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Are Proposed Revised Boundaries of the Green Belt Consistent with the Intentions of the CS?

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Are Proposed Revised Boundaries of the Green Belt Consistent with the Intentions of the CS? MATTER 3/26212/JB EXAMINATION OF LEEDS SITE ALLOCATIONS PLAN (SAP) EXAMINATION IN PUBLIC Response to Inspector’s Matters, Issues and Questions Made on Behalf of The Grammar School at Leeds Matter 3 – Green Belt Issue: Is the Council’s approach to the Green Belt Review robust and consistent with the CS. Introduction 3.1 This Hearing Statement is made on behalf of our Client, The Grammar School at Leeds (“GSAL”), in advance of making verbal representations to the Examination in Public into the Leeds Site Allocations Plan (“SAP”). 3.2 GSAL is one of the leading educational establishments in Yorkshire and is also a key employer and contributor to the Leeds City Region. GSAL has two main land interests in Leeds which are located in the Outer North-West and North Housing Market Character Areas (HCMA). The first is the main school campus which is located in Alwoodley, the second being Rose Court Nursery which is located in Headingley. This specific representation is made in relation to the main school campus site at Alwoodley Gates which is adjacent to the main urban area and has been proposed to be retained within the Green Belt in the Outer North- West HCMA. 3.3 GSAL have made representations to the adopted Core Strategy and have provided written comments to all stages of the SAP. Question 1: Are proposed revised boundaries of the Green Belt consistent with the intentions of the CS? 3.4 The policy framework for reviewing the Green Belt is set out within Policy SP10 of the adopted Core Strategy. This proposes, in effect, a partial review of the Green Belt for the SAP by outlining that the review would examine the main urban area, major settlements for growth and other smaller settlements identified within the Core Strategy’s settlement hierarchy. Policy SP10 then continues to state that Green Belt land put forward to be released and allocated would need to be assessed against the purposes of the Green Belt outlined in paragraph 80 of the NPPF. 26212/A5/SN/Matter 3 1 August 2017 3.5 In this respect, the Council undertook a Green Belt Review to support the Local P lan process. The results of which are summarised in a Background Paper published in September 2015 (EB5/1), a Background Paper covering the Outer North East (EB5/2) (September 2016) and a general Background Paper (EB5/3) (February 2017). 3.6 The February 2017 Background Paper (EB5/3) highlights the methodology used within the Green Belt Review. This seeks to assess parcels of land according to the tests outlined in paragraph 80 of the NPPF. In this respect, the approach in the SAP can be considered as broadly consistent with the intentions of the Core Strategy. The Council also undertook a ‘sieving out’ process early on in the SAP process to discount sites it deemed were unsuitable from the initial outset and this included consideration against the settlement hi erarchy. 3.7 Notwithstanding this, whilst the overall principles appear to be broadly sound, GSAL does have a number of concerns regarding how the methodology has then been applied to its site in Alwoodley and believes it has not been assessed accurately by the Council against the NPPF criteria (please see further detail on this point below in response to Question3) . The NPPF is clear that when drawing boundaries, local planning authorities should “not include land which it is unnecessary to keep open” and to “define boundaries clearly, using physical features that are readily recognisable and likely to be permanent .” 3.8 Consequently, the assessment against this site is unsound on the basis of being unjustified and inconsistent with national policy. Question 2: Is the release of Green Belt land in preference to some Protected Areas of Search identified in the UDP justified? 3.9 Our Client does not have any specific comments in relation to the above question but does nevertheless reserve the right to comment further on this in so far as it may affect their land interests. Question 3: Do the sites selected meet with the criteria set out in the CS? 3.10 Please see our response to Question 1 above. Whilst the Council’s methodology is based upon the Core Strategy Policy SP10 and paragraph 80 of the NPPF, we do have a number of concerns over the soundness of the approach in which the Council has applied this methodology as this returns land in the Green Belt not necessary to keep land open, such as The Grammar School at Leeds’ Alwoodley Campus. 3.11 The GSAL Campus in Alwoodley is an established educational and employment site . The site consists of a school providing educational and sporting facilities for pupils between the ages of 7 and 18. The school has been located on this site since 1997 and planning permission 26212/A5/SN/Matter 3 2 August 2017 was then granted in August 2006 for extensions to accommodate the merger of Leeds Grammar School and Leeds Girls’ High School. It and was then open to pupils from both schools in September 2008. 3.12 The Site is over 50 hectares in size and is situated to the north of the city of Leeds on the fringe of the main urban area. The Site is accessed from Harrogate Road to the east of the Site which links Leeds to the town of Harrogate to the north. In physical terms, the Site comprises of the main school buildings located at the end of a private drive together with playing fields, sports pitches and parking areas. 3.13 The Site is located in Green Belt north of the development limits of the Main Urban Area. Alwoodley Golf Course wraps around the Site to the south - east with the residential properties of Wigton Lane beyond. Harrogate Road forms the western boundary of the Site whilst open countryside washed over by Green Belt surrounds the Site to the north, east and west. Mature landscaping contains the Site to the north and the countryside beyond is characterised by sporadic dwellings and farmsteads. 3.14 Despite being in the Green Belt a number of applications have been granted for necessary works and extension to the school, all of which have been supported and not considered to have an impact upon the Green Belt or the purposes of including land within it. In line with our Clients previous representations and the criteria set out in the Core Strategy and NPPF, it is considered that the site should be excluded from the Green Belt. 3.15 One of the fundamental aims of Green Belt policy is keeping land open. The Framework is clear in paragraph 85 that when reviewing Green Belt boundaries, land that is not necessary to keep land permanently open should be excluded. 3.16 The issue of openness is linked very closely to the purposes of including land within the Green Belt. The development of this site clearly does not impact or harm the purposes of the Green Belt as the table below demonstrates: Green Belt Purposes Comments Control unrestricted No further sprawl will occur as the site as a whole has sprawl of large built-up strong defensible boundaries including Harrogate Road, areas Alwoodley Golf Course and a mature landscape belt, therefore any future development on the Site does not set a precedent for developing further into the Green Belt. Prevention of The future development of the site does not cause towns neighbouring towns to merge. The Site has defensible boundaries on all sides merging into one another and is located in an area where strong landscape and built features provide a strong gap between the main urban area and other towns. The development within this Site would therefore not lead to the coalescence of two towns. 26212/A5/SN/Matter 3 3 August 2017 To assist in safeguarding The site as stressed above has strong defensible the countryside from boundaries in the form of mature hedgerows, landscaping encroachment and walls. There is no access to the countryside from this land to the public and the land is a previously developed site which does not affect any agricultural unit or land. Preservation of the The site is not located in a conservation area, neither are setting and special there designated heritage assets within close proximity to character of historic the site. Furthermore, the site provides a high quality towns; and environment in which The Grammar School at Leeds would seek to retain and therefore and future development would be high quality and would help enhance the setting and character of the school and surrounding countryside. To assist in urban The site is a previously developed site which has partially regeneration, by been redeveloped. The site is located on the edge of the encouraging the recycling urban area and it has been considered suitable for of derelict and other redevelopment previously to meet the educational needs urban land. of the school. The site has a strong and identifiable curtilage which consists of a well-established school site. The school has sufficient room to expand to meet the educational needs when required within the exiting curtilage and will not require additional Green belt land. The development within the curtilage of the Alwoodley gates Campus will therefore assist in the regeneration of this site whilst not causing a greater impact on the openness of the Green Belt. 3.17 The Site is a longstanding educational and employment site which is well contained by physical boundaries. Its release from the Green Belt would not harm the openness of the Green Belt or its purposes.
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