John Richardson Chair of the branch says “The plans as they stand fail to give enough detail about the way it will be developed. They don’t say when the school will be built, they don’t give enough detail about how damage to the environment will be minimised and they don’t give enough detail about the quality, design and energy efficiency of the houses. If built I want this to be an exemplar development that demonstrates the very best in house building.”
The Labour Party’s detailed submission identifies many examples of where the plans fail to comply with planning guidance, including the requirements set out in the Otley Neighbourhood Plan which was agreed in a referendum by a huge majority in 2020.
Our submission raises concerns about the lack of detail available about the provision of affordable housing. It states that the Otley and Yeadon Labour Party is firmly committed to the provision of genuinely affordable housing: a significant proportion of which should be offered for rent and shared ownership. It points out that many children who grow up in Otley cannot afford to rent or buy here.
Our objection asks for much more transparency about the profits that the developers expect to make. It highlights the risk that, in order to make excessive profits, the developers are not being explicit about the amount of affordable housing that will be built.
It also challenges the plan to increase from 550 to over 700 the numbers of houses built. It points out that no justification has been provided for this. Increased numbers will put even more pressure on schools and health services and further damage local wildlife habitats.
Along with many other organisations in Otley, the Labour Party has serious reservations about the traffic analysis that has been carried. It has insufficient detail and minimises the impact of many more cars on the road. Our response point out that Otley centre is at least a 15 minute’s walk away and proposes that the development of community facilities such as a local shop/café in a “village hub”could reduce traffic and promote community cohesion.
Our objection also echoes the detailed criticisms of the plans to reduce damage to existing wildlife habitats and create new ones made by Wildlife Friendly Otley and others.
Labour Town Councillor Richard Davies says “The application as it stands is totally inadequate as the basis for the biggest development in Otley for a generation. It fails to comply with the Otley Neighbourhood Plan and will seriously damage our local environment. Local people have a right to expect better and the level and quality of their responses highlights the need for their concerns to be heard.”
Download the full 10 page objection as a PDF
Full text of the objection:
Otley and Yeadon Labour Party OBJECTION to the Otley East Consortium Planning Application
(21/01671/OT) 16 July 2021
Otley and Yeadon Labour Party OBJECTS to the East of Otley hybrid planning application in its present form as it fails to conform to key areas of planning policy in the Leeds Local Plan, Otley Neighbourhood Plan and Leeds Climate Emergency Declaration. It also fails to meet certain site specific development and design principles set out in the LCC Development Brief 2020.
As evidenced in comments from both statutory consultees and the local community, the outline and full application are at times ill-thought out, vague and inconsistent, contain significant gaps, insufficient information, and lack strategic documents to make a judgement on the impact of the development as it is presented.
The application needs revision, modification, development, and more detailed information to fully meet planning policy requirements and Development Brief principles. The Local Planning Authority should defer consideration of the application until it is fully revised to fully address these deficits.
Otley and Yeadon Labour Party believes everyone should have access to decent housing that is affordable and sustainable, in an attractive safe environment, with green space, adequate infrastructure and good local services.
Our response covers all these issues, but focuses particularly on housing aspects of the planning application as we are aware that many others, including people and groups with specialist knowledge, have made detailed and technical comments on environmental aspects such as ecology and biodiversity, flooding, drainage, travel and transport, archaeology, sports facilities, etc. We fully support all of those comments which set out the gaps between what is required by planning policy and what is presented in the planning application.
1. Outline application, phasing, infrastructure and design
The outline application does not provide enough information about the overall development and proposed phasing of the scheme. It also lacks sufficient information on green, blue and transport infrastructure issues. (Some of these gaps are highlighted by statutory consultees.) The Development Brief (3.5) requires ‘an overarching Phasing and Infrastructure Delivery Plan to ensure delivery of a policy compliant scheme’. Without this strategic plan, it is impossible to judge the outline application in terms of quality, layout and impact of subsequent phases.
1.1 New school and its phasing
The outline planning application gives insufficient information about the new school or whether there are plans to include Early Years / Nursery provision. The school should come on stream as soon as construction across the site enables safe access, ideally at the start of the school year, in either Phase 1 or very early in Phase 2. The child yield calculations used in ES Chapter L should be verified and the calculations set out in the Design Access and Sustainability Statement to explain the phasing of the school.
1.2 Outline Design Code
Neighbourhood Plan MU1i.c calls for an outline Design Code, but the policy statement only says ‘A Design Code is anticipated to provide the foundation of further detailed stages of the development as is required by the Neighbourhood Plan. Included within the design will be principles in relation to the proposed landscape character and general appearance of the proposed development.’
A fully worked up outline Design Code in line with Neighbourhood Plan policy should be provided with the Outline planning application.
2. Housing
2.1 Housing numbers
The application provides no justification for expansion from 550 to 700 houses. The number should be limited in line with the Site Allocations Plan, LCC’s current healthy supply of housing land, the ability of the local infrastructure to support the development, and minimising damage to the local ecology.
2.2 Housing density
The planning application proposes 40 dwellings per hectare (dph) based on ‘urban’ status.
However, calculations should be based on the edge-of settlement nature of the site, using the
‘fringe urban area’ calculation of 35 dph. We understand the Local Planning Authority expects a ‘net’ calculation: typically around 25% of a site is discounted as land that cannot be built on. The proportion of land not available for building on this site should certainly be greater than 25%, to retain/avoid damage to key environmental features, especially ‘irreplaceable habitats’, and for road infrastructure, and revised surface drainage features. The extra land added by moving the Relief Road to the east should not be included to calculate housing but used for landscaping to create a substantial green buffer from the road and separate cycleway and pedestrian footpath.
2.3 Affordable housing and viability
Local Planning Authority policy H5 requires 35% affordable housing on this site. The
Development Brief states affordable housing should be made up of 40% intermediate rent and 60% social rent (or equivalent affordable tenures).
We strongly support affordable rented tenure, as many children who grow up in Otley cannot afford to rent or buy here, due to the very small supply of rented and purchase properties, with consequent high demand and inflated rents and sale prices. As elsewhere, ownership, even at 80% of market value, is beyond the reach of those young people who most need affordable homes.
We understand the commercial viability of delivering the full 35% is in discussion. If this is because affordable housing will impact the developer’s profit margins, there should be transparency about what the expected profits are, and independent evaluation of the developer’s viability case. Options for providing the full 35% through a proportion off-site provision in Otley (and not elsewhere in Leeds) should also be presented in line with Neighbourhood Plan policy.
Otley and Yeadon Labour Party is strongly opposed to developers making excessive profits which deprive ordinary people of affordable housing. The National Policy Planning Framework Para 57 says that while 15% to 20% is considered a reasonable return on investment, alternative figures can be applied if appropriate. The cost of the land should not be taken into account in arriving at the return on investment as the cost of complying with policy requirements should have been accounted for in the price paid for the land.
2.4 Housing for independent living and accessible housing
Outline planning application – The size of the development requires a proportion of accommodation designed for independent living (Policy H8) and accessible units (H10) to meet the needs of people who may now or in future need care and support to enable them to live independently at home. ‘Enabling’ housing gives residents the option to stay in their own home for longer, living independent lives in properties which are future proofed and ‘care ready’.
The outline planning application says these policy requirements will be met but gives no details or examples of specific design features that will be included. The application should show how the developer will provide high quality, safe, attractive, sustainable and well-designed accommodation that is genuinely enabling.
Full planning application – The Phase 1 planning application should address siting issues and location options for housing required by policies H8 and H10, and specific details of the enabling design features that will be included.
There is occasional reference in the planning application to a ‘care home’ with no obvious further explanation. While sheltered or extra care housing could be provided, a care home is not what is intended by policies H8 and H10 and is not envisaged in the Neighbourhood Plan for this site.
2.5 Housing mix
The housing mix should conform to Neighbourhood Plan policies and include some provision for more homeworking. Neighbourhood Plan H2 says that a significant proportion of new Otley developments should include smaller 1 to 2 bedroom dwellings, and MU1 calls for predominantly semi-detached and terraced housing.
Terraced housing
We strongly disagree with the Local Needs / Housing Market Assessment that Otley is overprovided with terraces – this is a fundamental misunderstanding of the character of the town. Terraces are part of Otley’s Conservation Area character, short terraces feature in 20C housing throughout Otley including the Cambridge estate, and in Garnett Wharfe, the recent riverside development of 250 homes.
Terraced housing can vary in size and is not synonymous with ‘mean’ housing or greater overall density. Terraces are cheaper to heat and insulate and provide more internal space on a smaller footprint than 3-4 bed semi-detached homes, and they tend to encourage community cohesion.
Terraces with good size gardens can help to achieve the required number of dwellings per hectare on a smaller footprint than similar sized semi- or detached houses. This can free up more land to retain more green space and original habitat which is a major unresolved issue on this site. More public green space also boosts the prices of adjacent housing, increasing the financial advantage to the developer of using a careful balance of terraced dwellings throughout the site.
Building Design Code
The planning application does not conform to the Building Design Code required by Neighbourhood Plan MU1 vii–x. There is insufficient information about housing styles and materials in the Design Access and Sustainability Statement to judge the overall appearance and quality of building design. A fully worked up Building Design Code addressing the principles overlooked should form part of the Outline Planning Application
2.7 Character areas
Neighbourhood Plan policy calls for progression of character areas from stone built in the north reflecting the adjacent stone-built Victorian conservation area to more contemporary in the south closer to the Cambridge estate. There should be an underlying architectural unity. (MU1v.c)
The use of character areas in line with Neighbourhood Plan policy to create visual interest and distinct smaller neighbourhoods within in a large development is welcome. However, the treatment set out in the ‘masterplan concept’ (Design Access and Sustainability Statement pp33-38) is not very coherent, with no details of the ‘new and innovative design styles’ promised on p34. Overall, there are missed opportunities to reflect the best of the variety and quality in housing styles, materials and character architectural details in adjacent residential areas – photo examples in Fig 5.5 do not do this. (See also section 6.2)
Housing styles
Design Access and Sustainability Statement pp.46-7 presents 11 standard Persimmon house styles of which 10 will be used in Phase 1, suggesting all styles will be used through the site in all character areas. Given the aim is diversity of character areas, this is very disappointing. Illustrations of how building materials (see below) will be used to vary the appearance of standard styles in different CAs are not provided. It is also not clear which of the standard 11 styles are terraced houses.
All styles should have at least an overhanging porch. It is a particularly mean-spirited and discriminatory feature of modern developments that cheaper houses are sometimes visually differentiated by the absence of any type of porch.
Scale and grain
Four character areas of differing densities are proposed, with properties ranging from 1 to 3 storeys (Design Access and Sustainability Statement p.33). However, Neighbourhood Plan policy MU1viii only permits three storey buildings ‘in exceptional circumstances’, following the advice of Local Planning Authority officers during drafting that three storey buildings are not appropriate for an edge of settlement development adjacent to green belt. ‘Exceptional circumstances’ criteria for three storeys and illustrations of one storey housing styles should be included in the outline planning application.
CA1 and CA2 bordering existing residential areas are designated medium density, CA4 next to EORR is medium to high density, and CA3 bordering the central green space is low to medium density and excludes terraces. The rationale for this is not clear. The intended purpose of ‘character areas’ is visual diversity, not social segregation into high and low density areas.
‘Higher density taller properties’ are proposed for CA4, but type (terrace, apartment etc) is not specified. Design Access and Sustainability Statement p.38 says CA4 will provide a ‘unique gateway feature into the site’ and that taller properties ‘would provide enclosure from the relief road’.
Taller buildings are not a suitable gateway into the development. CA4 is on the edge of a greenfield development site next to green belt, and the view from the A660 and EORR provides the first impression of the town and the development. In this setting ‘enclosure from the road’ should be provided by a buffer of trees, hedges and landscaping, (Development Brief 2.32) not by tall dwellings, exposing more not fewer residents to air pollution from main road traffic.
Building materials to differentiate CAs
A range of building materials are proposed to differentiate character areas. Some of the materials proposed are not appropriate, and there is little differentiation in materials between CA2 and CA3. Red roofs are not used in Otley’s historic core and are less appropriate.
- CA1 abuts the conservation area and so should be stone and slate throughout. Buff brick is inappropriate. Stone lintels would be acceptable as well as mullion surrounds.
- CA2 Adjacent Peterhouse Drive and continues line of Lisker Drive. Brick, and also half and fully rendered houses in contemporary style would be appropriate.
- CA3 proposes materials similar to CA2 with the additional of a third style of roof tile. No illustration of how differentiation will be achieved.
- CA4 proposes southern half in brick and northern half in stone, so is not in fact one CA but two. Given the ‘gateway’ position of this area, stone should be used throughout to reflect the character of Otley’s historic core.
Full planning application – The full planning application for Phase 1 covers part of two separate character areas –about half of CA4 (stone and brick areas) and a smaller portion of CA3. There is a concerning disconnect between the outline proposal for separate character areas, and the full planning application design (eg Design Access and Sustainability Statement p.41) which appears to treat Phase 1 as a single character area with street layout designed as an integrated whole. There are no obvious distinctions or boundaries between CA3 and CA4, and no illustrations showing how building materials and different housing styles will be applied to create design distinction between the two CAs.
Street layout
The Development Brief 2.18 says “internal road layout should provide loops not long cul de sacs” to increase permeability and connectivity through the site. The Phase 1 plan does not adhere to this as streets are mainly long cul de sacs.
Hedging and trees
Ways to mitigate the alarming loss of habitat and biodiversity set out in Environmental Statement Vol 2 Chapter F are as yet undetermined in the outline planning application (see also comments in X Ecology and Biodiversity below).There is much further scope to use hedging not fencing for plot boundaries (we disagree with the recommendation in Appendix F3 5.2.1 to only site hedges in public areas) and more trees within plots as well as in public spaces. This is not as a solution to loss of biodiversity, which should be strenuously avoided, but as a small measure to help mitigate expected losses of biodiversity and enhance the site’s capacity to regenerate green corridors.
The Design Access and Sustainability Statement p.49 shows only some use of boundary hedging and ‘sporadic trees’ throughout the site. The full planning application should expand and specify the quantity and location of hedges and trees in Phase 1, as a small measure to mitigate loss
and contribute to the 10% Biodiversity net gain required by Policy G9 Biodiversity improvements.
2.7 Climate emergency and Energy Statement
The application fails to show how housing design will meet the demands of the climate emergency and Leeds Climate Change Emergency Declaration. Leeds Core Strategy policies EN1, EN2 and EN8 aim to help mitigate the impacts of climate change. The Development Brief 2.45 stipulates that an Energy Statement is required to explain how the reduced CO2 emissions and low carbon energy targets required by policy EN1 will be met.
The Design Access and Sustainability Statement p 63 ducks this requirement by saying ‘a full
Energy Statement, providing greater detail on the energy saving measures proposed by the Phase 1 housing development, can be secured via a suitably worded planning condition following the grant of planning permission.’
This is not acceptable. In the face of a Climate Emergency and the absolute requirement to reduce carbon emissions, the outline planning application must include a comprehensive Energy Statement. It is vital that housing is future proofed and emerging measures and regulations are anticipated as far possible. With gas boilers soon to be phased out, the Energy Statement should consider the full range of energy efficient options, including communal heating systems using ground source pumps. A good quality development should innovate to ensure the costs of responding to the climate emergency are not just passed on to future residents.
A comprehensive Energy Statement should form part of the outline planning application.
3 East of Otley Relief Road
The full planning application fails to provide safe crossing points for pedestrians to access the three sports clubs and public footpaths. We also agree with the East of Otley Action Group assessment demonstrating that the relief road design fails to minimise the impact on the environment or provide strategically located underpasses for local wildlife to pass safely across the new barrier.
The outline planning application fails to assess the likely impact of gravel extraction and lorry journeys on the relief road and other traffic movement.
The alignment of the road at Pool Road takes insufficient account of the impact on safe access to Otley Town FC’s playing pitches and parking requirements.
See also 6.1 Loss of biodiversity and 6.2 comments on design of EORR cycleway and footpath.
4 Infrastructure
4.1 Village feel
Neighbourhood Plan policy MU1iii calls for ‘creation of a genuine ‘village-like” feel with a local, neighbourhood ‘community hub’, including green spaces and a shop’.
There is a view that this contradicts Leeds Core Strategy policy SP2 which requires a ‘centres first’ approach that rules out edge of town retail. However, the Neighbourhood Plan policy is not requiring a retail park or supermarket, but amenities to promote community cohesion among new residents. It was accepted in the Local Planning Authority review and Planning Inspector examination of the Neighbourhood Plan before it was adopted, indicating planners did not at the time perceive a conflict with the ‘centres first’ policy.
There is good evidence in Otley of demand for such amenities: north of the river, there are 3 well-used small convenience stores serving areas of housing towards the edge of town, and 3 small community meeting spaces. Corner shops have experienced a growth in trade during the pandemic and will continue to provide residents who feel vulnerable with a greater sense of Covid safety than town centre supermarkets.
For older or less mobile people and families with small children, it is well over a 15 minute walk to the town’s primary shopping areas. The lack of a local shop will inevitably increase the number of car journeys to fetch the odd pint of milk or loaf of bread. A community hub with corner shop, small community meeting space and other amenities will reduce car journeys and unnecessary town centre traffic, which impact heavily on a town cut in half by a river with only one bridge.
4.2 Travel Assessment and impact of additional traffic on the town
We consider the Travel Assessment is inadequate. We note Highways comments that the Aimsun model used by Fore Consulting for the Travel Assessment is being reviewed, and we support Highways view that data from key junctions across the town are omitted and that a fuller assessment is needed. Detailed data collection which is limited only to Pool Road and Leeds Road ignores the traffic constricting effects of the river: it should be expanded to other traffic pinch points such as Kirkgate, Westgate, Bridge Street, Billams Hill, Weston Lane, Farnley Lane.
The model used to calculate changes in traffic flow in and out of Otley generated by the new development should not assume that people will walk or cycle to the shops or school rather than drive, especially while the development is a building site and a bus service is not yet agreed.
Calculations should also include development sites either proposed or committed in the surrounding area. Highways identifies several other such sites in the Leeds SAP and Bradford SAP areas that are omitted from the TA. The inter-related proposed sites of McCarthy & Stone at Cross Green the new Rugby Club clubhouse, as well as Ashfield Works, Westgate and expected lorry journeys from the proposed Midgeley Farm Gravel Quarry should be projected.
Whilst the relief road will divert some traffic from the town centre, it is not clear that there will be any significant reduction in congestion in Otley. The current incomplete Transport Assessment concludes only ‘benefits of minor significance’ to Otley town centre.
4.3 Local services
Chapter L assesses the population, health and socio-economic impact of the development, including projections of increased demand on primary and secondary schools, and primary healthcare – GP services (L5.79 – L5.91). The calculations are based on desk research.
We are concerned that this assessment does not also include the views of the Clinical
Commissioning Group, GP practices and dentists, and local secondary school and nurseries, who have a deeper understanding of local constraints on services and barriers to access.
This is particularly important when other new developments in the Leeds and Bradford SAP areas, including the proposed extra care housing on the Otley Rugby Club site will increase demand on local services.
The development must not proceed without fuller assessment so that Community Infrastructure Levy and Section 106 financial contributions can be accurately estimated and made transparent.
5 Employment
We welcome the 5 hectares of employment land, the potential to generate local jobs, and emphasis on provision of flexible space start-up premises (Neighbourhood Plan Policy E6). The rapid development of the former Armitage Shanks site to the West of Otley is evidence of strong demand for employment land, of which there is a shortage in Otley and North West Leeds.
We are concerned that the mix of designated uses seems very broad and the category ‘B2 any industrial use’ could allow large-scale industrial units in this location. We urge the Local Planning Authority to define the use classes more tightly if possible, to rule out activity inappropriate for a mixed-use area.
We note that the local planning authority expects developers to maximise the number of local contractors and employees during construction, including opportunities for apprenticeships, working with Employment Leeds (CS Policy SP8). We would urge the developers, Employment Leeds and the Local Planning Authority to explore ways of finding and engaging contractors and employees who work more locally, i.e. within Otley, the local ward, and the wider Wharfedale area.
6 The Local Environment
Individuals and specialist groups have made detailed comments on environmental issues such the loss of habitat and biodiversity that will arise from the development as currently proposed. We support the comments of groups such as Wildlife Friendly Otley, East of Otley Action Group, Otley 2030, ODD and Sport Chevin pointing out the environmental impact of the planning application, and the weaknesses and gaps where it fails to comply with planning policy.
6.1 Loss of biodiversity
The Ecology and Biodiversity assessment shows the development will result in irreplaceable habitats and unacceptable losses, causing a net biodiversity loss. It also refers to the need for off-site habitat creation to achieve the required 10% biodiversity net gain (Chapter F18.8, F9.14).
We also note the comments of LCC Nature Team, and LCC Landscape Team, two statutory consultees, on the impact on the site environment and ecology, and the high loss of biodiversity. Both highlight the absence in the outline planning application of any alternative scenarios to avoid or reduce such a level of losses.
Neighbourhood Plan policy MU1xx calls for the retention of East Busk Lane as a walking and cycling route. This is an old drover’s road, and the Public Rights of Way Consultee notes it may carry public bridleway rights, and certainly footpath status. There is no rationale presented for destroying this important historic route that could easily be retained as a ‘green lane’ to provide cycling and footpath connectivity and an already thriving wildlife corridor.
Appendix F13 Biodiversity Net Gain assessment refers to a proposed ‘Landscape and Ecological Mitigation Plan’ which should also be submitted before the application is considered. (See also comments in section 3 East of Otley Relief Road.)
6.2 Cycleways, footpaths and wildlife corridors
Land freed up by moving the road east should be used to create a wider-than-proposed twolane cycleway and separate footpath (to protect pedestrians) on the west of EORR. We support Highways view that a footpath east of EORR is also required. Both should be separated from the road and each other through green buffers of trees and hedges and landscaping.
There should be more synergy and clearer connections in and out of the housing areas in the proposed network of footpaths, cycleways and wildlife corridors. Adequate connection to Wharfedale Greenway is a major local concern. A safe cycle route and footpath for school students from the development to Prince Henry’s Grammar School via the White Bridge is also necessary.
A key character of Otley is the extensive network of ginnels and footpaths that criss-cross older and newer residential areas. These provide quiet green routes for pedestrians and wildlife through built up areas. Most of the PROWs that cross the site are green tracks, not surfaced paths, and replacement routes should be planted with hedges and not hard surfaced to retain this quality wherever possible. (see also ‘Hedges and trees’ in section 2.7)
6.3 Landscape
We share the concerns of statutory consultees LCC Landscape Team about the quality and gaps in the outline planning application.
We are also astonished that the Visual Impact Assessment Appendix E4 map and photos of key viewpoint locations fails to include the panoramic view of the site from Surprise View, extending the length of the ridge at the top of Otley Chevin. To the south, this is the key elevated viewpoint of the site and its impact on the overall townscape. This viewpoint, mentioned as one of the most beautiful in England by John Ruskin (along with the famous ‘Ruskin’s View’ at Kirkby Lonsdale), shows how dominating the site will be as a proportion of the panoramic view of the town, especially in winter when trees are bare.
6.4 Heritage and archaeology
We note that statutory consultee West Yorkshire Archaeology Advisory Service says the material covering heritage and archaeology is currently insufficient to make a judgement on the impact of the development, and recommends the application is deferred until more information is made available.
7 Conclusion
The Outline Planning Application takes a wrecking ball approach to the ecology of the site, and fails to provide adequate strategic information and plans for various aspects of the development. The EORR design does not adequately provide permeability and connectivity between the site and surrounding area. These deficits should be addressed before the application is considered, and not deferred to conditions of consent or Reserved Matters applications.
Our detailed comments show where the Full Planning Application provides insufficient information to make a determination.
Otley needs housing which enables residents to enjoy living here, no matter their age, income or family circumstances. However, the current planning application falls short of this on many different levels. The Consortium should be required to significantly modify and develop the current outline and full planning applications so they meet the housing needs of people in the 21st Century whilst minimising the impact on the wider environment, wildlife and local infrastructure and services. The planning application in its present form should therefore be rejected.