journeys will be necessary for employment/shopping/schools/health/leisure. People are unlikely to cycle on main roads in winter. If the Greenway cycle route is not the most direct, people are unlikely to use if for daily journeys.
•Wheatley Lane under the railway bridge is a bottleneck. IL1/H&IL3/H will cause substantial increases in traffic which is undesirable. The installation of traffic signals has increased the speed of traffic raising the risk to children crossing.
•There needs to be planned improvements to public transport. More ‘through’ trains to beyond Leeds/Bradford. The new plans for Bradford Interchange do not improve connections for rail users of Forster Square station.
•The trams proposal does not come near to Ilkley.
•Bus services need redesigning to give people direct access to the suburbs of Leeds/Bradford for work/study/leisure without having to change in the city centre.
•People from Ilkley need direct services to Bradford, Airedale Hospital, St James’ Hospital Leeds, BRI, Trinity and All Saints University, Leeds Beckett University.

Object

Representation ID: 29799

Received: 23/03/2021

Respondent: Ilkley Civic Society

This is an attractive green belt site supporting the rural aspect of Ben Rhydding Drive.

The site access is to be via Wheatley Grove and not via the private road Ben Rhydding Drive. There is a difficult junction to access Wheatley Grove from Wheatley Lane. The junction of Wheatley Lane and Bolling Road is problematic and there is single line working at the railway bridge. There is no pedestrian crossing of either Wheatley Lane or Bolling Road. Below the railway bridge there is another poor junction with Valley Drive where traffic exiting Valley Drive has poor sight lines.

From Wheatley Lane, Wheatley Grove proceeds up a steep curving bank. This is too difficult for the gritting vehicle to negotiate, so during winter weather, Wheatley Grove can be perilous. Wheatley Grove is a residential road not designed for additional traffic, including many delivery vehicles.

The field is used for pasturing livestock but is also a wildlife haven, especially for owls. It has substantial recreational value. The very top section is within the HRA 400m zone for Ilkley Moor.

There may be a Roman road crossing the field – the route has not been defined.

The field has drainage problems. After heavy rain, water cascades off the golf course at the top of the site, through the field onto Ben Rhydding Drive and overwhelms the storm drain system.

If there is to be pedestrian access to Ben Rhydding Drive from the site, it should be noted that there are no pavements. There is a 20mph limit on Ben Rhydding Drive, but experience shows that many drivers do not observe it.

Comment

Representation ID: 29800

Received: 23/03/2021

Respondent: Ilkley Civic Society

This small site is in green belt but is in very poor condition – nothing grows on a large part of it. Access is straight onto the A65 Skipton Road and the junction would need to be carefully designed. Substantial earthworks, the remains of the former railway embankment dominate the site and would need removal to render the area habitable.

We suggest that the line of the railway embankment through this site is reserved for the Greenway en route to Addingham.