Participant Statement – Matter 7 Site Allocations Plan On behalf of Mr P & Mr N Crowther

25 August 2017

Participant Statement – Leeds Site Allocations Plan Mr P & Mr N Crowther, August 2017

1. Introduction

This is a Participant Statement prepared by Spawforths on behalf of Mr P & Mr N Crowther in respect of:-

Matter 7 – Selection of sites allocated for development.

2

Participant Statement – Leeds Site Allocations Plan Mr P & Mr N Crowther, August 2017

2. Main Matter 7 – Selection of sites allocated for development

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?

Our client is the landowner of part of the allocation at (HG2-145).

The site forms part of a wider allocation, and the land as a whole is being promoted for development for housing by others. Our client fully supports this in principle. Our client has consistently supported this allocation though the SAP process including the preceding SHLAA.

The site is allocated in line with the CS approach as development in one of the ‘smaller settlements’. Whilst classed as a village, Gildersome is relatively large.

The sites are located to the north of Road, Gildersome. It is in the south of the Gildersome. Drighlington is located to the west. The site is within the outer south-west of Leeds District in a highly sustainable location being close to the aforementioned villages with a decent range of services and amenities (schools, local shopping facilities and restaurants), but is easily accessible to Morley, a town that has a wide range of shops, services and amenities. The site is also just to the north of facilities at Birstall Retail Park which provides a range of shops and restaurants as well as a cinema. The site is well located in terms of the local highway network and is close to Junction 27 of the M62 and the M621.

The land can be accessed via existing access points to the north of Bradford Road, an adopted road which formerly constituted the through road from Morley to Drighlington. The road has been more recently stopped up prior to the construction of the A650 Drighlington bypass and the roundabout/major junction at Gildersome spur. As such, road traffic is now minimal within this short road length and services only a limited number of properties including our client’s operation. However, the road is significantly wide in terms of individual carriageways and footpaths, but has separation between carriageways relating to

3

Participant Statement – Leeds Site Allocations Plan Mr P & Mr N Crowther, August 2017

its previous role in the road network. The road therefore is capable of handling a substantial volume of traffic and links into the wider network via the B135 and A650.

Our clients land is in single family ownership and is available for development in the short term.

The site is suitable for residential development as an infill development opportunity with built development on three sides and in a very urbanised area close to the Motorway network and significant retail park. The site is in a highly sustainable location within Gildersome, a large village that is well served by local services and facilities (2 Primary Schools, nurseries, a Co-operative foodstore, an indian restaurant, various eateries/takeaways, public houses, clubs, a library and community centre. It is also close to Drighlington which has a similar range of facilities and amenities. It is very close to key bus routes with stops in easy walking distance to the east and the west. There are playing fields to the east and a cricket club to the north. Morley is close by which is a key town in the south of Leeds that is served by a substantial range of schools, shops, leisure, services and facilities. To the immediate south of the Motorway is the Birstall Retail Park with a regional scale shopping and leisure offer.

The site is achievable as it is located in a highly sustainable location and is in single family ownership. The owners are willingly promoting the land for development. The site can come forward for development within 5 years and certainly can be developed during the Plan Period.

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

Our client does not have a particular view on this except to note that their site at Gildersome has been identified as part of the supply as set out in the CS and it has been established that the Council has failed to meet its current requirement of a deliverable five year housing supply. The housing ‘targets’ are a minimum requirement not a ceiling and so there may be a need for additional land in a variety of areas to address the current shortfall, and the inevitable ‘lag’ from plan adoption to site mobilisation an delivery which can be up to three years or longer. As indicated in previous matters, the phased approach is not supported, but has been adopted in the CS. The SAP needs to reflect the current

4

Participant Statement – Leeds Site Allocations Plan Mr P & Mr N Crowther, August 2017

circumstances and have flexibility to allow for a range of sites to come forward on their merits and not simply be precluded on the basis of phasing.

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)

Our client has no specific comment to make in this regard.

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

Our client has no specific comment in respect of Question 4.

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?

The site at Gildersome is adjacent to a settlement and close to key road infrastructure and existing businesses. Access into the site can be achieved through our client’s existing operation. Utilities and other such infrastructure can be provided to serve the properties.

6. Are the identified Protected Areas of Search sites justified?

Our client has no specific comment in respect of Question 6.

5

Participant Statement – Leeds Site Allocations Plan Mr P & Mr N Crowther, August 2017

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?

Our client’s site is part of Site HG2-145 Bradford Rd, Gildersome. It has consistently been identified and allocated for development through the SAP process. We have concerns that the phasing of sites may affect the supply of housing land, especially given the relatively poor performance of the Leeds district in terms of delivery of units at the current time. There may be a need for more flexibility in the general Policies to ensure that sites can come forward sooner if appropriate and justified rather than as an exception. For example, in Gildersome there has been limited housing development and much of the housing stock is of an older generation. It is a sustainable area in a highly accessible location. Development of site HG2-145 which is likely to be delivered over a period of time (c.10-15 years) could commence sooner and start to provide much needed housing.

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.

Site HG2-145 is considered to be deliverable. The Policy requirements themselves are rather simplified and do not necessarily reflect the site itself and its particular characteristics. It would make sense to identify the potential for some ancillary facilities to support the housing such as small shops or leisure. The location is already highly sustainable, but provision of nearly 400 houses would justify additional facilities.

It is accepted that the site should have two points of access given the size. This can be provided through our client’s existing operation which is outside of the allocation but currently provides access through.

We have sought previously to ensure that the business (JW Crowther & Son) is not part of the allocation as it is a brownfield site that could come forward now subject to justification

6

Participant Statement – Leeds Site Allocations Plan Mr P & Mr N Crowther, August 2017

of loss of employment land. Our client would seek to relocate at that point. On allocation of the wider site, our client will consider timescales for delivery and again would ensure that access is provided here and seek to relocate the business in line with any timescales. This could be in the shorter term, but is certainly achievable in the plan period.

The highways requirements are of some concern, not in respect of whether the site should consider such implications, but moreover what the policy is requiring. It states:

““There is a direct impact upon the congested A62/A650 junction at Gildersome. To mitigate this impact the development will be required to contribute towards any improvement scheme as agreed with Highways . There is also likely to be a direct impact on the A62/Asquith Ave and A62/A6110 junctions and contributions will be required towards mitigating measures.”

We OBJECT to this Policy requirement and propose alternative wording to the policy as it is not considered appropriate to specify in the Policy which roads / junctions that the development may or may not impact on and what the development is ‘required to do’.

The education element in respect of Birchfield School is not likely to be on our client’s land and so our client has no specific comment except that this is a part of the development the site and will be considered in due course as to need and form, but does not prevent other parts of the site from being delivered ahead of this.

PROPOSED CHANGES

The policy wording relating to Site HG2-145 should be amended as follows (new text/amended text underlined and text to be deleted struck through):

• Highway Access to Site:

Two points of vehicular access are required.

• Local Highway Network:

There is the potential for a direct cumulative impact upon the congested A62/A650 junction at Gildersome. To mitigate this impact a proportionate contribution may be required to contribute towards any improvement scheme as agreed with Highways

7

Participant Statement – Leeds Site Allocations Plan Mr P & Mr N Crowther, August 2017

England. There is also the potential for a direct impact on the A62/Asquith Ave and A62/A6110 junctions and contributions may be required towards mitigating measures.

• Education Provision:

Part of the site should be retained to allow for the extension of accommodate an extension to adjacent Birchfield Primary School.

Ancillary Facilities:

Whilst the predominant use will be residential, where appropriate, allowance will be made for supporting facilities such as small shops that will serve the needs of the site and the locality.

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?

As detailed above, our client is concerned about the potential impact that the policy requirements may have on the viability and therefore the deliverability of the site. The key area of concern is the wording used in respect of the local highway network. Again, subject to our proposed policy changes identified above, this can be confirmed and addressed through a transport assessment as part of the development management procedure. There does not appear to be any analysis of the consequences on delivery of applying the policy wording, particularly where elements are ‘required’.

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?

Our client has no specific comment in respect of Question 4.

8