City Council Site Allocations Plan Examination

Matter 7: Selection of sites allocated for development – :

Main Issue 1 Main Issue 2 Additional Site Specific Questions

Doc No. M7/1a

Leeds Local Plan

Page 1 of 16 Main Issue 1: For each Housing Market Characteristic Area, are the individual sites selected sound?

1 Are the selected sites justified having regard to the site selection methodology and process, paying particular attention to the deliverability of the allocated sites?

1.1 Yes. The Council’s response to Matter 6 details the overall site assessment and selection process used for allocation of sites in the Plan. The Council considers that this approach is the most appropriate in terms of meeting CS aims and objectives for the MD as a whole and that the selection of sites is justified. This response to Matter 7 sets out how the overall methodology and process has been applied in this HMCA. It highlights the specific characteristics of and evidence relating to Aireborough and notes whether there are any specific issues arising.

1.2 Further to paragraph 3.1 of the Submission SAP CD1/1, Aireborough is in north west Leeds, containing the major settlements of , Yeadon and Rawdon and Leeds Airport. The settlements are situated along the A65, a main arterial road into Leeds, leading out into the Wharfe valley and the A658 runs through the HMCA from Bradford to Harrogate. To mitigate impacts upon the A65 in particular, a number of sites have site requirements concerning the cumulative effect of development on the A65 corridor, which Bradford MBC were also consulted on and agreed. Guiseley has a train station, with rail links to Leeds and Bradford. The settlements are surrounded by Green Belt to the north, east and west, with large areas of countryside, including Hawksworth Moor to the west and the Wharfe valley to the north. The Bradford administrative boundary adjoins the north western boundary.

1.3 The methodology as outlined in Matter 6 is considered robust. In Aireborough in terms of new housing allocations 48 sites were put forward for consideration, 35 of which are in or partly in Green Belt. In Aireborough there are:

a) 13 housing allocations (9 of which are Green Belt/part Green Belt)

b) 4 safeguarded land designations (all of which are Green Belt) (see response to question 6 below)

c) 31 rejected sites (26 of these are Green Belt).

The reasons for allocation and rejection of sites are detailed at Appendix 2, pages 72 to 78 in the Housing Background Paper CD1/34.

1.4 In terms of office and general employment allocations, 5 sites were put forward for consideration in Aireborough.

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In the HMCA there are:

a) 1 general employment allocation EG3 (Green Belt)

b) 4 rejected sites.

Reasons for allocation and rejection of sites are detailed at Appendix 1, page 24 and 48 of the Employment Background Paper CD1/29.

1.5 Within the context of the NPPF CD3/1, the deliverability of sites concerns whether they are suitable, available and achievable. Paragraphs 5.5 to 5.17 of the Housing Background Paper CD1/34 considers this at a strategic level, paragraphs 5.6 to 5.8 looking at suitability, paragraphs 5.9 to 5.10 availability and 5.11 to 5.17 achievability. The appropriateness of employment sites is explained in the Employment Background Paper CD1/29 and also in response to Matter 2, Question 9.

1.6 In terms of suitability, the site assessment process has considered an individual site’s suitability for development including physical constraints such as access, infrastructure, flood risk, ecology and heritage considerations alongside compliance with the CS. The Site Assessments document CD1/38 provides the full site assessments for all allocations in Aireborough (both housing and employment). Where necessary specific site requirements have been applied to sites where mitigation measures are necessary to ensure a site remains suitable for development.

1.7 In terms of the availability of sites, as paragraph 5.10 of CD1/34 and paragraph 3.13 of CD1/29 details, the sites have generally been submitted to the Council for consideration for the allocated use therefore there is landowner intention to release the sites for that purpose. Where this is not the case the Council has contacted the landowners of allocated sites. No evidence has been received that any of the proposed allocations will not be made available. As the sites are considered to be policy compliant and suitable, any lack of response from a landowner has been deemed to mean that the land remains available and the allocation is justified. The majority of the sites are already being actively promoted by the agents/developers as evidenced in representations received. In addition site HG2-16 Silverdale Avenue, Guiseley has a current planning application pending determination (planning application number17/01262/FU).

1.8 In terms of achievability, the Council’s response to Matter 6 Question 7 explains how viability has been tested and how the Council will respond to any future changes. Aireborough is a relatively high market value area. There is no evidence and no landowner representations have been received on any particular site to suggest that development is not viable.

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2 Are sufficient sites identified in the HMCA consistent with the CS?

2.1 Please see the Council’s response to Matter 2 Question 9.

2.2 Aireborough is 286 under the indicative target of 2,300 as illustrated in the table below.

Extract from Table 1 Housing Distribution by Housing Market Characteristic Area (HMCA), paragraph 2.27 of the Submission Draft Plan CD1/1

Housing Core Percentage Existing Proposed Total +/- Market Strategy supply allocations housing Target Characteristic Housing (‘Identified supply Area Target sites’)

Aireborough 2,300 3% 965 1,049 2,014 -286

Whilst under the CS target, the Council have outlined how it will address this shortfall in our response to Matter 2 and in EX2, response to Question 11.

2.3 As regards employment sites there is no specific HMCA target. Provision and distribution of employment sites is addressed in the Council’s response to Matter 2, Question 9.

3 On identified sites where planning permission has expired, is there very convincing written or verbal evidence that the intentions of the owners /developers have changed? (Please see schedule 1)

3.1 The Council’s response to ‘Further Questions to the Council’ (7th August 2017) EX2c, response to Question 1 provides a narrative in relation to Schedule 1 and gives a detailed response for each expired permission. Since 2012, the base date of the plan, some sites have inevitably expired. This, which is common to all authorities, is a general reflection of the recent state of the market and ‘turn over’ of planning permissions. The Council considers that relying on such sites forming part of supply is justified because: a) of the evidence that sites with expired permissions are developed (see paragraphs 1.1 to 1.4 of the Council’s response to ‘Further Questions to the Council’ (7th August 2017) EX2c, and b) these sites remain suitable, available and achievable. Whilst expiration of planning permissions may have implications for a 5 year land supply assessment and the demonstration that sites are available now, it does not follow that such sites, given Core Strategy aims and objectives and the scope of the SAP, will not come forward over the plan period.

3.2 In Aireborough, 2 identified sites are listed on Schedule 1 of the Inspectors Matters and Issues. The status of each of these sites is set out in the Council’s

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response to further questions 7th August 2017 EX2c and Appendix 1 of the Council’s response to Inspectors initial questions June 2017 EX2. In Aireborough 2 identified sites have expired planning permissions; these are HG1-5 Parkside Works, Road, Guiseley and HG1-11 Station Garage, Henshaw Lane, Yeadon . The evidence as to the intentions of owners/developers is already provided in the Council’s response to Question 1 ‘Further questions to the Council (7th August 2017) EX2c.

3.3 As noted in paragraph 2.3 above, the identification of employment land allocations and floorspace is District-wide rather than apportioned by HMCA. As part of the Employment Land Assessment Update 2017, EB3/7, the Council wrote to landowners in December 2016 (which includes Identified sites with expired planning permission), to make informed decisions as to how sites contribute to the future supply of employment land through an assessment of availability. The Council updated the ELR EB3/7 according to the landowners intentions for the site including confirmation that development for employment purposes could be delivered within the plan period to 2028. In response to that process, one main modification (to site EG1-48 Opposite Ravell Works, Gelderd Road in Wortley, in Outer South West HMCA) is proposed to delete part of the site from the boundary following confirmation that this part of EG1-48 will not be available for the delivery of employment land.

4 Is the proposed mix of uses on mixed use allocated sites justified?

4.1 N/A. There are no mixed use allocations in Aireborough.

5 Where the development of a site relies on the delivery of critical infrastructure (e.g. new roads, new water and waste water infrastructure, significant pre-commencement work), does the evidence support that the infrastructure will be in place to support the timely development of these sites?

5.1 Yes. Please see the Council’s response to Matter 5 Infrastructure. In addition, CD1/35 identifies infrastructure requirements across the District and potential sources of funding/provision, and includes sections on transport modelling and school provision – from looking at the cumulative effect of the proposed allocations, what the infrastructure needs are in terms of the highway network and school provision. Strategic and site specific infrastructure needs are identified, both through the Infrastructure Delivery Plan and in site specific site requirements where necessary.

5.2 In terms of new water and waste water infrastructure there are no site specific requirements within the Plan. Water has been involved in the Plan throughout its preparation. Provision for new water and waste treatment infrastructure can be delivered subject to further feasibility work to look at

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capacity of existing systems. Yorkshire Water are currently analysing the requirements for water and waste water infrastructure and will look to work with and developers to ensure its timely provision. Yorkshire Water raised no objections during the formal consultation stages of the Plan and have confirmed their agreement to this statement.

5.3 Where other critical infrastructure including a new road, or other pre- commencement works are required, these are detailed in the site requirements for specific sites. In Aireborough, all proposed allocations can be accommodated without the need for new road provision, except for site EG3. On this site policy EG3 states that a major highway scheme should be identified with funding and trigger points. Notwithstanding this, evidence suggests that development can commence without this significant infrastructure, and there is no evidence that the highways solution will not be completed prior to the end of the plan period. The Council has consulted on 3 options for an airport link road and is currently undertaking detailed assessment of the road proposal to provide a road link from the A65 at Rawdon to Leeds Bradford Airport.

5.4 Transport modelling has considered the cumulative impact of proposed allocations upon the road network, in particular the A65, and where necessary site requirements for contributions to mitigate any impacts are attached to specific sites. These sites are: HG2-1 Ings Lane, Guiseley; HG2-2 Wills Gill, Guiseley; HG2-3 Shaw Lane, Guiseley & Banksfield Mount, Yeadon; HG2-4 Hollins Lane, Guiseley; HG2-5 Coach Road, Guiseley; HG2-9 Victoria Avenue; and HG2-10 Gill Lane, Yeadon.

5.5 The site requirements are considered justified and no evidence has been received to suggest that they cannot be delivered. The Council is therefore satisfied that the site requirements will ensure timely delivery of infrastructure.

6 Are the identified Protected Areas of Search sites justified?

6.1 Protected Areas of Search are designations in the adopted Unitary Development Plan. The SAP designates Safeguarded Land under Policy HG3. These are sites to be safeguarded from development for the plan period (to 2028) to provide a reserve of potential sites for longer term development post 2028 and to protect the Green Belt from such development. In Aireborough there are 2 UDP PAS sites. Neither site is proposed for allocation or as safeguarded land as subsequent to the UDP designations, Canada Road, Rawdon has been rejected due to highway access and Haw Lane, Yeadon is now designated as a village green.

6.2 Of the 4 sites designated as safeguarded land in Aireborough (total housing capacity 360 representing 5% of the safeguarded land target of 6,600 identified in the Core Strategy) Appendix 2 of CD1/34, page 74 provides reasons for these

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designations. It is acknowledged that allocation of safeguarded land sites could help to make up the housing Core Strategy target in this area, but, as explained in our response to Matter 2 the Council do not consider this to be the best approach. To have allocated the safeguarded land site as a housing allocation, would have simply necessitated the release of further Green Belt land to provide replacement safeguarded land provision.

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Main Issue 2: For each site, are the policies and specific site requirements sound?

1 Are the general policies and site requirements relating to all sites positively prepared, justified and effective (are they clearly expressed so they can be applied in day to day decision-making?) and consistent with national policy?

1.1 Yes. The general policies for each site include policy HG2 and policies HG3, HG4 and HG5 where applicable on sites allocated for housing, policy EO2 on office allocations, and Policy EG2 on general employment allocations. The Council considers that the SAP has been positively prepared on the basis that it is delivering a strategy which seeks to meet objectively assessed development and infrastructure requirements, and is consistent with achieving sustainable development principles (NPPF, CD3/1). As outlined in CD1/28, City Region authorities have been involved through the Duty to Cooperate process and consultation stages of the Plan. In certain cases, where allocation of sites have the potential to impact upon infrastructure in neighbouring authorities, site requirements have been applied to specific sites to mitigate the impact . The SAP is set within the context of the adopted CS and the Council considers that its policies and site requirements are justified. They have been based on up to date evidence, and all reasonable alternatives have been assessed, through the site assessment process and the sustainability assessment of sites. (See the Council’s response to Matter 6).

1.2 The general policies have been positively prepared, in accordance with this approach and are considered justified and effective. The policies are considered to be unambiguous to enable decision makers to apply them in dealing with specific planning applications. Please see also the Council’s response to Question 4 below. The response to this question regarding site requirements is given under Question 2 below. Not all sites have specific site requirements over and above the general policy requirements. Assessment of applications on these sites will therefore rely on policies elsewhere in the Local Plan to guide decision making, all of which have been found to be sound.

2. Are the specific site requirements relating to individual sites justified and effective (are they clearly expressed so they can be applied in day to day decision-making?) and consistent with national policy? For example, many suggest that ‘consideration’ should be given to various matters as part of proposals / planning applications but does not explicitly require anything further to be done beyond that.

2.1 Yes. The site requirements are considered to be justified, effective and consistent with national policy CD3/1, and clearly expressed. Where sites listed

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within the general policy (see response to Question 1 above) have specific requirements, these are listed as site requirements under the allocation concerned. The site requirements are considered necessary in order to make the site sound and enable the delivery of sustainable development in accordance with the policies in the NPPF CD3/1. For example, site requirements concerned with conservation areas and listed buildings will help deliver section 12 of the National Planning Policy Framework.

2.2 See the response above to Main Issue 1, Question 5 regarding critical infrastructure site requirements. In addition to requirements for infrastructure provision, sites have requirements where heritage, ecology or other factors need to be taken into account in ensuring development is sustainable. Certain site requirements have been triggered where a site lies within a certain distance of a designation, such as a Conservation Area or Listed Building, or where a culvert or pipeline crosses or incurs into a site boundary. Where any such trigger is present, we have consulted appropriate bodies further on such sites – for example, on sites adjacent to Conservation Areas or Listed Buildings, the Council’s heritage officers have been consulted and involved in the production of the site requirements and Heritage Background Paper, and Historic has also been involved in the production of the Background Paper and consulted on the site requirements. The site requirements stem from NPPF guidance, including on flood risk (paragraphs 100 to 104 NPPF), section 11 on conserving and enhancing the natural environment and section 12 on conserving and enhancing the historic environment.

2.3 With regards to the Inspector’s reference in this question to site requirements which refer to ‘consideration’ being given rather than an explicit requirement, across the Plan as a whole there are 554 specific site requirements (attached to 208 sites). Only 48 site requirements have wording referring to ‘consideration should be given……’ and most of these (39) relate to a site requirement for re- opening or restoration of culverts.

In Aireborough, 13 allocations have specific site requirements, which amounts to 52 individual site requirements. As with the general policies, the site requirements are considered to be unambiguous, to enable decision makers to apply them in dealing with specific applications. Only 7 individual site requirements in Aireborough have wording referring to ‘consideration should be given to…. ‘ or ‘regard to…’. The table below lists these allocations and the justification for this.

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Site ref and address Site requirements that include Explanation of this wording related to ‘consideration should be given to….

Culverts & canalised To use the word ‘consider’ in this context HG2-1 Ings Lane, watercourses is considered appropriate as opening of Guiseley culverts needs to take full account of The site contains a culvert or public safety considerations, and in some canalised watercourse. cases development cannot be achieved Development proposals should through opening a culvert. The wording consider re-opening or allows for the implementation of the UDP restoration in accordance with policy. saved UDP Policy N39B.

Culverts & canalised As above HG2-2 Wills Gill, watercourses Guiseley Wording as above

Culverts & canalised As above HG2-6 Silverdale watercourses Avenue, Guiseley Wording as above

Aircraft Noise Mitigation The Council propose a Main Modification HG2-9 Victoria to amend the wording of this site Avenue, Leeds Consideration should be given requirement to delete the words at the planning application stage ‘consideration’ and insert ‘aircraft noise to aircraft noise mitigation mitigation is required, (particularly in (particularly in bedrooms), for bedrooms), for example by means of example by means of enhanced enhanced glazing for habitable rooms, glazing of habitable rooms, alternative means of ventilation, and an alternative means of ventilation, enhanced roof specification as and an enhanced roof appropriate, such that the internal noise specification as appropriate, standards of BS 8233 can be achieved.’ such that the internal noise standards of BS8233 can be achieved

Culverts & canalised Culverts & canalised watercourses HG2-12 Woodlands watercourses Drive, Rawdon As Above Wording as above

Gas Pipelines Gas Pipelines To use the wording ‘have regard’ in this The site is affected by a gas context is considered appropriate as pipeline. Detailed design layout Northern Gas Networks will need to be should have regard to the involved at detailed planning application building proximity distance stage and development layout designed required. Consult with Northern to avoid hard development in protection Gas Networks to see if any zones. additional plant protection provisions are needed.

Culverts & canalised As Above HG2-229 The Old watercourses Mill, Miry Lane, Yeadon Wording as above

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3. Does the evidence demonstrate that the deliverability and viability of the allocated sites is not prejudiced by the site requirements, particularly those that have been subject to additional / revised requirements as a result of consultation during the plan process?

3.1 Yes. See the Council’s response to Question 1, paragraph 1.7 above and to Matter 6, Question 7. There is no evidence that any of the site requirements would unduly affect deliverability of the sites or that viability would be prejudiced and no representations have been received on any particular site to suggest that development is not viable. As stated, the online PPG CD3/2 states “Assessing the viability of plans does not require individual testing of every site or assurance that individual sites are viable” (Paragraph 006 Reference ID: 10-006-201440306 revision date 06 03 2014). If any detailed viability issues do arise over the plan period these would be assessed at planning application stage and be subject to full viability appraisals.

3.2 In Aireborough, 7 housing allocations have been subject to additional/revised site requirements which were advertised as pre-submission changes to the Plan in February 2017. These sites are:

Site ref and Pre submission changes to site requirement/additional site address requirement added as pre-submission change

HG2-1 Ings Lane, Additional wording added to conservation area site requirement. Guiseley New flood risk site requirement added.

HG2-2 Wills Gill, Additional wording added to conservation area site requirement. Guiseley

HG2-5 – Coach Additional wording added to conservation area site requirement. Road/Park Road

Guiseley

HG2-6 Silverdale Additional wording added to green space site requirement to Avenue, Guiseley make type of provision more flexible

HG2-9 Land at Additional wording added to conservation area site requirement. Victoria Avenue, Yeadon

HG2-10 Gill Lane, Additional wording added to conservation area and listed Yeadon building site requirements.

HG2-12 Additional wording added to highway access site requirement Woodlands Drive, and ecology site requirement. Minor change to conservation Rawdon area site requirement. Deletion of Local Highway Network site requirement.

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3.3 All the changes to site requirements listed above have given more clarity as to the specific requirements, but are not considered to unduly affect viability or deliverability of the sites concerned and no representations have been received suggesting this.

4. Some sites are identified as being suitable for older persons / independent living. (a) Whilst a preference is highlighted on some sites, it does not appear to be expressed as a requirement. Will Policy HG4 therefore be effective in the delivery of this type of housing? (b) Is the identification of these sites justified?

4.1a) Policy HG4 is not intended to allocate sites for older persons/independent living. It identifies sites which are particularly suitable for older persons housing/independent living as those within walking distance of a local centre. This is simply an indication of which sites could be suitable for this use. It is considered that Core Strategy policies H4 on Housing Mix and H8 on housing for independent living will ensure delivery of this type of housing, with Policy HG4 in the SAP being effective in assisting in this process by identifying potential sites. In Aireborough 6 sites have been identified under Policy HG4 – sites HG2-2 Wills Gill, Guiseley; HG2-5 Coach Road, Guiseley; , HG2-6 Silverdale Avenue, Guiseley; HG2-7 Swaine Hill Terrace – former Brookfield Nursing Home, Yeadon; HG2-11 Larkfield Drive – Ivy House (adjacent), Rawdon; HG2-229 The Old Mill, Miry Lane, Yeadon.

4.2b) Identification of such sites is considered justified in that it is supported by evidence that such housing should be located within easy distance of centres/local community facilities. Policy H8 states that “LDF Allocation Documents should seek to identify land which would be particularly appropriate for sheltered or other housing aimed at elderly or disabled people”: The SAP is therefore in conformity with this CS policy. In the Council’s view, the alternative approach to not identifying such sites would be unhelpful to those providers of such housing seeking appropriate sites. However, in order to allow for flexibility, a specific allocation for older persons has been avoided. Due to the range of types of delivery of such housing, including private developments for over 55 year olds, Council provision, sheltered, nursing and residential care homes etc, the requirements for a particular type of provision may vary, and to require such provision at the exclusion of other housing, is considered to be too restrictive. Moreover, older people can acquire housing on the general market providing that it meets their needs and other CS policies on mix and independent living as well as emerging policies on Housing Standards will seek to ensure the housing product in Aireborough meets their needs.

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Additional Site Specific Questions

1 In relation to EG3 – Leeds Bradford International Airport employment hub:

(a) Is the approach to site selection within the Green Belt justified over the consideration of other sites? Is the allocation consistent with the CS? (b) Do the site requirements clearly express a framework for the proposed Supplementary Planning Document? (c) Is the site viable and deliverable particularly in relation to the link road?

1.1 (a) Yes. The Green Belt Review Background Paper CD1/31 broadly sets out the exceptional circumstances to justify the release of Green belt at the airport in paragraph 3.6. These can be supported by a number of additional points:

• The CS objective 7 and Policy SP8 and SP9 set out a need to find employment land which is accessible to local labour markets.

• The North and North West part of the MD lacks current employment opportunities and has no identified hub in the CS. It has also lost employment land to residential uses e.g. through conversion of mills and warehouses.

• An “Assessment of Employment Needs for North West Leeds” prepared by the BE group on behalf of the Council (June 2015) recommended that 12-14 ha of additional employment land over and above the existing employment allocations be brought to the local market beyond 2021 (EB3/14).

• The North West labour market, comprising the major settlements of Aireborough and Otley is limited in its supply of non-Green Belt alternatives for employment. Otley is constrained by topography and flood risk albeit provides some employment in mixed use sites e.g. East of Otley. Aireborough is constrained by the balance between the need to find suitable housing sites and land which fulfils Green Belt purposes.

• Meeting local employment land needs at Leeds Bradford Airport whilst requiring the release of land from the Green Belt is a justified alternative to the provision of employment land adjacent to Otley or Aireborough given the lack of more suitable, viable and sustainable sites.

• This complies with CS Policy SP10 which includes consideration of employment growth and allows that exceptionally, sites unrelated to the Main Urban Area, Major Settlements and Smaller Settlements, could be considered, where they are more appropriate in meeting the spatial objectives of the plan than the alternatives within the Settlement Hierarchy.

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• From a commercial perspective the allocation addresses a number of drivers for employment growth in this area including:

o Additional airport related employment land requirements to support the continued long term growth of the international airport;

o An opportunity to build a strategic hub in the north of Leeds;

o Synergies and opportunities from the delivery of local employment land with airport related employment use.

• An employment hub would also benefit from planned longer term infrastructure around airport access.

1.2 For the reasons above the Council consider that there is justification for the Green Belt release in this location in conformity with the Core Strategy.

1.3 (b) Yes. The Council considers that a Supplementary Planning Document is necessary to ensure the comprehensive development of the airport and surrounding land as a whole. This is clearly set out in EG3. The objective of the SPD is to deliver a comprehensive approach to the future development of the airport, employment hub and adjoining land, which will bring together and encapsulate wider issues around car parking, surface access and delivery that can be looked at as a package of activities and linked to Spatial Policy 12 of the Core Strategy.

1.4 However, the Council recognise that site requirements should be added at this stage which are specific to site EG3, although relating to the wider SPD criteria. This would ensure clarity for any future planning application, which may come forward in advance of, or in tandem with progressing an SPD. The Council therefore propose a main modification to the Plan to include site requirements for highway access, local highway network, public transport and ecology.

1.5 (c) Yes. The site is viable and deliverable. In any event, Policy EG3 does not explicitly require delivery of the airport link road or contribution to the cost of its delivery. As detailed in our response to Main Issue 1 Question 5 above, policy EG3 states that a major highway scheme should be identified with funding and trigger points. Notwithstanding this, evidence suggests that development can commence without this significant infrastructure, and there is no evidence that the highways solution will not be completed prior to the end of the plan period.

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2 In relation to Site Allocation HG2-1 (New Birks Farm, Ings Lane, Guiseley):

(a) The capacity of the site was reduced to 160 units following a flood risk appraisal that concluded that the western part of the site is at risk of flooding. Does is remain a viable & deliverable site? (b) The requirement for contributions to the local highway network to mitigate the impact of development on A65/ Oxford Road Junction & A65 corridor is quite vague. Is the site viable?

2.1 (a) Yes, the Council considers that the site is viable and deliverable. Following a preliminary flood risk appraisal undertaken on behalf of the Council in June 2016 (CD1/30 Appendix 1), the site capacity was reduced from 285 to 160 units and a new site requirement on flood risk was provided at the Pre-Submission stage to reflect the recommendations of the flood risk appraisal.

2.2 The flood mitigation measures identified in the site requirement do not make the site undeliverable or unviable. The Council has experience of addressing flood risk issues through appropriate design and construction. CD1/30 outlines the flood risk standards in place to assess and identify the appropriate flood mitigation measures as developments advance to the planning application stage.

2.3 Notwithstanding the representation from Gallagher Estates (rep no. PSE00648) which requested flexibility to allow for alternative approaches, the Council consider the wording of the site requirement reflects the findings of the flood risk appraisal and provides appropriate flood risk mitigation. In the event that a planning application is submitted, the necessary flood risk measures will be considered in detail as part of that process. At this stage providing greater flexibility in the wording would not adequately protect future development from flood risk. It is considered that the site remains viable and deliverable.

2.4 (b) Yes. The Local Highways Network site requirement is common to a number of allocations along the A65 corridor in recognition of the constraints on this road. Sites will be expected to provide a contribution towards measures to mitigate against impact on the A65. The Council is currently preparing a methodology paper to determine the level of cumulative impact contributions apportioned to dwelling numbers which will be referred to at application stage. In terms of viability the site falls within a strong market area and it is considered that the site is viable.

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3 In relation to HG2-6 is the requirement for half the site to be greenspace justified?

3.1 Yes. In relation to HG2-6 Silverdale Avenue, Guiseley, the site is designated for allotment use (Policy N1A) in the UDP (CD2/4). Notwithstanding this, given the need to address the CS housing requirement, the extent of existing allotment use of the land, the site in other terms is considered to be acceptable (as it is within the urban area, and not in Green Belt). For this reason the allocation of the whole of the site for housing with a requirement that half is laid out as allotment and /or greenspace is a sound approach to ensure flexibility for the provision of greenspace within a comprehensive development scheme. Furthermore representations have been received supporting the retention of greenspace which is supported by the deficit in allotment provision in the Guiseley & Rawdon ward (CD1/32 Green Space Background Paper – Appendix 2). The site requirement is therefore considered justified.

3.2 A current planning application (ref no. 17/01262/FU) by Stonebridge Homes proposing 46 units on part of the site does not address the site requirement and makes no provision for allotments and / or greenspace as part of the site layout. The applicant has requested that the application be put on hold pending the SAP examination.

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