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Aireborough Neighbourhood Development Forum

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Aireborough Neighbourhood Development Forum 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 Leeds 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 Menston and Guiseley 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 Pudsey 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). 2 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 Leeds Bradford Airport, 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.
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