RESPONDING TO THE LATEST AIREBOROUGH SITE ALLOCATION PLAN BY 4 MARCH 2019

Moonlight Wharfedale – John Atkinson Grimshaw

As we reported in our last post, Leeds City Council have retained 4 Aireborough Green Belt sites in their revised housing allocations.

  • Ings Lane, Guiseley
  • Hollins Hill, Guiseley
  • Wills Gill, Guiseley
  • Victoria Avenue, Yeadon
  • Also the greenfield site of Silverdale/Coach Road Allotments, Guiseley

The Council suggests that these sites are needed for housing development before 2023.  Green Belt sites that were in the SAP but are not needed before 2023 have, for the moment, remained designated as Green Belt.

Current SAP Consultation 21 January 2019 – 5pm 4th March 2019

To make these, and other, changes to the SAP LCC have written ‘main modifications‘ to the Leeds Site Allocation Plan May 2017 (copy here) ,  Aireborough part here .  Before the Inspector considers these SAP modifications they need to be put to the public to see if the residents think the changes are reasonable and will allow for housing growth to meet housing need in a way that is sustainable.  Is the plan ‘sound‘, is it based on evidence, has it looked at alternatives to the proposed housing sites, is it in line with planning law, and can it be delivered?  If there are any negative effects the SAP needs to  demonstrate that development would provide sufficient public benefits to outweigh the harm – what is called ‘mitigation.

How Can You Respond To This Latest Site Allocation Plan Consultation

LCC have put all the main modifications on their website here, together with a response form.   The Public consultation started on 21st January and will run for 6 weeks up to 4th March.  The responses will go to the SAP Planning Inspectors  and they need to be in by 5pm on 4th March to. sap@leeds.gov.uk.  There is also a postal address. The consultation is just for the ‘main modifications’, many people have written to us to ask what it all means and how they can respond.  Below is a typical comment

“I have received the latest letter from Leeds City Council and am at a complete loss about how I can submit anything meaningful. Have you managed to decipher the letter?”

Our Advice on Response

We have taken time to go through all relevant papers to this consultation.  Not all the relevant background documents are on the consultation website, and sometimes there are updates that are not obvious  However the key documents you need are

  1. The LCC SAP May 2017 which is the one being altered – that is here.
  2. The LCC table of Main Modifications – that is here

Below is our view of the key modifications you may like to comment on.

Modifications to do with deleting Green Belt

Broadly, LCC is of the view that the Green Belt sites in Aireborough are needed for housing before 2023 to meet their housing targets for the City, and for Aireborough which is one of their Housing Market Character Areas (HMCAs). This is in the context that housing need is known to be falling in Leeds from Official Government ONS Statistics.

LCC   believe that their housing targets are the exceptional circumstances legally required to change Green Belt boundaries.   You will find this written into the following modifications

  • Modification 1– the need for Green Belt release before 2023
  • Modification 3 – housing targets are the exceptional circumstance for releasing GB and only sites necessary for housing provision have been released
  • Modification 5 – is broadly the table that gives the target for each area of the City (Housing Market Characteristic Area HMCA), of which Aireborough is one.   You will find the table at appendix 1 of the modifications paper.

We think these are the 3 key main modifications for members of the public to respond to, particularly the table in modification 5 which gives the targets for different time periods and, the type of sites available.

It should be noted that the SAP target to 2023 is 43,750, and that LCC wishes to release Green Belt land across the City for 810 houses more than this target.  Another point of note, is that after 2023 the Council has identified non-Green Belt Land for 14,766 houses.    Their reasoning for their proposals is in Modification 3 and says that it is important there is “choice and competition in the market for land throughout the City with a degree of flexibility”.  

When you consider the modifications – especially number 3 –  keep in mind that all Aireborough sites have sustainability negatives – so the question is can these be mitigated so that the public benefit of new housing outweighs the harm?

For example – Most of the Ings Lane site has been graded as a Zone 3b Flood Plain, and developing the site would go against the Green Belt Purpose of keeping Menston and Guiseley separate.  So, does the benefit of houses there outweigh harm to the area or the environment?  What harm would there be?

What about Hollins Hill?  Negatives there include accessibility to facilities, next to an A road and junction with potential air pollution (see tests in the Summer) , and could it encourage urban sprawl in an area of listed buildings and the Tranmere Park Conservation Area?

At Wills Gill Historic England have already said that to mitigate harm to the conservation area a significant buffer has to be left between the medieval tofts and crofts and the site; this has to be ‘natural green space’ in nature.   But this buffer is the only place for an access road on to Queensway now that Shaw Lane is no longer a potential housing site.  (This is mentioned at Modification 27 and can be commented there.)  What about the access on to Queensway and potential standing traffic – how can this be mitigated?   And what about a permanent Green Belt boundary eg road, solid wall, railway, is there one all around this site?   And finally, is it a risk that developing this site will encourage urban sprawl at a later date?

Victoria Avenue, is both next to the Leeds Bradford Runway, and also the main Harrogate Road (see the air pollution tests above).  This site is mentioned in modification 30.

Do you agree with LCC that housing need is so exceptionally great up to 2023 that these Green Belt sites are needed for public benefit, that these are the best ones to build on, that the negatives mentioned (and any others) can be satisfactorily mitigated, and there are no alternative options?

Aireborough Site Specific Allocations

Aireborough Specific Site Allocations run from Modification 27 to Modification 38.  Wills Gill is covered by MM27 due to the change to the plan regarding the natural green space buffer.  Victoria Avenue is Modification 30 due to ta change to do with noise pollutions.  So, people who wish to comment on this can do so under this modification.

Aireborough Habitat Regulations Assessment

Modification 38, is also an important one.  The reason for this additional policy is that all the Aireborough GB sites and many of the other non-GB allocated sites like Silverdale Allotments are within the 7km zone for the South Pennines Moors  (Rombalds Moor).   Part of Ings Lane is also in the 7km zone for the Nidderdale AONB.   You can find a map of this in the LCC Habitats Regulation Assessment November 2018 here, Plan 1 on the page between 22 – 23. 

Housing development in the 7km zone needs to be assessed to see if it will increase the potential for harm to these special protected areas through recreational use of the resident and visitor population.   LCC have revised this assessment in November 2018, and modification 38 is as a result of that.

It is worth reading the LCC Habitat Regulation Assessment (here pages 16 – 29) to see if you agree with LCC’s conclusions.  Are the South Pennine Moors adequately protected from the recreational use from an increasing population?   LCC say that the scale of new development in Aireborough does not need any further actions to ones already being taken to keep increased recreational use away from the South Pennine Moors.

What are these LCC actions?

  1. promotion and management of Chevin Forest Park as an alternative and accessible natural area for recreation
  2. the creation of a pathway (the North West Leeds Country Park Green Gateway)
  3. to continue with the current green spaces in Aireborough  and ensure new ones are created on the proposed development sites for amenity use – eg dog walking , strolling, playing of the following size:
  • Ings is 0.64 h or 1.6 acres
  • Wills Gill is 0.53h or 1.3 acres
  • Hollins Hill is 0.32h. or 0.8 acres
  • Silverdale Allotments – half the site
  • Victoria Avenue is just outside the 7km zone.

ANDF Actions

Email us for help – We are going through all the modifications carefully and using the evidence base we have put together on landscape, ecology, housing need over the last year to examine the situation.  You will find that here.   If you would like help with your response, on a particular point, or if we can help explain anything like the Table at Modification 5, please email us at aireboroughnp@gmail.com.  

Legal advice.  We are also taking legal advice and seeking to raise funds for this through crowdfunding .   We have decided to do this because of the complexity of the process, the confusion over the correct housing target and changes to planning regulations.  If you would like to help fund this legal advice you can do this through our Local Giving Account  here  or email us on aireboroughnp@gmail.com and we can give you details for sending a cheque of a bank transfer.

Write to our Local Represenatives. You might like to write to our local Councillors for either Guiseley and Rawdon Ward (Cllr Graham Latty, Cllr Pat Latty, Cllr Paul Wadsworth),  Otley and Yeadon Ward (Cllr Colin Campbell, Cllr Ryk Downes, Cllr Sandy Lay), and/or our MPs –  Pudsey – Stuart Andrew  stuart.andrew.mp@parliament.uk,   Leeds North West –  Alex Sobel alex.sobel.mp@parliament.uk

Finally, LCC have asked that you use their form to respond.   We would suggest completing that as requested and you can then use it as a front page to a letter.

 

 

 

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