How to Object to the Hybrid Planning Application
UPDATE - THE CONSULTATION IS NOW CLOSED!
We are almost at the deadline for submitting comments on the East of Otley planning application (16th July 2021). These are the main points of objection (along with the Lisker Drive trees) that we have identified. Please feel free to choose some areas (or all of them) and use this information as the basis of your objection. Help us get as many objections submitted as possible and show how important this greenspace is to our community.
The planning application for the 700+ new houses, employment land, school and major road can be found at leeds.gov.uk >Search for Planning Applications Using Public Access> 21/01671/OT
This will lead to the Hybrid Planning Application, and you will be invited to register, with your email address and a password, or log in if you have already registered. Then click on ‘comment’ and write your comment, first choosing and clicking on ‘neutral’ (for questions), ‘support’ or ‘object’. Please click on ‘object’ if that is what you wish to do.
There is no limit on the number of objections you can make, or on the number per household.
(Top tip: write in a word document first to avoid getting timed out!)
If you do not have access to the internet and you want to read the planning application, please go to The Core, and ask for a printed copy. To object, please write your objection and send it to:
Planning Services, Leeds City Council, Merrion House, 110 Merrion Centre, Leeds, LS2 8BB
You will need to include your full name, address, and the reference number of the application you want to comment on: 21/01671/OT
The final date for objections is July 16th.
Grounds to object to 21/01671/OT
The National Planning Policy Framework (NPPF) 3 states that “Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, biodiversity and landscapes, and the risk of overheating from rising temperatures”. The HPA set of documents fail to properly address this requirement as indicated below.
The HPA is too large:
The developers’ February consultation was for 550 homes, now increased to 700+. The site area has also increased from 50 hectares to 57 hectares, intruding upon Green Belt land. It is a massive development, due to take 6 ½ years to build and is disproportionate for a market town the size of Otley.
The development area now extends eastward beyond the boundary of Site Allocation Plans MX1-26 into the Green Belt.
The community should be re-consulted, and the matter referred back to the LCC Executive Board who only agreed 550 homes. In addition, a Homes England grant of £6.3m was only agreed for 550 homes and 35% affordable, and could risk being withdrawn.
Leeds already has adequate allocations to meet the projected housing needs for more than the required 5 years so can and should choose to resist more than 550 homes on this site.
It should be considered together with other related planning applications:
To ensure the cumulative effects are fully assessed: planning application 21/03709/FU for the existing rugby ground at Cross Green to be turned into a ‘retirement village’, the (still awaiting validation) planning application from Otley Rugby Union Club for a new ground on the Green Belt and the inevitable housing application that will follow the sale of All Saints school (once the new school opens) should be considered together.
Similarly, the consequences of the adjacent Midgley Farm Gravel Allocation being worked. 1.6 million tons of proven sand and gravel reserves and the only allocation in the Leeds district in the current plan up to 2028; river aggregates currently have to be imported from outside the district. Construction of EORR makes it likely that extraction will begin shortly afterwards. This is also not considered in the HPA cumulative effects or transport impact assessment, even though it would result in tens of thousands of lorry trips on the EORR and up the A660.
There are no clear benefits to Otley residents from East Otley Relief Road (EORR):
It is claimed that the relief road will reduce peak-hour congestion, but insufficient origin-destination data was collected with no focus on the consequence for north-south traffic over Otley Bridge. Specifically, no assessment of the increase in daytime traffic with EOO residents driving into town to use amenities in the absence of any onsite proposed shops or community facilities (other than a primary school). 700 new homes could add well over 1,000 extra cars onto our roads potentially increasing existing congestion. An adequate Traffic Impact Assessment is still needed.
With a proposed 30mph speed limit and four roundabouts, the EORR is not a rapid bypass. It is likely to have queuing cars, HGV and increasingly gravel lorries (from the Midgley Farm allocation) stop/starting at the roundabouts and crossings. With the considerable gradient to the south, air and noise pollution will be increased.
A raised section of the EORR, as is happening for the East Leeds Orbital, would allow pedestrians, cyclists, horse riders and wildlife a much safer crossing.
The adjacent walking/cycling path, which needs to be wider, segregated and sheltered, will also suffer from noise and poor air quality.
EORR will provide an impossible barrier for wildlife, unless their movements are fully taken account with tunnels, channels and an underpass. Without this extensive safety fencing to keep wildlife off the road seems inevitable.
Loss of Biodiversity and Green Space
A 47% reduction in biodiversity from the loss of hedgerows (all of East Busk Lane) and other valued habitats is predicted with no indication as to how to attain the required 10% biodiversity gain required by Leeds’ policy. On top of this, substantial losses of “irreplaceable habitat” and a veteran tree will require additional special mitigation.
East Busk Lane should be fully retained as a major ecological and human asset. The development should work around and maintain the existing green infrastructure as per policy MU1.
The Leeds Nature team report indicates what is being lost and how to minimise this, it should be fully taken into account.
Flooding & drainage
The site gets waterlogged in many areas over the winter, for example the back of Danefield Terrace. The detailed application for the Phase 1 housing provides no details of how water is to be moved off the site through a drainage system. Indeed, the only drainage drawing for the whole of the housing and employment areas is a drainage strategy drawing. This fails to deliver the level of clarity and confidence necessary to be assured that an effective and appropriate drainage scheme can be delivered. For example, it shows many indicative attenuation tanks / surface ponds when the reality is that most will have to be attenuation tanks because of the increased housing density.
More detail is provided about the drainage of the EORR, but this drains into a pond located in the Green Belt on “irreplaceable habitat”, it should be located within the site.
The application fails to demonstrate that the drainage proposals will not increase flooding in the local area and therefore fails to meet Policy EN5.
Otley is seriously lacking in sports facilities and a sport hub would be welcome which could cater for a wider range of local sports clubs. It is unclear how the ORUC would facilitate this for other smaller clubs as its application is not yet validated and may not cover this fully or in part. Given the environmental complications and the underlying gravel reserves on this area of Green Belt land, it is questionable whether it is a suitable location.
Viability of the scheme and homes affordable for local people
it appears that for the scheme to be viable it needs to be at least 700 houses, and for the number of affordable homes to reduce from 35% to 23% in order to maintain the developers' standard profit margin of 20% (Persimmon's 2019 accounts suggest a profit of £66,000 per house sold). The simple answer here would seem to be; take a lower profit and provide homes for those who most need them. Viability is the developers' not the community's problem.
Build more terraced homes which are more energy efficient and affordable and less larger homes.
Low carbon homes and the Climate Emergency
CO2 generated will be around 30-50 tonnes embedded in each house built and 2 tonnes per house, per year, thereafter for a hundred years! This is unacceptable in a climate emergency as declared by both Leeds City Council and Otley Town Council.
All homes should be built to the highest possible standard of energy efficiency, and at least to the Future Homes Standard 2025 (FHS). However, the proposal is to build the first 90 homes at 2013 standards, then from June 2023 apply an uplifted standard, with FHS unlikely to apply before 2026. This means 3 different standards of energy efficiency and less readiness for a future replacement low-energy heating system to replace gas boilers. All homes will need future retrofitting and the cost for the first homes will be much higher, with costs falling to the new homeowners.
Schools numbers and places
Schools have not been consulted about the proposed new two form entry school. Where does this leave All Saints Primary adjacent to the site? Can Prince Henry Grammar School (PHGS), cope with increased pupil numbers, in particular with the 330 homes Bramhope development now proceeding? It is estimated using Kirklees LA calculator that the Otley development alone could result, on average, in an extra 14 pupils per year group going to PHGS, casting doubt on whether all eligible children could be accommodated at the school. There is no attempt to deal with this in the application.
Local Health Services
Access to health services, such as GPs and dentists will be under even more severe pressure than they are currently from an additional 700 homes; also requiring consideration is the 66-room development ongoing at Ashfield Works, the consequential 89 units at the Cross Green rugby ground and the expected housing application at All Saints School. No consideration has been given on how to deal with this in the HPA. In particular, the NHS Leeds Clinical Commissioning Group, especially the Primary Care Team, has not been approached to provide a specific response on the development in Otley.
Otley Neighbourhood Plan (ONP)
Was supported by 90% of residents who voted in the 2020 referendum and sets out how any East of Otley development should proceed.
The HPA should respect local residents’ wishes and comply with the ONP in full, the many objections, in excess of 30, raised by OTC to this HPA should be fully responded to.
Transparency is critical so that local residents don’t feel they are being misled and ignored. There should be no hidden decisions made through reserved matters later on. This means providing much fuller information now before any outline planning permission can be considered.