Please see below the response by the Adel Neighbourhood Forum to the reserved matters application.
Residents and other interested parties may wish to send their own responses to Leeds City Council, quote application number 18/04343/RM and email; firstname.lastname@example.org
To Mrs Carol Cunningham, Planning Services
Merrion House, Merrion Street
LEEDS LS2 8BB
Dear Mrs Cunningham
Land to the East of Otley Road, Adel, Leeds – Application Number 18/04343/RM
We wish to comment on this Reserved Matters application:
Adel Neighbourhood Forum and significant numbers of local people individually have consistently objected to any development on this site. However we recognise that with outline planning approval having been granted, some development will take place on the land to the west of the beck running through this site.
We and many others have articulated that this site is of particular significance in view of its heritage and landscape context.
We are bitterly disappointed with the submissions made by the developer in this Reserved Matters application as they show a blatant disregard for any of the views of the local community and in effect are stating their views are irrelevant. This follows on from feeble efforts to carry out any sort of local consultation. It is therefore with regret that we have to address the detail of these submissions in the hope that the Council will be able to take a more robust stance when it comes to consideration by the Plans Panel.
We and many others have articulated that this site is of particular significance in view of its heritage and landscape context
We have examined the “Design and Access Statement” submitted in support of the application. It contains numerous inaccuracies, half-truths and misrepresentations and needs to be read with a sceptical eye.
Archaeology: the risk of further destruction of historically significant evidence
We note that the West Yorkshire Archaeology Advisory Service has recommended that this planning application be deferred until such time as a proper investigation of this site has been completed. The Service refers to crop marks indicative of a Roman Road crossing the site. We understand that this Roman road may well be the important road from Manchester to York meeting the already known Roman Road in Adel (from Ribchester to York). If that is the case, this has important ramifications for the significance of Adel as a settlement in the Roman period.
The line of the crop marks continues into the recent Barratt David Wilson Homes ( BDWH) development which they named “Centurion Fields”, acknowledging the Roman legacy of this location. BDWH did not conduct a proper archaeological investigation of that site . It is disappointing that Leeds City Council did not demand a proper investigation; the failure to do so means that important archaeology has probably been destroyed by that development.
This must not be allowed to happen again and we strongly endorse the recommendation of WYAAS that this application be deferred pending proper archaeological investigation and then re-considered when the results of that investigation are known.
Subject to the overriding issue above, we have the following observations about the proposed development, reminding ourselves that the site is opposite a Grade 1 listed, 12th century Norman church of national importance, opposite Adel conservation area and adjacent to landscape classified as a Special Landscape Area.
Site Topography and Environment
The Design and Access Statement (“DAS”) seeks to downplay the sloping nature of the site. At 3.0 it states “Generally the site has a gently sloping platform, the highest point being 134m AOD on the south-east and south-western corners, falling to 129m AOD in the north-east and north-western corners.“ What the DAS should have added is that the site falls a further 10 metres down to the beck running through the middle of the site and that the site is therefore quite steep in places.
The site slopes quite steeply about 50 feet down to the beck from the plateau on which Adel churchyard stands. This is important in understanding the visual impact the development will have from the churchyard and conservation area. We can only assume that BDWH are asserting that the site is almost flat to support their incorrect assertion that it will be blocked from view from the churchyard by newly planted trees.
It is on this steep part of the site where BDWH proposes that school sports pitches be placed; that would be impossible without significant earthworks and terracing. This is a major issue which would have significant cost and quality implications and it needs to be addressed now.
Similarly, the land slopes quite steeply from the Northern edge of the site in a North-Easterly direction down to Adel Mill. Houses on the Northern part of the site will be very visible when entering Adel from the North East and would need to be screened by a substantial shelter belt.
Part 3.0 of the DAS goes on (at page 10) to provide a very misleading description of the context in which this site is located. It asserts that the land to the west of the site comprises “The prominent Lawnswood Arms public house and a mixture of 1930s and 1960s semi-detached houses”. Infact these are on Otley Road and are invisible from the site because only a tiny portion of the western side of the site actually abuts Otley Road- and that is partly screened by mature trees. The great majority of the western side of the site abuts woodland garden surrounding Adel Willows. This is not “a strong residential boundary” as asserted.
At 5.0 of the DAS it is asserted that “Existing views from the Church directly west currently terminate on the housing on the West of Otley Road creating a suburban view.” This is simply not true. Views west from the church terminate at the trees surrounding Adel Willows which is between the church and Otley Road and blocks any view of Otley Road. The assertion at 5.0 that “New woodland planting within the site will ….create a more rural view..” is similarly untruthful for the reasons set out above.
The east of the site is farmland; the conservation area, Grade 1 listed church and related buildings stated to be at the east of the site are actually beyond the farmland. The north of the site is also farmland, again with listed buildings beyond.
The only boundary with any significant level of buildings adjoining is the short southern boundary where a recently planted shelter-belt is overlooked by the BDWH Centurion Fields development.
The southern boundary is short compared with the other boundaries. Approximately 85% of the boundaries to the site adjoin farmland or wooded areas.
It would appear that BDWH are attempting to create a false impression that this site is a suburban location such that its current proposed development will fit in and cause no detriment to the outlook from the churchyard and conservation area. The aerial photograph at the front of the DAS show a truer picture of the site which will be confirmed in a site inspection.
Before any reserved matters consent is granted, a site inspection is essential and an accurate representation of the topography and site environment fully presented.
English Heritage (as it then was) recommended in 2014 in relation to this site: “The design and materials used for the new buildings will affect the extent and nature of the visual impact of the development when viewed from the church. Therefore, ensuring that the design and materials reflect the local built character will be a critical part of the reserved matters stage. High quality, local materials should be used taking reference from the existing character of the settlement”.
As to materials, BDWH say nothing in their proposal. This lack of transparency is of concern and leads us to assume they intend to use materials similar to those in their recent developments at Centurion Fields and Bodington Hall.
Apart from the aberration of BDWH’s Centurion Fields development, the building material exclusively used in the neighbouring structures to this site (Adel church, rectory and stables, Adel Willows and Adel Mill) is Yorkshire stone. We would expect this development to be constructed in natural Yorkshire stone. BDWH will sell these houses at a significant premium because of the special location and the use of natural stone will not impede the commercial success of the development.
English Heritage also advised in 2014 that” the height of the proposed new dwellings along the west edge of the beck should ideally be 1.5 storeys…..” At the time of the outline application, BDWH stated that the sight might indeed include 1.5 storey dwellings. In fact, none appear anywhere in this proposed development and again English Heritage advice has been ignored.
As to character, BDWH claims (Design and Access statement 6.0) that it achieves a green standard. In fact, the proposed houses (according to the drawings submitted with the application) are just standard BDWH house-types in artificial stone with plastic windows which can be found anywhere in the UK. The only ”local” character they reflect is recent BDWH houses. The mediocre design of the proposed development is just not good enough for this special site and goes nowhere near meeting the English Heritage recommendations. This is not just a question of house design but also other factors such as inappropriate boundary treatments which clearly do not match their setting (contrary to the assertion at 6.0 of the Design and access statement). The overall design of the site shows no sensitivity whatsoever to the rural location.
It is particularly disappointing to note that whilst BDWH are instructing a firm of architects who designed an award- winning site at a similarly sensitive location (Church Fields, Boston Spa), they are apparently only using them for site layout of BDWH standard units. We believe BDWH should be required to allow their architects to start afresh and design something good enough for this special site.
The assertion by BDWH (Design and Access statement 6.0) that this proposal provides a “varied [housing] mix which would address local housing needs appealing to the needs of all members of the community.” is nothing short of disingenuous. 100% of the houses available on the open market under this proposal are 4 or 5 bedroomed. None is likely to be marketed at much under £500,000. Despite BDWH’s assertions, the development they propose will do nothing at all to address local needs.
Adel Neighbourhood Forum requested a Housing Market Needs Assessment in June 2014 (subsequently commissioned by Leeds City Council) which demonstrated a need for smaller homes suitable for down-sizing by older residents. This need is regularly raised by residents at Adel Neighbourhood Forum meetings. Adel Neighbourhood Forum and our local councillor have raised this as an issue with BDWH on numerous occasions over recent years but have been consistently ignored, with no open- market houses of fewer than 4 bedrooms being offered on the BDWH sites at Centurion Fields or Bodington Hall or under the current proposal.
As a result, older members of the Adel community have reluctantly remained in larger properties, meaning that these are not then available for younger families and those who do downsize have had to leave Adel. One such resident is our local historian and church warden. Our community is very much diminished by the loss of these people and this loss cannot be allowed to continue. It would make much more sense for the current proposed development to include small and medium-sized open- market properties for people to downsize into, thus enabling those who choose to, to remain part of the community, and releasing their family-sized homes for families moving into Adel.
Nor are there any bungalows as intimated in the application for outline consent. Bungalows are important not only for older citizens but also for people with disabilities.
The lack of smaller and mid-sized open-market houses in the proposed development also means there is nothing within the price range of any but the wealthiest young families.
Development which excludes older citizens, those of all ages with disabilities and young families cannot honestly be described as sustainable.
Development East of the Beck.
In common with Historic England, Adel Neighbourhood Forum (ANF) remains strenuously opposed to any development East of the beck because of its impact on the environment of the Grade 1 listed and nationally important Norman Church and its churchyard.
ANF was particularly disturbed by the decision of planning authority to disregard the advice of statutory consultee Historic England even before that advice had been received. We are aware that this has been the subject of an ombudsman decision. That decision raises further questions about which we are considering our position.
ANF previously objected to the location of playing fields and associated fencing to the East of the beck; that objection still applies, particularly when one takes account of the earthworks and terracing which would be required and which have never been mentioned by BDWH. These will have a significant effect on this sensitive landscape. This important issue needs to be addressed urgently as it will have implications both for the landscape and for the costs and quality associated with the creation of a school on this site.
The Forum is particularly concerned at BDWH’s attempt to introduce further development East of the beck. In the consultation documents submitted in 2016 for the outline planning application, apart from the playing fields, the only changes shown East of the beck were tree-planting and the construction of two ponds to contain possible floodwater.
Nature Conservation team suggest there is variation from outline approval and request no development on areas hatched in the outline plans. We understand that a pumping station is shown in the previously hatched area east of the beck which quite plainly constitutes “development” within the hatched area and has been introduced as a replacement for the SUDs as originally proposed
This is wholly unacceptable. If a pumping station is required it should be placed to the West of the beck in place of one of the proposed houses. ANF has been told by a Planning Officer that consent for the pumping station has already been given . If that is the case, that decision was made without consultation with the public or with statutory consultees and was therefore ultra vires and unlawful. It must be revoked.
No temporary site depot or buildings should be allowed east of the beck at any time. BDWH will have plenty of space on the site west of the beck, particularly given the availability of the land reserved for school buildings.
Footpath 17: proposed BDWH destruction of ancient path
This path (crossing the Southern part of the site from west to east) is known locally as the Corpse Way because it was used historically for carrying the dead from the west of the parish to Adel church. The path is ancient and marked at each end and near the beck with ancient stone stiles and steps.
The current proposals completely obliterate this ancient footpath west of the beck and are wholly unacceptable.
The line of the existing right of way is arguably retained if one crosses and re-crosses road, pavement and verge (although we doubt the accuracy of the route on BDWH’s plans), but there is a significant difference between preserving a bare right of way and preserving an ancient footpath.
It goes without saying that the ancient stiles and steps must be preserved. But the form of a proper footpath must also be retained. Previous iterations of BDWH’s proposals for this site have shown it as remaining a footpath with wide verges and scope for tree planting. This is what was recommended by the Landscape Team. The proposed substitution of a line along an estate road/pavement/verges is not acceptable.
We understand that BDWH have no particular proposals for this footpath on the eastern side of the beck. However, we understand that the Highways Department is imposing a condition that it should be converted into a 3 metre wide hard-surfaced footpath and cycle path. This ill-considered decision made without any consultation wholly ignores the universally- accepted need to maintain the rural character of the fields to the east of the beck. There is already a perfectly adequate surfaced foot and cycle route to the site via Centurion Fields. The path should be left as it is. In any event, this site does not extend as far as Church Lane. Leeds City Council only has jurisdiction to impose planning conditions in relation to the land which is the subject of the current planning application. Any condition requiring this footpath to be hard surfaced right up to Church Lane would be ultra vires and unlawful. It is therefore futile for Leeds city council to impose any condition in relation to any part of this footpath east of the beck.
Given that there can be no hard surfacing of this path, there will be no increased demand to cross Church Lane to reach it so there need be no construction of a raised pedestrian crossing in front of the church. In any event there should be no such urbanizing of the sensitive area in front of the church without the support of the Adel community following thorough consultation.
A large number of trees on the North Western part of the site are protected by TPOs. If developers are allowed to fell such trees, the whole concept of TPOs becomes pointless and Leeds City Council’s position totally undermined.
If TPO-protected trees have to be felled in order to enable access from Otley Road to this site, then the number of trees to be felled should be kept to an absolute minimum for that purpose only. It would appear from their plans and drawings that BDWH are also proposing to fell TPO-protected trees in order to get more houses onto the site; this is wholly unacceptable: BDWH should be required to build a safe distance around protected trees.
These trees are not only important in their own right; as the Nature Team has pointed out, they provide a valuable corridor for bats and other wildlife.
BDWH should be required to include in their planning documentation a plan of the site showing the location of protected trees and which of those trees they propose to fell, along with their justification for so doing.
As stated above, a shelter belt (of at least 10 metres) is essential on the Northern edge of the site.
As recommended by Historic England, shelter belts East of the beck screening the proposed development from the churchyard are also essential. ANF is disturbed to note that the current plans show far less extensive planting than shown on the plans submitted in the outline planning application.
Given BDWH’s poor record in relation to shelter belts and landscaping locally (they only planted the agreed shelter belt north of Centurion Fields under pressure of enforcement action) no construction on the site should be allowed to commence until the shelter belts have been planted.
The outline consent includes the reservation of land for a primary school. We understand that Education Leeds policies require any such school to be two form entry. This means that the school will have about 400 pupils and perhaps 50 staff. The land reserved for the school buildings has very little space for parking. It is well established that schools in North Leeds generate a huge amount of traffic. Much of the traffic for this school will attempt to park on the estate roads on this site. The proposed roads are simply not wide enough for this purpose and need to be made much wider and/ or to be provided with a substantial number of parking bays to meet the demands of school traffic whilst maintaining the ability of residents and the emergency services to use the roads easily and safely.
Whilst ANF believes that the proposed layout for the junction with Otley Road will work tolerably well for the journeys generated by the new housing on this site ( providing no-one is any hurry to turn right out of the site during rush hour), the planned junction will plainly be unable to accommodate the additional traffic generated by the parents of 400 pupils and 50 staff entering and leaving the school each day. Otley Road is already busy and will only become busier as a result of new developments in Bramhope and Otley. The junction as designed will be unworkable and dangerous if a school is built on this site.
ANF is also concerned that school traffic has the potential to cause congested and dangerous conditions on Centurion Fields, Church Lane, the Kingsleys and the Gainsboroughs.
If the housing mix included adequate provision of houses for older people, that would reduce the numbers of journeys to and from the site during rush hour.
If the school is built, it will almost certainly be built after BDWH have built and sold their houses. BDWH appear to have given no thought to the impact of school traffic. BDWH must not be allowed to leave a legacy of parking chaos caused by the construction of inadequate estate roads. The proposed development will fail to achieve a green standard for parking contrary to what is asserted at Design and Access Statement 6.0.
ANF endorses the proposal that no traffic other than emergency services should be allowed to enter the site via Centurion Fields. But this must be the position from the outset. No traffic (and especially no construction traffic) to the site should be allowed via Centurion Fields at any time. No good reason has ever been provided for vehicles from a number of the proposed houses to be allowed to enter and leave via Centurion Fields for a limited period.
The exceptional landscape and heritage factors mentioned above mean that a density lower than a suburban norm should apply to this site. BDWH are trying to cram far too much onto it to try to make up for the ruling that they may not build to the east of the beck.
Units 26-29 and 35 &36 should be deleted. They are ridiculously cramped- essentially shoe-horned into what should be the gardens of the surrounding houses. They are overcrowded in themselves and detract from the houses which surround them, both in terms of overlooking and outdoor space.
As an alternative, the inclusion of some smaller open-market housing for down-sizing or young families might free up some space. BDWH need only look at the housing at Eddison Walk in Adel to see how reasonably dense single storey development with private outdoor space can be achieved.
The inclusion of a Northern shelter belt, the retention of more protected trees and the construction of wider estate roads all mentioned above will also impact on density, but should not prevent BDWH building the 80-or so houses envisaged in the draft site allocation plan.
There is a lack of clarity as to what green space is to be provided within this development. Apparently there will be none amongst the houses themselves. That might possibly be acceptable providing adequate land is dedicated for green space/recreation to the east of the beck. Given that the land east of the beck cannot be built on, BDWH can afford to be generous with the provision of green space.
ANF does not accept that this site is an appropriate location for a new primary school. The two existing primary schools are also located in the north east of Adel and it is makes no sense to locate a third primary school in the same area. The two existing schools already generate a high volume of traffic from other parts of Adel which endangers children trying to walk or cycle to those schools. The building a third school which would generate similar traffic problems is not sustainable. There are better and more sustainable sites in Adel for a third primary school. In the public meeting, BDWH representatives appeared to concur with our belief the school should not be built on this site, putting forward HG1-60 Adel Reformatory Site as a better option. There has been no discussion about this possibility and we would see this site as inappropriate given its close proximity to Adel Primary School. However we recognise the rationale for the developer that they would see this as allowing more houses to be built on the Church Lane site.
As a result of current political policies as to who builds schools, it is not even clear whether a school will ever be built in this location in any event. This uncertainty causes real difficulties both for the developer and residents in relation to this site. Revocation of the decision that land should be reserved for a school on this site would remove almost all the planning problems associated with it:
- Inadequate junction on Otley Road to accommodate school traffic
- Serious congestion issues on Kingsleys, Gainsboroughs, Centurion Fields and Church Lane as well as dangerous conditions on Church Lane arising from conflict between cars parking and through traffic
- Heritage issues east of the beck. The school playing fields and associated earthworks and 2.4m fencing would not be required, the pumping station could be moved west of the beck. There would be no possible justification to urbanise the area in front of the church with 3m hard foot/cycleway or raised crossing
- BDWH could achieve their ambition of building 100 houses and meet objections relating to estate roads, density, design, housing mix, shelter belt and footpath 17
- Leeds City Council will not face challenges to the lawfulness of its decisions referred to above
Statement of Community Involvement
The document lodged by BDWH shows what scant regard BDWH has for consulting the Adel community about this development. It is the same document filed for the 2016 outline application. Again it does not include the appendix referred to, which was the document supposedly circulated in the “community”. For the record, that document was only circulated to about 10% of Adel households even though a development affecting the church and conservation area impacts on all Adel residents. It was not even delivered to the neighbouring houses on Centurion Fields. The document itself had no element of consultation. It simply stated that this was what BDWH were going to build, that a planning application would be submitted in the next couple of weeks and that any questions about it should be sent to BDWH.
BDWH had to be persuaded by our local councillors to hold a consultation event on the current proposals. BDWH did display its current proposals at Adel Stables on 5 June and the event was well attended. BDWH did make forms available for comment and many comments were made. However, BDWH has not acted on any of them and this leads us to believe that they were only going through the motions in holding this event.
Adel Neighbourhood Forum reluctantly now accepts that some housing development will take place on this site but are bitterly disappointed that BDWH have shown no evidence of being willing to listen to the local community or indeed some of the statutory consultees. As a result, the development is likely to be severely damaging to the local area as set out above. The view of the developers appears to be that Leeds City Council will not wish to face a legal challenge if it opposes BDWH proposals. Despite platitudes in consultation BDWH are continuing to show a determination to build a mundane standard of design similar to that in other BDWH developments across the UK and are replicating the adjoining Centurion Fields development which they themselves acknowledge has not been a design success.
We have consistently asked for CGI interpretation of how their proposed development will fit in the landscape. Their failure to do so suggests an arrogance that the impact on the local community is irrelevant. The design of the proposed development shows a determination just to cram as many maximum- profit houses as possible into the site.
Adel Neighbourhood Forum believes that these issues need to be rigorously challenged by the Council before consideration by plans panel, and that crucial information be provided so that appropriately informed decisions can be taken.
Ian Bond Chair
Adel Neighbourhood Forum
c/o 1 Park View Adel
Leeds LS16 8DF