Greenbelt

GREENBELT

  1. MX2-39 is a key component of the Leeds Green Belt, serving an important function in ensuring the city and its satellite communities do not merge with consequent loss of greenfield land;
  2. MX2-39 is a particularly important part of the Green Belt due to it containing Grade A agricultural farm land;
  3. MX2-39n comprises Ancient Woodland and any change of status would damage this;
  4. MX2-39 is also a designated site of Special Environmental and Geological Interest (SEGI) and is an integral part of the magnesian limestone Green Infrastructure corridor as defined by Natural England and incorporated within Leeds City Councils’ Adopted Core Strategy;
  5. Inserting MX2-39 a few hundred metres from Barwick and Aberford is a gateway for future encroachment and the vehicle for the merging of Barwick, Aberford and Garforth;
  6. MX2-39 cannot be substituted by land to the east of Wetherby currently locally designated as ‘rural land’;
  7. MX2-39 is unsound as any sequential test would propose brownfield, then greenfield (rural land) before Green Belt;
  8. The NPPF and Leeds City’s own core strategy state that one purpose of Greenbelt is to stop communities from merging. The proposed arbitrary extents of MX2-39 in our view, are not defensible planning barriers and as such provide a vehicle for encroachment, coalesce and merging in the future;
  9. Furthermore, the governments National Planning Policy Framework (NPPF) outlines criteria that suggest special circumstances for which Greenbelt can be re-designated and subsequently be allocated for development;
  10. The greenbelt land containing MX2-39 should not be subject to a selective, isolated greenbelt review, and full and sequential review should be taken on all greenbelt in the HMCA area and the whole of the principle authority area.
  11. LCC has identified only 6% of its allocation target from brownfield land for the Outer North East Area. This is not consistent with its own register of available brownfield sites which identifies 30,000 homes as being deliverable on brownfield sites (45% of the 66,000 identified in its own core strategy).
  12. Section 9, paragraphs 79 to 92 of the NPPF articulate the clear importance ascribed to green belt land, the requirement for them to not be used for development with only limited ‘exceptional circumstances’ to this rule.
  13. That these ‘exceptional circumstances’ have not been adequately defined as part of this development proposal. The use of green belt within this proposal is attempted to be addressed by the proposal itself against the 5 purposes of the green belt, as defined in paragraph 80 of the NPPF, but I do not believe these to be correct:
  14. Green Belt serves the following five purposes:
  15. Firstly to check the unrestricted sprawl of large built-up areas – this proposal will increase the ‘sprawl’ of Garforth and East Garforth into the neighbouring villages (particularly when considered against the planning applications for the Garforth area) as well as a continuation of the East Leeds conurbation from say Colton and Seacroft;
  16. Secondly to prevent neighbouring towns merging into one another – this proposal will have the effect of merging Barwick in Elmet, Aberford, the proposed Parlington village and Garforth as well as linking more closely with Colton;
  17. Thirdly to assist in safeguarding the countryside from encroachment – this proposal will only exacerbate the likelihood of encroachment from the aforementioned areas in Garforth and even Colton. The proposed ‘defensible buffer’ is not sufficient to prevent this and will be managed by the same land holders as the proposed development with no recourse to prevent further development;
  18. Fourthly to preserve the setting and special character of historic towns – as discussed above the limited impact on the historic neighbouring villages is predicated on flawed assessments of traffic flows using modelling techniques that do not reflect reality and also based upon a single entry/exit point which the highways agency has assessed as being inadequate;
  19. Fifthly to assist in urban regeneration, by encouraging the recycling of derelict and other urban land – the use of this green belt land runs contrary to this principle as there are alternative sites such as the brownfield sites at Thorpe Arch that could take a significant proportion of house building without recourse to destroying existing green belt land;
  20. These ‘exceptional circumstances’ have been established when other brown field sites such as those at Thorpe Arch have been overlooked in preference of using green belt land;
  21. If any greenbelt land is to be considered for allocation, it should be at an appropriate percentage and on an infill basis immediate adjoined to existing settlements and NOT a country estate containing grade II* and II listed buildings of national heritage value;
  22. MX2-39 is 99.88% green belt;
  23. It includes Ancient Woodland;
  24. It contains ancient monuments;
  25. It will not assist urban regeneration as it is actively farmed arable land; it seems Leeds City Council is trying to frame a tenuous argument that the lack of suitable land to deliver Leeds’s self-imposed housing target is, a “special circumstance” thus the greenbelt at Parlington should be given an allocation;
  26. Barwick should be protected in perpetuity, by the greenbelt, from encroachment by new and existing settlements;
  27. All land in the ONE HMCA area should be sequentially tested in order to establish the most suitable land for development;
  28. LCC has identified only 6% of its allocation target from brownfield land for the Outer North East Area. This is not consistent with its own register of available brownfield sites which identifies 30,0000 homes as being deliverable on brownfield sites (45% of the 66,000 identified in its own core strategy);
  29. The inclusion of this site is inconsistent with National Planning Policy Framework:
  30. PRIORITISATION OF GREENEBLT OVER BROWN FIELD: NPPF states that brown field sites are to be prioritised over the development of green field and greenbelt. The July 2016 Plans Panel meeting had the option of taking forward a brown-field site at Thorpe Arch but rejected this in favour of this greenbelt site.
  31. LOSS OF COMMUNITY IDENTITY: NPPF states that merging of communities is to be prevented, yet development of this greenbelt site will threaten the individual identities currently held between the areas in which they are located. This development of 5,000 houses will only be separated from Garforth by the motorway junction, particularly once the planned development in East Garforth near junction 47 takes place. Although the developers call this development a “village” and the council call it a “garden city” this is clearly an extension of Garforth and represents urban sprawl. The size of this development dwarfs the two villages of Barwick-in-Elmet and Aberford and by extending to within 500m of each village threatens the separate community identity of both villages. The urban sprawl represented by this development will knit the areas of Garforth, Aberford and Barwick together resulting in a loss of individual community identity. There are no defendable features that would prevent the engulfing of Barwick and Aberford by this development;
  32. INADEQUATE ENVIRONMENTAL CONSTRAINT: NPPF now states that the target level of housing development within the plans should be capped in line with the capacity of brown field sites to accommodate it, to protect and enhance greenbelt. The current plans significantly exceed this capacity; resulting in the permanent destruction of greenbelt;
  33. NON-EXCEPTIONAL CIRCUMSTANCE: NPPF states that greenbelt is to be protected and requires exceptional circumstances to be built on. There is nothing exceptional about the council’s plans to build on unspoilt land to meet their current housing target. The council’s adoption of the self-imposed Core Housing Strategy cannot be considered to be an exceptional set of circumstances, but is merely part of their scheduled housing building policy plan;
  34. DAMAGE TO ANCIENT WOODLANDS: Parlington Hollins is classified as ancient woodland. NPPF states that “planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland” (http://planningguidance.communities.gov.uk/blog/policy/achieving-sustainable-development/delivering-sustainable-development/11-conserving-and-enhancing-the-natural-environment/#paragraph_118). This includes land, including parkland next to ancient woodland. The development would threaten this ancient woodland according to the following criteria which are set out by the government to provide guidance for local authorities for developments close to ancient woodland (http://planningguidance.communities.gov.uk/blog/policy/achieving-sustainable-development/delivering-sustainable-development/11-conserving-and-enhancing-the-natural-environment/#paragraph_118):
  35. breaking up or destroying connections between woodland and other habitat;
  36. reducing the amount of semi-natural habitats (like parks) next to this ancient woodland;
  37. changing the water table or drainage;
  38. increasing the amount of pollution, including dust;
  39. increasing disturbance to wildlife from additional traffic and visitors;
  40. increasing light pollution;
  41. increasing damaging activities like flytipping and the impact of domestic pets;
  42. MX2-39 will result in damage to ancient woodland according to nearly all the criteria that Planners have to consider and it is impossible to see how a developer can mitigate the effect of most of these criteria. Therefore, the costs of damaging this irreplaceable national asset do NOT clearly outweigh the benefits of this development, given that the benefit appears to be ONLY that LCC meets its ONE self-imposed housing target.