LEEDS SITE ALLOCATIONS PLAN MATTER 3 GREEN BELT KCS DEVELOPMENT AUGUST 2017 Smith Limited Suite 9C Joseph s Well Hanover Walk Leeds LS3 1AB T: 0113 2431919 F: 0113 2422198 E: planning@peacockandsmith.co.uk www.peacockandsmith.co.uk
1. INTRODUCTION AND BACKGROUND 1.01 These comments are submitted on behalf of KCS Development, a residential site promotion company seeking the allocation land of south of Harewood Road, Collingham (Site 1293) in the Leeds Site Allocations DPD (SAP) for 85 no. homes with extensive open space and buffer landscaping. 1.02 KCS Development is a Member of a consortium of housebuilders (the Collingham Consortium) and site promoters that is proposing a comprehensive masterplan for future housing development in Collingham. The KCS site comprises one of 4 allocations that are proposed in the settlement that together will deliver: 450 new homes, thus reflecting Collingham s role as one of the larger settlements in the Outer North East Housing Market Characteristic Area (HMCA), with a good range of shops and services and public transport services; A site for a new primary school, thus providing the opportunity for education facilities within Collingham to be substantially improved, to the benefit of existing and future residents; and A new access route between Harewood Road and the A58 Leeds Road, which would help to reduce traffic through Collingham Local Centre. 1.03 KCS Development is also a member of a consortium of housebuilders and site promoters (the ONE Consortium) that is proposing an alternative strategy to meeting housing needs in the ONE HMCA than that proposed by the Council. This alternative approach seeks to meet housing needs according to the settlement hierarchy set out in the Core Strategy rather than directing substantial development to a new settlement at Parlington and Wealstun Prison, which is considered unsound. 4585 KCS Development Page 1 August 2017
2. MATTER 3 GREEN BELT Issue - Is the Council s approach to the Green Belt Review robust and consistent with the CS? Question 1 Are the proposed revised boundaries of the Green Belt consistent with the intentions of the CS? 2.01 The first part of Policy SP10 of the Core Strategy indicates that the Green Belt review should generally take place around: The Main Urban Area; Major Settlements; and Smaller Settlements (as listed in Table 1). 2.02 In respect of the ONE HMCA, the Council s approach does not follow these requirements. No housing allocations are proposed in Collingham, a defined Smaller Settlement, and a very substantial Green Belt release (amounting to 53% of all housing allocations in the ONE HMCA) is proposed in Parlington, a location that does not accord with the Core Strategy settlement hierarchy. 2.03 Policy SP10 indicates that exceptionally sites unrelated to the Core Strategy settlement hierarchy can be considered, but that should only take place where: A site can provide a full range of local facilities and services within the context of their HMCA; and A site is more appropriate in meeting the spatial objectives of the plan than the alternatives within the settlement hierarchy. 2.04 We set out in our client s response to Matter 2 (Question 16) the reasons why Parlington does not accord with the above criteria. In respect of the first requirement, we consider it highly unlikely that it will be viable to provide a full range of local facilities and services within the first phase of Parlington, and no evidence has been provided by the Council to demonstrate that this will be the case. Settlements in the ONE HMCA 4585 KCS Development Page 2 August 2017
such as Collingham with a good range of established services and facilities are likely to represent a far more sustainable option. 2.05 Regarding the second requirement, the Council has not provided robust and credible evidence to justify why the housing requirements of the ONE HMCA cannot be met within existing settlements that accord with the locational strategy set out in Policy SP1. The Housing Background Paper (February 2017) makes reference to factors such as poor public transport links, the rural character of the area, the lack of non- Green Belt opportunities and poor infrastructure, but these are generalised assertions that have not been supported with detailed evidence. Furthermore, we address each of these points in our response to Question 16 of Matter 2. Question 3 Do the sites selected meet with the criteria set out in the CS? 2.06 The Council has provided a Green Belt assessment of proposed allocations (and other sites that have been rejected to date) using a Site Assessment Form and methodology provided in the Housing Background Paper (February 2017). The methodology directly relates to the first four Green Belt purposes set out in Core Strategy Policy SP10, which in turn are the same as the national Green Belt purposes set out at Para 80 of the NPPF. 2.07 Our main concern with the Council s approach is in respect of the proposed new settlement at Parlington () when more suitable options that accord with the Core Strategy settlement hierarchy are available. One such opportunity is our client s proposed allocation Harewood Road, Collingham (Site 1293). 2.08 We consider that the Parlington site performs poorly when compared to our client s site, and accordingly we provide a comparison in Table 1 below: Table 1: Green Belt Performance of Sites and 1293 Site Council Conclusion Peacock and Smith Comment Purpose: 1 to check the unrestricted sprawl of built up areas High potential to lead to unrestricted The Council finds that a development of sprawl. the site would result in isolated development in the Green Belt, which we agree with. 4585 KCS Development Page 3 August 2017
Site 1293 Low potential to lead to unrestricted sprawl. The Council finds that a development of Site 1293 would be well connected to the built up area, and it would partially round off the settlement, which we agree with. Purpose 2: Prevent neighbouring towns from merging No merging, but would significantly reduce the Green Belt gap. The gap between and Barwick in Elemet would be as low as 600m, and it would be approximately 1,000m between the eastern edge of the draft allocation and Aberford. The narrow gap between and those settlements could impact on their identity, and constrain their natural growth in the future. Site 1293 No merging but there is no defensible There are well established hedgerow boundary. along the southern and western boundaries of the site. These can be reinforced with further buffer landscaping. Purpose 3: Assist in safeguarding the countryside from encroachment Site performs an important role in safeguarding from encroachment. The site is 114 hectares in size and would represent a significant incursion into the Green Belt in a single location. The Council s assessment states that there is a strong defensible boundary between the site and the urban area and the site which we agree with. Site 1293 Site does not perform an important role in The Council s assessment states that safeguarding from encroachment. there is not a strong defensible boundary between the site and the urban area, and the site does not provide access to the countryside. The site is 4.59 hectares in size and would represent a modest extension into the extensive countryside around Collingham. Purpose 4: Preserve the setting and special character of historic towns Marginal effect on the setting and special There is an outstanding unresolved character, could be mitigated against objection from Heritage England through appropriate detailed design. expressing serious questions about the impact of the development upon a number of designated heritage assets. 4585 KCS Development Page 4 August 2017
Site 1293 No effect on the setting and special character of historic features. Council s Overall Conclusion Development of the site would create an incursion within the Green Belt and the site performs an important role in safeguarding the countryside from encroachment. The site is adjacent to some heritage assets and lies close to Aberford and Barwick which are historic settlements. The site encompasses a well contained landform which is surrounded by mature woodland areas with further scope for significant landscaping works to be incorporated into any development scheme, which will help to assimilate the development and reduce the visual impact from neighbouring historic settlements. The Outer North-East area is already characterised by a pattern of free standing settlements. If developed the new settlement would be situated equidistance from neighbouring villages of Aberford and Barwick-in-Elmet and is separated from Garforth to the south by the M1. As such no merging of settlements will occur, but it would reduce the greenbelt gap between settlements, but not to a significantly detrimental degree. Whilst it is acknowledged that the site would have an impact on the purposes of Green Belt, Paragraph 82 of the NPPF identifies large scale developments such as new settlements are examples where new Green Belt boundaries could be established in exceptional circumstances. Site 1293 Existing residential development is present to the north and east of the site. As such development of the site would Heritage England has cast doubt on the ability of proposed mitigation measures to comply with national policy. We agree with this finding. The reference to major settlements at Para 82 of the NPPF is in relation to the creation of new Green Belts. Site MX2-39 would be a major incursion into attractive countryside, and would leave only a small gap between the development and the settlements of Barwick in Elment and Aberford. The comments by Heritage England indicate that development of the site could result in major conflict with the fourth Green Belt purpose and national policy to protect heritage assets generally. The site does not perform well in relation to any of the 4 Green Belt purposes. It comprises an area of 4585 KCS Development Page 5 August 2017
partially round off the settlement. However, the site slopes and is clearly visible from views to the south. A significant Green Belt gap would remain to Bardsey to the south-west, as such the potential for merging of settlements is low. arable agricultural land with few features other than boundary trees and hedgerow. There are extensive areas of this type of land around Collingham, and the landscape proposals put forward by KCS Development seek to mitigate views of the development. 2.09 Having regard to the above, we consider that the comparison of sites and 1293 shows that the former site performs all 4 purposes of the Green Belt. The proposed allocation of Parlington as a new settlement does not therefore comply with the key criteria of Policy SP10 of the Core Strategy. 2.10 In contrast site 1293 does not contribute significantly to the four Green Belt purposes. The Council s overall site assessment conclusion is that the site is not required to meet housing numbers due to a local preference for an alternative strategic option (which is not specific, but clearly ). However, sites should be allocated based on their planning merits, not on local preferences. Notwithstanding this, the evidence set out in the Submission Draft Report of Consultation (Feb 2017) states at paragraph 6.43 that the vast majority of the representations made to the Revised Publication Draft were in relation to Parlington (3,365). Paragraph 6.50 states that the majority of these representations, over 3,000 objected to the proposed new settlement at Parlington with only a small number of supportive comments. This clearly does not support the Council s conclusions made in respect to site 1293 that there is a local preference for an alternative strategic option. The reference to a local preference for suggests that the proposed allocation of Parlington is not based on a robust and credible evidence base, and it has not been fairly considered against the alternatives such as Site 1293. Question 4 Are new boundaries defined clearly, using physical features that are readily recognisable and likely to be permanent? 2.11 In respect of the proposed new settlement at Parlington (Site ) we note that the boundaries of the site are not well defined along the eastern side of the site, close to a Grade 2* Triumphal Arch feature. The boundaries are also not well defined along the main proposed access to the site from Aberford Road, which cuts across a field that is 4585 KCS Development Page 6 August 2017
a former deer park. The Heritage England objection expresses concerns about significant harm and potential impact to these (and other) heritage assets. 4585 KCS Development Page 7 August 2017