Bramham NPG: Formal response to SAP

This response also is issued on behalf of Bramham Parish Council

The document below was added to the online form filled in at Leeds City Councils Site Allocation Plan online response form - now closed.

The confirmation of the online form from LCC can be downloaded HERE

1. The Site Allocations Plan as a whole is not considered to be sound, in view of its incorporation of  this large scale allocation, since this proposal was not considered through the original SHLAA and SHMA processes, but was introduced at a later stage, with no evidence of having been evaluated in the manner of other potential development allocations.

2. This allocation is for a new free standing settlement, similar in size to Wetherby. The case for such a scale of development should have been examined as part of the Core Strategy, so that both the principle and the possible location could be properly considered, rather than be intoduced at the Site Allocations stage. It is also evident that this allocation contradicts the settlement hiearchy which is incorporated in the Core Strategy.

3. The allocation involves a substantial loss of Green Belt, with all the consequences which follow in terms of landscape quality and character and loss of habitat. In this respect the allocation is contrary to the policy set out in NPPF. In addition, the loss on this scale and in this location would undermine the purposes of the wider Green Belt in this part of Leeds and would create the risk of further reductions in future, since the allocation is not defined by defensible boundaries. 

4. There is no established case in support of this allocation. This is confirmed by the City Council's own commentary on the proposal, which states the need for a master plan to show that a sustainable development solution can be achieved, as well as a requirement for work to be undertaken to show how the impacts in terms of transport provision and highways can be dealt with. This is an admission by the Council that the case  for the allocation has not been made.

5. The City Council's commentary fails to mention the loss of agricultural land and this must be regarded as a serious omission, not only because of the large area affected, but, in particular, because of the quality of the land concerned, which combines areas pf Grade 1 and Grade 2 classification, which is not common within  the City. In any genuine assessment of the sustainability of the development proposed, this loss of high quality agicultural land must carry substantial weight in the balance of material considerations. The cost to agriculture is a fundamental part of this objection to the proposed allocation.

6. The suggestion that the Headley allocation represents a critical mass of development such as to make it potentially self-sufficient in infrastructure and facilities is disputed as being simplistic and unrealistic. No account has been offered to show how this could be achieved in practice and no mechanisms have been identified whereby the required level of provision could be delivered in conjunction with housing from the outset.  In reality this scale of allocation would be developed over a period of many years, involving an extended period in the short and medium term in which housing would not be supported by adequate local facilities. This would impact on provision in other existing settlements and would increase the likelihood that the new settlement would be predominantly dependent upon private car use. In short, the inherent unsustainability of this allocation cannot be disguised by a conceptual master plan.

7. The feasibility of Headley as a development allocation must be in doubt following the University of Leeds' recent announcement that it does not now intend to pursue the scheme.

8 The Neighbourhood Plan Group has carried out consultation involving every household in the Parish. The responses received have all endorsed the approach taken by the Group and no representations in support of the Headley allocation have been received. The opposition to the Headley allocation has been endorsed by the Parish Council throughout the process.

8. In the event that allocation 3391 is retained within the proposals following this period of formal consultation, the Neighbourhood Plan Group requests the opportunity for its representative to participate in the Examination in Public.

John Lynch MRTPI

for Bramham Neighbourhood Plan Group



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