Matter 3 Hearing Statement – Green Belt

Our ref 50765/JG/JG Date 25 August 2017

Subject : Site Allocations Plan (SAP) - Public Examination Matter 3 Green Belt - Hearing Statement on behalf of Persimmon Homes West Issue – Is the Council’s approach to the Green Belt Review robust and consistent with the CS

1.0 Introduction 1.1 This is a Hearing Statement prepared by Lichfields on behalf of Persimmon Homes (PHWY) in respect of Matter 3 – Green Belt.

1.2 This Statement responds to questions in relation to this Matter. The responses of PHWY are made in the context of the following sites being promoted by PHWY, which involve issues relating to Green Belt and are proposed for allocation in the SAP or currently not proposed to be allocated where PHWY considers that they should be: 1 Outer North West – East (Allocation Ref: MX1-26) 2 Outer West – Warm Lane, Yeadon (SHLAA Site Ref: 2162 &1104) (PDE01764) 3 Outer North East – Kings Meadow View (SHLAA Site Ref: 5277) 4 Outer North East – Land East of (Allocation Ref: HG2-226) 5 Outer South – Cemetery Lane, Lofthouse (SHLAA Site Ref: 3085) (PDE02852) 6 Outer South East – Barwick Road, Garforth (SHLAA Site Ref: 2156, 1226, 3114 and 1165) (PDE02826) 7 Outer South West – Land East of Churwell (Allocation HSG2-150)

2.0 Questions

1. Are proposed revised boundaries of the Green Belt consistent with the intentions of the CS?

2.1 PHWY considers that in general terms, the revised Green Belt boundaries are consistent with intensions of the Core Strategy. However, there are a number of anomalies in the regard, which the SAP Examination process should identify and rectify. 1 East Otley (MX1-26): this site is a former UDP allocation that is rolled forward to the SAP. Further work by PHWY, Barratt David Wilson Homes (BDWH) and (LCC) has been undertaken to progress the delivery of this site. Consequently, the extent of land to be removed from the Green Belt requires adjustment on the SAP HMCA Map. The justification for this is set out at Q4 below. 2 Land at Kings Meadow View is proposed to be allocated as Green Belt. PHWY objects to this proposed allocation where there is no justification and allocation as Green Belt would be

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inconsistent with the CS. Specifically, this site lies adjacent to the administrative boundary to Harrogate District where the land is not in the Green Belt nor proposed to be designated as Green Belt land, thus the land will not perform a Green Belt function in the wider area. PHWY considers that there is no justification in national or CS policy for the SAP to allocate land for development within the Green Belt in remote locations such as at Parlington, where sustainable options exist on non-Green Belt land adjacent settlements where the CS seeks to focus development, such as at Wetherby. Further detail on this proposed Green Belt allocation is provided in response to Q5 below. 3 Land at East Wetherby, north of allocation HG2-226, is proposed to be designated as Green Belt, but will be required to form part of the allocation to secure the full delivery of housing required by that allocation. This area, known as Sandbeck Wood is devoid of extensive tree cover and could accommodate housing or public open space required by the wider allocation, thus ensuring the full delivery of the required 1100 homes at HG2-226. PHWY considers that there is no merit in defining a new Green Belt boundary along the notional line of the northern boundary of the proposed housing allocation and the school site in the north east of the allocation. Rather, a more clearly defined and long term Green Belt boundary would be formed by the A1(M) to the north and west and the B1224 to the east. 4 PHWY is promoting additional sites where Green Belt release would be consistent with the intensions of the CS at Barwick Road, Garforth, Cemetery Lane, Lofthouse and Warm Lane Yeadon. As set out by PHWY in response to Matter 7, Barwick Road, Garforth is required to be allocated to meet the housing needs of the Outer South East HMCA within the Plan period. The sites at Warm Lane, Yeadon and Cemetery lane, Lofthouse are available, deliverable and represent Green Belt release sites that would not prejudice the function of the Green Belt in these locations and are therefore consistent with the approach of the CS. These two sites are put forward by PHWY on the basis that should the SAP Examination conclude that additional land is required to deliver housing in the relevant HMCA, then these sites should be removed from the Green Belt and allocated.

2. Is the release of Green Belt land in preference to some Protected Areas of Search identified in the UDP justified?

2.2 Protected Areas of Search are identified in the UDP as locations where development beyond the Plan period would be acceptable and have therefore previously undergone site suitability assessment. They are not Green Belt sites.

2.3 Paragraph 5.4.9 of the UDP explains the role of Protected Areas of Search (PAS) as follows: “To ensure the necessary long-term endurance of the Green Belt, definition of its boundaries was accompanied by designation of Protected Areas of Search to provide land for longer-term development needs. Given the emphasis in the UDP on providing for new development within urban areas it is not currently envisaged that there will be a need to use any such safeguarded land during the Review period. However, it is retained both to maintain the permanence of Green Belt boundaries and to provide some flexibility for the City’s long-term development. The suitability of the protected sites for development will be comprehensively

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reviewed as part of the preparation of the Local Development Framework, and in the light of the next Regional Spatial Strategy. Meanwhile, it is intended that no development should be permitted on this land that would prejudice the possibility of longer-term development, and any proposals for such development will be treated as departures from the Plan.” 2.4 The UDP explanation of the purpose of PAS land is clear, in that it is expected to accommodate development needs beyond the UDP period and to provide some flexibility in the City’s long term development. Thus, future development needs, as identified in the context of the current CS and the SAP, would be appropriately accommodated on PAS sites. With reference to the Housing White Paper 2017, Green Belt land should be released on the basis of a full consideration of alternatives. PAS land represents an alternative in this regard and should be given priority over Green Belt land releases. A specific example of this issue arises in the Outer South East HMCA, where a Road, Garforth PAS site (HG3-18) is not preferred as a development allocation, but where, due to the anticipated delivery of housing from site HG2- 124, Stourton Grange Farm. (see PHWY response to Matter 2), additional sites will need to be allocated in the Outer South West above and beyond the South Garforth PAS site. One such site should be land at Barwick Road, Garforth, which is wholly deliverable within the Plan period and while representing a Green Belt release, occupies land where the Green Belt function is currently not performed and where a defensible, long term Green Belt boundary can be established.

3. Do the sites selected meet the criteria set out in the CS?

2.5 CS Spatial Policy 10 sets out the criteria for the Green Belt Review and allocation of sites to meet the employment and housing needs of the City. This establishes both the hierarchical approach to land allocation depending on the status of the settlements and the role of Green Belt land, consistent with NPPF. PHWY considers that the SAP has, overall, followed this approach. However, it should be noted that: 1 land which has not been identified as appropriate for housing development and which remains proposed as Green Belt land is promoted by PHWY as suitable and deliverable within the Plan period to meet the CS housing requirement for the respective HMCA within which they are located, or to provide flexibility within the relevant HMCA to ensure that the Plan has sufficient reserve capacity to ensure the housing needs of the City are met. These sites are: a Barwick Road, Garforth, b Outer West – Warm Lane, Yeadon c Outer South – Cemetry Lane, Lofthouse these sites are also within areas defined as priority locations within the CS settlement hierarchy, where it would be appropriate to allocate additional land to meet the City’s housing needs. 2 Additional land has been proposed to be included within the Green belt in the Outer North East HMCA, where this land has not been included in the Green Belt Review and the role of the land not fully assessed against the purposes of including it within the Green Belt. Further as set out a question 5, below, the SAP proposes to release large areas of Green Belt land such as at Parlington to accommodate development as a preference to allocating

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housing on non-Green Belt land, or adjacent to land proposed to be removed from the Green Belt much closer to the settlements defined as priority locations by CS Policy SP10. 2.6 PHWY considers that the sites selected by the SAP do not meet the criteria set out in the CS for the above two reasons.

4. Are the boundaries defined clearly, using physical features that are readily recognisable and likely to be permanent?

2.7 There are some instances where the SAP fails to identify clearly defined and long term boundaries to the Green Belt. With regard to the sites proposed to be allocated in the SAP where PHWY has an interest, this is relevant at the following site: 1 East Otley – The Green Belt boundary identified on the SAP HMCA plan does not align with the line of the East Otley Relief Road (EORR) which has now undergone engineering design review by PHWY. The alignment of this highway is shown on the draft master plan attached at Annex 1. The Green Belt boundary therefore needs to be pushed marginally to the east to reflect the highway alignment shown on the attached master plan. This will also release a small area (approx. 05ha) of land to the east of Stephen Smiths Garden Centre on the Pool Road to accommodate development, where a ‘gateway’ development at the entrance to Otley from the east could be provided. This land should also therefore be taken out of the Green Belt in the SAP.

2.8 Sites which are not allocated, but which can be removed from the Green Belt and represent sustainable opportunities to meet housing requirements in the respective HMCA are: 1 Warm Lane, Yeadon – where 130 units can be delivered on land which forms a natural ‘rounding off’ of the urban area south of Yeadon and where Warm Lane would represent a long term defensible and well defined Green Belt boundary. Presently, the Green Belt boundary in this location is formed by Yeadon Gill and a variety of field and property boundaries, often of an indistinguishable nature. 2 Cemetery Lane. Lofthouse – where up to 340 new homes could be provided on the 10.41Ha site without detriment to the visual amnesties of the local area, or the purposes of the Green Belt in this locality. The site was considered by the Council to be the most sustainable in the Lofthouse area but was mysteriously not allocated for housing development. The site represents an ‘infill’ location where access can be taken directly from the A61 Leeds Road and where a long term, easily identifiable and defensible Green Belt Boundary can be formed by the disused railway to the north, which can accommodate a pedestrian and cycle route, and Cemetery Lane to the east. 3 Land to the south of Allocation HSG2-150 at Churwell should be removed from the Green Belt to accommodate the required level of housing for this allocation. The allocation contains a requirement for the delivery of large supporting infrastructure including new school, allotments and railway halt as well as public open space, such that extension of the allocation to the south is required. The proposed SAP Green Belt boundary follows no features which would derive a clear long term defensible boundary. Taking the above into consideration, it is requested that the site be extended to the south in line with the Barton Willmore drawing (RG-M-07, dated 26-07-17) attached at Annex 2 and allocated for housing.

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5. Is the inclusion of additional land within the Green Belt justified and consistent with Policy SP10 of the CS?

2.9 No. Particular example of where land is not justified to be included within the Green Belt are at: 1 Land at Kings Meadow View. PHWY objects to this proposed allocation where there is no justification and allocation as Green Belt would be inconsistent with the CS. Specifically, this site lies adjacent to the administrative boundary to Harrogate District where the land is not in the Green Belt nor proposed to be designated as Green Belt land, thus the land will not perform a Green Belt function in the wider area. This site represents a highly sustainable ‘rounding off’ of western Wetherby, where there is a need to identify additional housing land. The proposed addition of the site to the Green Belt would have no defined Green Belt boundary other than a notional map reference as the administrative boundary between Leeds and Harrogate districts and would, therefore, not be sound under the NPPF. On the ground, this site would be separated from open countryside to the north and west by defensible, permanent boundaries in the form of Ashdale Lane and the former Wetherby Railway Line. PHWY considers that should it be determined that this site should not be allocated for housing in the SAP, that it be designated as a PAS site and remain as open countryside (the same designation as adjacent land in Harrogate) to accommodate future housing requirements. 2 Land East of Wetherby, north of allocation HG2-226, is proposed to be designated as Green Belt, but will be required to form part of the allocation to secure the full delivery of housing required by that allocation. This area, known as Sandbeck Wood is devoid of extensive tree cover and could accommodate housing or public open space required by the wider allocation, thus ensuring the full delivery of the required 1100 homes at HG2-226. PHWY considers that there is no merit in defining a new Green Belt boundary along the notional line of the northern boundary of the proposed housing allocation and the school site in the north east of the allocation. Rather, a more clearly defined and long term Green Belt boundary would be formed by the A1(M) to the north and west and the B1224 to the east.

2.10 As an overarching comment on this question on Matter 3, PHWY considers it illogical and counter to national (NPPF) and adopted CS policy, to allocate large areas of remote Green Belt Land for development where non-Green Belt land exists closer to settlements where development is prioritised under CS policy SP10. Thus, no Green Belt land should be added to the Outer North East HMCA where such alternatives exist and particular examples of such land, well located adjacent to existing settlements or proposed allocations should be allocated as a preference.

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Annex 1: East Otley Draft Concept Masterplan (Allocation Ref: MX1-26) – (drawing number: IL50386/01-002 Rev G, dated 21-06-17)

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Key KEY

Boundary of Study Area Boundary of Study Area Residential Area (High ResidentialDensity) Area (High Density)

ResidentialResidential Area Area (Low (Medium Density) Density) Potential Additional Land for 2 Form Entry Primary School (dual Relocated Sports Residential Area (Low Density) Pitches Sports use recreation) Pitches 2 Form Entry Primary School Potential Employment/Commercial (dual use recreation) - East Otley Gateway

Potential Pool Road Potential Employment Employment/Commercial - East Otley Gateway Open Space Potential Employment East Busk Lane Trees Open Space Future Open Space Trees Stream Future Open Space

Indicative new access roads Indicative New Access Roads

Phasing boundaries Phasing Boundaries PHASE 2 PublicPublic Right Right of Way of Way

CyclewayCycleway

ProposedProposed Sustrans Sustrans Long Long Distance CyclewayDistance Cycleway

St Clair Road PHASE 1

Project East Otley Lisker Drive Title

Client Persimmon Homes (West Yorkshire)

Date  

Scale NTS N Drawn by .

Leeds Road '( /  LR34

Based upon Ordnance Survey mapping with the permission of Her 5L  L © !  !

Annex 2: Land East of Churwell (Allocation HSG2-150) - Barton Willmore drawing (RG-M-07, dated 26-07-17)

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The scaling of this drawing cannot be assured R L ARK A R Revision Date Drn Ckd R ---- D L K O Allocation Boundary L (Ref HG2-150) K A V N U E A R E 10.64Ha/26.29Ac

A N

D D P E Approximate Development A 3 O W Area: 8.64Ha/21.35Ac

R A R Railway embankmentH Approximate School Area: YA O S S Potential location forM 2FEN L 2.00Ha/4.94Ac C A H L Primary School on existing I O Lowest part of site. Approximate Allotment Area: O allotments site M L Potential for attenuation basin 0.84Ha/2.08Ac S T Station car park Emergency/ Service access to station 1 Pocket Parks 2 Existing Footpaths Potential location for 3 Vehicular Access D 2 A new station adjacent to O LITTLELITT LA existing underpass Indicative dwelling numbers LE L (subject to site survey and A 1 technical information) COTEROYDCOTE AVE OTEOTTTEROYDR 259 units @ 30dph AVEAVE 3 2 N 345 units @ 40dph E E R Railway Embankment G 1 K PWW Relocation of Allotments Project Churwell N (Land to the East) Drawing Title 2 Layout Option 3 - Primary School L at current allotments site A P Area to accommodate Date Scale Drawn by Check by P 26.07.17 1:2,500@A3 KD MA R open space requirements O Project No Drawing No Revision A C 2 25384 RG-M-07 - H 20 60 100m Proposed woodland blocks to 04080 2 define development edge

D Planning ● Master Planning & Urban Design ● Architecture ● Landscape Planning & Design ● Environmental Planning ● 2 Graphic Communication ● Public Engagement ● Research bartonwillmore.co.uk

Certificate FS 29637 Offices at Bristol Cambridge Cardiff Ebbsfleet Edinburgh Leeds E Reproduced from the Ordnance Survey Map with the permission of the Controller of HMSO. Crown Copyright Reserved. Licence No 100019279. J:\25000 - 25999\25300 - 25399\25384 - Churwell (Land To The East)\A4 - Dwgs & Registers\M Planning\25384 - RG-M-07 - Layout Option 3.dwg - (1-2500@A3) Newcastle Reading Birmingham Southampton