AIREBOROUGH NEIGHBOURHOOD Designing thriving place

DEVELOPMENT FORUM

Response To Revision Submission SAP Matters and Issues June 2018

Matter 1A Does the RSSAP meet the legal process and requirements

Duty to Co-Operate – Bradford Green Belt Review Aireborough HMCA shares a large area of landscape with Bradford MDC where openness is important. BMDC is currently preparing an Allocation DPD, and are undertaking a comprehensive Green Belt Review to inform them of current Green Belt purpose. The consultation for the GB Review methodology was in Dec 17/Jan 2018; the ANDF responded to the consultation (our response is available if required).

Within the proposed BMDC methodology is a definition of Neighbouring Towns in order to assess GB purpose; the definition is 5km (3.1miles) of BMDC’s GB Boundary (section 4.45 Duty to Co-Operate, Green Belt Review – Draft Methodology1). A large part of Aireborough, newly deemed a major settlement by LCC, is within that BMDC Neighbouring Town definition, as are all the Aireborough RSSAP GB phase 1 and Broad Locations sites. HG2-1 and HG2-4 are actually on the Bradford GB border.

Bradford’s 2013 Growth Assessment has already shown that their assessment of Bradford GB purpose is different to that of CC’s site specific GB Review, also done in 2013. For example, on HG2-1 LCC conclude that the site would not merge settlements, whilst Bradford concludes that GB in this area stops and from merging. The Bradford view is supported by a Planning Inspector’s report on HG2-1 (see our early response to the RSSAP page 5). There is a similar story with HG2-4.

The draft NPPF due out in July 2018 puts far more onus on strategic policy making, of which Green Belt boundaries are a part – statements of common ground on strategic matters will be required for soundness. The Government are of the view that LAs should be preparing for such changes in the NPPF as the direction of travel has been clear for some time. We therefore consider that changes to Green Belt boundaries in Aireborough under alleged exceptional circumstances should be subject to a statement of common ground with Bradford MDC. Therefore the RSSAP is not justified in allocating the Aireborough GB phase 1 sites, particularly those on the boundary, and the plan is unsound. We’d suggest their removal from the RSSAP and replacement with the UDP PAS sites brought forward to the RSSAP as safeguarded land HG3.

LCC should undertake a comprehensive GB Review collaborating with Bradford as part of their revised SAP following the Core Strategy Selective Review (CSSR). There needs to be a particular focus on urban sprawl on the Aireborough/Bradford border. If the Aireborough/Wharfedale area is deemed suitable for a GB Boundary change through a statement of common ground, then the precise location for this can be determined through the emerging Aireborough Neighbourhood Plan ( Draft revised NPPF 135). We have now done a masterplan for Aireborough with the Academy of Urbanism. (copy available on request).

1https://www.bradford.gov.uk/Documents/LandAllocationsDPD/green%20belt%20review%20draft%20methodology% 20consultation//Green%20Belt%20Review%20Draft%20Methodology%20Paper.pdf 1

Sustainability Appraisal – Measuring Natural Capital and Ecosystem Services In our response to the Matters and Issues of August 2017 we said

“Leeds Sustainability Appraisal (SA) for the current SAP has not mapped or measured the benefits of, or the opportunities for, the provision of ecosystem services by the green belt land directly around the urban environment ; in particular those of the sites the LA wish to develop. Nor has the SA considered how sites could alleviate current sustainability issues through ecosystem services and green infrastructure, rather than urban development.”

We argued that to be consistent with the NPPF 109, and to anticipate the emerging environmental plans under the 25 Year Environment Plan, as well as the draft NPPF 168, a positive and justified SAP should have measured natural capital assets in Green Belt – which the Leeds SA has not done.

In the October hearings we said we had written to DCLG through our MP to establish their advice on methodology for measuring natural capital assets. We received the following points in replies from Minister Alok Shama of 8 November and 12 December 2017.  The strong protection for Green Belt  That LA’s, together with their communities, should know where “planning restraint is essential”  That the NPPF expects LAs to recognize the character of the countryside, and to enhance biodiversity as well as protect the historic environment.  That a sound plan should also include policies for sustainable development  That if Green Belt was lost then there should be an assessment of it impact and compensatory improvements to environmental quality and accessibility of remaining Green Belt (draft NPPF 137)  That currently the Government did not advocate a single way of measuring the value of natural capital assets or the flow of services from them, but that they recognized that there were a wide range of tools and methodologies available to provide indications of ecosystem services value.  That planning issues such as the ones we raised on natural capital measurement was being considered by the Department of the Environment and DCLG in upcoming policy in 2018.

We maintain that there has been enough indication of the Government’s direction of travel on the environment, and protection of the Green Belt, for the Council to have built more evaluation of natural capital and ecosystem services into its sustainability appraisals (see our response to the M & I August 2017). DLCG point out there is a wide range of tools available including the Natural Capital Planning Tool https://ecosystemsknowledge.net/sites/default/files/wp-content/uploads/2017/events/Housing- infrastructure-wkshop/OliverHolzinger-Cranfield-Oct17-presentation.pdf

This was further signposted in February 2018 when the Minister ruled on the housing appeal at Bagley Lane, Farsley (copy of judgement can be supplied if required), that environmental constraints including harm to the character and appearance of the surrounding area and to the landscape outweighed the issue of LCC not having a 5 year land supply. Even though considerable weight was given to the shortfall of housing land in Leeds, and the site was not Green Belt but greenfield UDP PAS land.

If the RSSAP is to be sound then it needs to plan positively for core strategy P12 and what is now in NPPF 81 and 109 (and which has developed into draft NPPF 137 and 168). At the moment it doesn’t, because there has been no robust measure of natural capital and ecosystem services. Yet, these deficient sustainability appraisals are being used as justification for choosing which Green Belt sites should be in phase 1 and which in Broad Locations, as well as which Green Belt sites are to be deleted rather than using UDP PAS land (HG3)(see our RSSAP response).

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Statement of Community Involvement – Aireborough Neighbourhood Plan and Masterplan

In the Initial Questions and Comments Inspectors asked LCC

Q7 Are any Neighbourhood Plans in the process of preparation, and if so what stage have they reached?

LCC answered with a standardised table, which showed Aireborough was in the stages of Early Engagement. We would like to point out that we are actually in the process of Draft Plan Preparation and have recently completed a masterplan with the Academy of Urbanism; the final report is nearly finished and the output is currently being consulted on with the local community. The rules regarding the preparation of a neighbourhood plan (NDP) by a qualifying body allow considerable flexibility in the stages leading up to formal submission – this is not reflected in LCC’s table.

Following initial work on the issues, priorities and aspirations of local residents and businesses the ANDF realized that the evidence base used by LCC for the SAP in Aireborough was not adequate for policy making in the NDP, particularly in areas such as the environment (eg NPPF170). In essence Aireborough needed a masterplan. In addition, site specific SAP policies did not cover important areas such as design and environment.

We also made it clear that we wished to plan for the housing allocations in the Neighbourhood Plan (see the ANDF response to the 2015 Public Consultation SAP, p7/8 ) on smaller sites (draft NPPF 69) in the urban environment at higher density. We have therefore, on the advice of DCLG’s Neighbourhood Planning Partner AECOM (see AECOM, Aireborough’s Baseline Report, Oct 2015, part 6), built a proportionate evidence base with a strong focus on community involvement to plan positively and justifiably. We have shared this information with LCC so they could improve their Aireborough evidence in line with NPPF 185 and 155. (see our response to M&I August 2017).

During, the SAP hearings in October 2017 there was a discussion with regards a masterplan for , and we put forward the crucial need for a masterplan for the whole of Aireborough. Following those hearings, the Neighbourhood Forum asked the Academy of Urbanism to use our evidence base to suggest a masterplan for the Aireborough Neighbourhood Plan area – this they have now done

From this exercise, we are now in the process of drafting out the theme based policies for our Neighbourhood Plan in conjunction with the required community engagement so vital to neighbourhood planning. The only reason we appear not to be in the second column of the LCC table is because as this draft is not finished LCC has not commented on it; although they have made comment on our initial breakdown of themes and potential policies.

Matter 2A Does the RSSAP give effect to and is it consistent with the Core Strategy

Our view is that Broad Locations in the Leeds Revised Submission RSSAP (RSSAP) are flawed; unjustified, not effective, and inconsistent with the NPPF. Their use raises issues of both principle and methodology. As a matter of principle they serve no purpose, do not meet development needs in the Core Strategy and have no exceptional circumstances to justify release – especially in the light of the Core Strategy Selective Review. Meanwhile, the methodology used for the identification of Green Belt sites and Broad Locations by HMCA cuts across important planning policy considerations such as Green Belt policy and sustainability including those we mention in matter 1a. (our RSSAP response has more detail.)

As a consequence policy BL1 is a fudge and the Council should accept that there are no exceptional circumstances to justify their Green Belt releases. Therefore, all Green Belt sites should be withdrawn and the RSSAP found sound through an explanatory paragraph regarding an early review of the RSSAP following the adoption of the CSSR in line with the High Court decision in GUI v Dacorum. 3

Matter 3A Is the Council’s approach to the Green Belt robust and consistent with the CS

Our view is that the Council has not demonstrated the exceptional circumstances for GB release in the RSSAP – neither phase 1 or Broad Locations. Furthermore, the CSSR removes the need for the proposed dwellings on Green Belt sites (see the ANDF response to the Core Strategy Selective Review March 2018).

The Council claims their lack of 5yr land supply since 2016 is an exceptional circumstance, but this is flawed and unsound: there are alternatives to use of Green Belt sites, whilst those chosen are not demonstrably the most sustainable as we have shown in our detailed response. Also, as the appeal on a greenfield site at Bagley Lane, Farsley (which is close to the Aireborough border) showed there are times when environmental planning restraint outweighs the 5 yr land supply issue. Further, this claim to exceptional circumstances is a short-term claim; from November 2019 the Council’s current 5yr supply issues will no longer be extant.

As a consequence the RSSAP should remove all Green Belt sites, and make clear that following the CSSR there will be an early review of site allocations including a comprehensive Green Belt Review as required by the Core Strategy and the CS Planning Inspector’s Report - if it is felt exceptional circumstances exist. In addition, there should be a statement of common ground with Bradford on the green belt in Aireborough/Wharfedale especially as the latest Leeds SHMA (2017) shows that the housing market for Leeds has changed since the last SHMA (2010?) and that the Aireborough HMCA is now shared with the Wharfedale part of Bradford (see Leeds SHMA 2017 2.28, 2.8, 2.9).

Matter 5A Whether necessary infrastructure will be in place to support planned development

Two of the major infrastructure issues in Aireborough are the chronic congestion on the A65, and the lack of schools both primary and secondary for future needs. We consider that the RSSAP changes to phase 1 and Broad Locations create issues in the timely delivery of supporting infrastructure ( see Table 1 below). There is also a critical shortage in smaller homes (see 2017 SHMA) as well as older persons/independent living – smaller homes have not been identified in site specific policies. The SAP site specific policies are based on an out of date SHMA; new HMCG specific SHMAs have now been produced (2017), although the have not yet been released to the public.

TABLE 1 Site Name Site A65 corridor Other School Type of Site Ref Cap mitigation Highway Provision Housing HG2-1 GB Birks Farm, Guiseley 160 x x HG2-2 GB Wills Gill, Guiseley 133 x HG2-3 Older pers HG2-4 GB Hollins Hill, Guiseley 80 x x HG2-6 GF Silverdale Allotments, Gui 32 Older pers HG2-7 BF Swaine Hill, Yeadon 7 Older pers HG2-8 BF Kirkland House, Yeadon 17 Older pers HG2-9 GB Victoria Avenue, Yeadon 102 x x HG2-11 GF Larkfield Drive, Rawdon 6 Older pers HG2-229 BF Miry Lane, Yeadon 15 BLHG2-3 GB Shaw Lane, Yeadon/Gui 234 x HG2-2 BLHG2-5 GB Coach Road, Guiseley 83 x x Primary Older pers BLHG2-10 GB Gill Lane, Yeadon 155 x BLHG2-12 GB Woodlands Drive, Rawdon 25 (x @ 130) x BLHG3-1 GB Ings Lane, Guiseley 114 BLHG3-2 GB Knott Lane, Rawdon 81 BLHG3-3 GB Rawdon 35 BLHG3-4 GB Layton Lane, Rawdon 130

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Matter 7A Aireborough

We have stated in Matter 1a that the Aireborough NDP had reached the stage of masterplanning on an up- to date, relevant evidence base. In that work it has been calculated that within the Aireborough Neighbourhood Plan area the current urban capacity for houses is 1,200 units (see Table 2), with further units possibly available in the Rawdon Neighbourhood Plan area, and a question of whether applications for 154 units have been included in current figures.

TABLE 2 Aireborough Neighbourhood Plan Area – Urban Capacity as at 2018 154 units Applications not yet included in figures 140 units increasing the density of current sites such as HG2-8 560 units in sites identified in the urban character report 500 units small windfall sites over the plan period Total 1,200 Newly identified opportunities Further units Rawdon Neighbourhood Plan area

These sites are the type of sites that are most suitable for the critical shortage of smaller homes for young couples, downsizers, and accommodation for independent living that our Housing Need Survey identified and which the 2017 SHMA confirmed. We are still awaiting the LCC release of the HMCG specific SHMAs.

In previous UDPs Aireborough urban core has been deliberately planned with a tight Green Belt boundary to conserve its character.

“Guiseley is protected by a tight Green Belt boundary around it, it is important that it remains so to prevent Guiseley from becoming an extension of suburban Leeds or merging with Bradford. The Green Belt enables Guiseley to remain a compact town and ensures that new development is focused within Guiseley and does not create urban sprawl. “ Guiseley Consultation Report, LCC, May 2007

Our response to the CSSR demonstrates the issues caused by the HMCG target and the Leeds spatial strategy in policy SP6 and 7 in such an area. NPPF direction, CS spatial strategy for priority regeneration areas and environmental considerations, especially contained in the ANDF evidence base, should have played a larger part in SP7. And, what of the future and the permanence of the GB boundary? There is no room to keep taking 3% of the LCC housing need, and it is absolutely critical for Aireborough’s OAN to get its housing stock types right in this planning period? Aireborough needs more careful thought for the long term permanence of its Green Belt, sustainability and wellbeing for the SAP to be sound, and that is why we have evidenced our masterplan with experts in the AoU. In addition, the Leeds SHMA (2017) has indicated that Aireborough HMCA has links to Bradford’s Wharfedale area, and thus cross-border strategic planning is required for sustainability. The masterplanning work noted that our evidence showed local residents were “right to be concerned about allocations in the Green Belt ……….all set within valuable landscape or will affect the setting of the town.” This has also been said by other professional, respected, urban planners who have looked at the area over recent years. For a sound allocation plan, Aireborough’s RSSAP should have its GB sites deleted, and the Council should work with the ANDF and Rawdon Parish Council on their Neighbourhood Plans, as well as with Bradford on the CSSR and BMDC’s Allocations DPD

Specific questions 1. HG2-2 and HG2-3 (Wills Gill and Shaw Lane) were planned in the original SAP to be an urban extension relying on each other for highways infrastructure, especially since HG2-2 needs to leave a significant buffer on the west to preserve or enhance the toft and croft part of the medieval field system ( the site of HG2-2 is also part of the medieval field system) – the very fact that a large landscape buffer is required rather points to this Green Belt site fulfilling purpose in keeping land permanently open. (The same is true of HG2-1.) We do not see how an urban road can enhance the setting of medieval fields? This means that the development of this phase 1 site will leave an isolated protrusion of urban development jutting out from the old GB boundary with no 5

permanent eastern boundary, or strong natural boundary feature to ensure containment. We maintain that this will lead to urban sprawl, eastwards, especially when it is considered that the north of site HG2-3 has no feature that is a natural boundary, let alone a permanent one. The allocation, site specific policies and splitting of this urban extension between phase 1 and BL is not sound.

2. The change of HG2-5 (Coach Road) to a Broad Location means there is no allocated site for a much needed Primary School. However, this was not a sustainable site for such a school owing to access issues. The SAP or Neighbourhood Plan does need to allocate sites for both a primary and secondary school and with so little available land that needs to be done at the same time as other allocations – hence the need for a masterplan. In terms of the site specification for Independent living we do not consider this a good choice because of limited access to public transport and facilities. There are other sites we have identified in the masterplan where Independent living could be accommodated.

3. HG2-10 (Gill Lane) is the medieval manor land that belongs with 17th century Low Hall and was separated one from the other in the 1950s following a sale of other estate lands to the Ministry of Ministry of Works under the requisitioned land act 1945. Local residents wish to see the medieval manor land and Hall reunited as an historic asset and a feature of Nether Yeadon (a pre industrial settlement) – which is also the point made by Historic England. Although it scores less than other sites on GB purpose, this one historical environment factor carries significant weight, and the community would like to see it removed from the SAP altogether so that its natural capital can be enhanced. However, that being said, in terms of the criteria for LCCs choice of phase 1 and BL sites, no, it is not consistent, (see the table on page 5 of our RSSAP response), but this is true of other sites as well.

Jennifer A Kirkby For and on behalf of the Aireborough Neighbourhood Development Forum

Attchments ANDF response to the Core Strategy Selective Review March 2018

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