Holme Valley Vision
Response to Kirklees Council’s Pulication Draft Local Plan – December 2016
We welcome the opportunity to comment on the November 2016 version of Kirklees Council’s Local Plan and recognise that account has been taken, in part, of the comments we made on the 2015 version. However, we have remaining concerns and would appreciate the chance to express our views to the Planning Inspector during the public examination phase of the plan’s approval process.
Our concerns are set out below and for ease of reference our previous response and our comments on the Council’s economic strategy are appended.
We consider the Local Plan to be unsound for the reasons given below. We also make suggestions about changes to the Plan that would bring greater benefit, make the Plan more sustainable and sound. We would appreciate the opportunity of providing further information to the Planning Inspector during the public examination.
We are particularly concerned about the basis for the projected number of houses Kirklees’ says it requires to meet population and job growth, the location of those houses, the impact they will have on the nature of the ‘places’ to which they have been allocated, the environment and the infrastructure, especially roads and drainage.
We believe a more realistic assessment of the economic conditions and labour market would reduce the jobs-related component of the housing needs assessment. We also believe that increasing the density and making greater use of mixed sites would reduce or remove the need to allocate land on the urban fringes and would avoid the disproportionate expansion of small settlements and the merger of others.
We continue to be concerned about the number of houses and the amount of land allocated for them in the Holme Valley.
We agree that there needs to be adequate housing to meet the future requirements of local people but fear the Local Plan will encourage larger, more expensive houses on green field and green belt land. These are likely to attract more people into the Valley and add to other problems, identified below.
The Local Plan identifies the challenge to growth by saying:
Generally high house prices create problems of affordability for local people.
We agree wholeheartedly with the brownfield first policy and recognize the need for smaller, lower priced properties to meet the needs of those wishing to remain in the Valley and downsize and those starting out in own homes. We would therefore like to see increased density on the allocated sites, more mixed use sites and generally across Kirklees, greater use of brown field sites, closer to town centres and existing concentration of housing.
We continue to be concerned about the incremental incursion on to green fields and green belt land, the way this outward spread will result in the further merger of settlements (particularly New Mill, Brockholes and Holmfirth) and the substantial changes to the nature of the ‘place’, particularly Scholes and Hade Edge.
We believe there are some inconsistencies in the way in which sites have been allocated and rejected. For example, there is no rational explanation to justify the change in the land allocation at Hade Edge, the increase in density in the site at Holmbridge and the reasons for rejecting some of the plots at Cinderhills PDLP 16 (H576) and (H577) H335 H314 and accepting the Vicarage Road plot (H47).
We note that, in the Local Plan, the housing density has been increased to 35 houses per hectare.
The average of the sites allocated in the Holme Valley is 27.33 per hectare. None of the sites is above 30 houses per hectare.
If the Kirklees density average were to be applied to all the sites in the Valley, the number of houses would increase to 1,474 from the proposed 1,151. If the density were to be increased to 30 houses per hectare, the number would increase to 1,264.
Higher density would encourage smaller, lower cost houses and reduce the need for such large sites in the smaller settlements.
There will be a mix of high quality housing which offers choice and meets the needs of all our communities including affordable housing. The challenges of an ageing population will have been addressed and a range of housing and employment choices available to attract and retain younger age groups within the district to build sustainable communities.
We would like to see a greater emphasis placed on the growth in jobs in sectors other than precision engineering and advanced manufacturing. We recognise the importance of these to the overall economy of the district and believe more attention should be given to other sectors that also offer potential for growth.
We also believe the Plan is old fashioned in its view of employment. This has led to the allocation of large tracts of land in the north of Huddersfield some distance away from where the bulk of the new housing development is expected to take place i.e. in Kirklees Rural.
We responded to Kirklees’ draft Economic Strategy in 2014 (a copy is appended) and still consider this to be an inadequate document. We further note that it has not yet been approved by the Council as a final policy statement. We are therefore unsure how the Local Plan can be predicated on an unapproved document.
The Local Plan states in Section 7.1 paragraph 7.6
The local plan will assist in the creation of new jobs in a variety of ways, most obviously through the allocation of new or prime land for employment uses, the safeguarding of existing employment sites but also by less direct means, for example, by promoting town centre regeneration, supporting local services in rural areas, enhancing visitor facilities, supporting expansion of education and training, and facilitating improvements to transport and telecommunications. It also seeks to maintain an attractive environment through the protection of the landscape and heritage assets which will encourage the tourism and inward investment from businesses that wish to locate here.
The land allocated for employment use in the Valley has remained the same for a considerable number of years. The main change has come from that land being released for houses. Very little action has been taken by Kirklees over the last 30 years to improve employment prospects in the Valley and we are surprised to see that a key business site currently used by around 40 businesses (Bridge Mills H50) has been changed from business to housing use despite previous representations. This change of use also places at risk one of the few remaining iconic mill buildings in Holmfirth.
The projected increase in employment rate, based on historic trends, evidence from Kirklees’ previous performance and current forecasts, in our view, is unrealistic and unattainable. We believe a figure of 70% employment rather than 75% is more achievable.
Despite the policy intent quoted above, we also consider that the predicted growth in jobs fail to appreciate the potential value from other sectors, particularly tourism, craft and home-based working (for example in the business and professional services sector) and micro and small organisations.
This growth, we believe will come from residents making life style decisions and or expanding their existing businesses to hopefully create more job opportunities for the Valley’s young people who are currently obliged to move away. The draft Economic Strategy is very quiet on how it will address these potential growth areas and Kirklees’ track record is light on evidence on this.
We carried out a survey of local businesses in 2016, the results of which will be available to the Planning Inspector at the Public Examination stage. This found that the growth in self-employment in the Holme Valley has occurred in Management and Professional occupations. A significant number of employees are in micro organisations and in “service” occupations, e.g. construction and property maintenance, motor vehicle and hair dressing i.e. dependent on the affluence of the area, as does the growing night-time economy.
Tourism is a significant growth area that would add value to the local and district wide economy. Evidence of this potential can be seen in the increased use of local routes by cyclists following the Tour de France and the Tour de Yorkshire visits. The associated publicity has cemented Holmfirth’s existing image as a nationally known and internationally renowned brand and tourist destination. Yet the Local Plan makes passing reference only to this and the Economic Strategy document is insultingly silent. It refers only to tourism assets in other local authority districts.
There are considerable opportunities where land allocation could be used to enhance the tourism offer. Examples include the improvements to the Sands and other recreation areas, the introduction of park and ride services, identification of areas where appropriate developments, such as mountain bike trails and new bridle paths, could provide new facilities for visitors and residents as well as contribute to the public health agenda.
The top five priorities identified in the recent HVV Business Survey were:
1 Encouraging entrepreneurs to come to the Valley
2 Improved employment opportunities, particularly for young people
3 Education and training for all
4 Visitor attractions
5 Affordable housing
We propose that, therefore, that more use be made of Valley bottom sites (accepting the need for flood risk mitigation measures) to provide land for mixed developments, such as that recently proposed for the Wash Pit Mill site in Holmfirth.
This will also make it more possible for people to walk, cycle or use public transport to get to work, shops and other services, which tend to be located along the main roads as well as reducing the need to use sites further up the Valley sides.
Other opportunities for greater economic activity in the Holme Valley and other rural parts of Kirklees exist A fuller consultation on the Economic Strategy would have enable these to be included in the Local Plan but hopefully, the Planning Inspector will include these in the final version. Examples include Agritech, urban farming and other measures to increase local food production. The amount of land used for animal farming has diminished but could be brought back to food production use rather than being lost forever to housing.
There is also a need for increased over-night accommodation in the Valley. This could be achieved through the development of more hotel and bed and breakfast beds, more camping and caravan sites and increased diversification of farmsteads.
Therefore, we would like to see greater appreciation of the value the Valley’s economy could make to the Kirklees District through the development of a more forward looking, adventurous rural and semi-rural vision. We fear that the Valley is seen by those determining the Plan’s contents as a residential dormitory, supplying homes for those who work in the Huddersfield and the North of the District, Wakefield, Leeds, Sheffield and Manchester. To us the Valley is a place to live, not just sleep. It is made up of a mixture of small communities, settlements and isolated buildings, varied activities, groups and facilities which is appreciated world-wide but sometimes, we suspect, not by those in the middle of Huddersfield.
Flooding and Climate Change
With the history of the Holme Valley, we would be stupid not to recognize the dangers of flooding. Monuments to the devastation of previous floods are part of our historic heritage. However, our main concern now is flooding caused by surface water run-offs rather than that coming down the hillsides into the becks and river.
The flooding in New Mill in November 2016 provided evidence of this risk. There is also evidence from local people about how the water table and watercourses have changed resulting in drainage problems, more saturation and flooding following building works. There is also considerable local concern about the adequacy of the sewage system and its ability to cope with addition domestic load and significant weather events.
We cannot see how adequate mitigation measures or the measures needed to cope with increased sewage and large volumes of water can be afforded or taken practically, if the number of houses proposed in the Plan is built up the Valley sides and on the hilltops. Even if developers contribute, it is likely that the required public funds will not be available.
We are also concerned about the loss of woodlands. Not only does this affect the visual nature of the Valley and the hillsides and wildlife habitats. Trees are known to be effective in flood prevention and as defenses and make a wider contribution to the reduction of greenhouse gases. If anything developments should include more tree planting than tree destruction and the protection of ancient woodlands be seen as important as the protection of listed buildings.
The Holmfirth Transition Town group will be commenting on this and other matters affecting the implementation of the Council’s policy intent. In our view, the policy is conventional rather than forward-looking and the contents of the Plan, particularly relating to traffic and land allocation are contradictory.
One of our most significant concerns is the increased impact traffic volumes will have on the Valley. The Plan fails to recognize the existing known traffic hot spots in Honley, New Mill and Holmfirth. It also neglects the difficulties causes by parking and traffic volumes on the main trunk roads running through the Valley.
We appreciate that congestion is not as great as in some other parts of the District but would like to point out the topography here is different. Steep sides, narrow Valley bottoms, narrow roads, with limited scope for widening, limited space of off road parking for existing houses and major trunk roads, characterize the Valley. The latter take the burden of cross-Pennine traffic when there are problems on the M62 and A629.
Local businesses in the recent Holme Valley Vision business survey reported their major concern was traffic level and the impact current volumes have on their trade. Increased traffic load will increase the negative effect.
Locating houses on the Valley slopes and hilltops does not encourage walking or cycling. The access roads are narrow, many with no footpaths and limited off street parking. Even though rural school routes are marked, parents have concerns about their and their children’s safety. Other locations are available for housing that would encourage cycling and walking, with the associated health benefits.
There are other safety concerns; not least, the effect of carbon emissions on climate changes. The adverse effects of air pollution have recently received greater attention and refer to The West Yorkshire Low Emission Strategy (dated November 2015) which aims to reduce all vehicles journeys in urban areas by 10% and says:
The local authorities in West Yorkshire encourage the uptake of active travel through the provision of infrastructure and behaviour change programmes, this work has seen a steady increase in the number of people choosing to walk and cycle for shorter journeys in West Yorkshire.
The practical implications of this must include the location of houses near to jobs and other services so people are able to change their behaviour. The current Local Plan allocations give people little choice in their mode of transport.
We note that Kirklees is committed, in Section 6 of the Plan, to:
Allocating land for new development in locations and ways, which reduce greenhouse gas emissions particularly by identifying urban extensions, which have the scale and capacity to benefit from low carbon and/or decentralised energy solutions.
In Section 5.4 paragraph 5.10, a challenge to growth is:
Limited opportunities for people to work and shop locally, more people in this part of Kirklees commute longer distances to work.
We are puzzled by the fact that the allocation of land for housing is located away from the land identified for employment growth and other services. The housing allocated land is also, in many cases, remote from public transport routes and would be difficult for pedestrians and cyclists. The plan’s proposals therefore, appear to contradict the Council’s policy intent.
The Local Plan is laudable in its intent by saying in Section 4.2:
The local character and distinctiveness of Kirklees and its places will be retained. The natural, built and historic environment will be maintained and enhanced through high quality, inclusive design and safe environments, opportunities for play and sport, the protection and enhancement of green infrastructure, minimisation of waste, enhancement of distinctive and contrasting landscapes, tree and woodland protection, opportunities for local food growing, the enhancement of biodiversity and geodiversity and the protection and enhancement of heritage assets.
Local residents and groups believe that the Plan, as it stands will contradict this policy imperative.
Work done as part of the development of the Holme Valley Parish Council’s Neighbourhood plan described the nature of the Holme Valley:
The Valley is narrow in width with a river bottom and steep valley sides affording very large views. It is possible to see for miles, taking in the Valley floor and the tops of the moorland from one vantage point. And there are loads of such vantage points around the Valley.
The sides of the Valley display examples of human endeavour created over centuries – the dry stone walls, the tree plantations, the isolated dwellings and farmsteads and clusters of houses nestling in the cloughs and clinging to the sides of the hills and in more recent times the electricity pylons and wind turbines The Valley bottom is home to the industrial past, the confluence of the waterways and the developing present.
The size of the Valley keeps human interventions in proportion. They are miniscule in comparison to the magnificence of the Valley.
Large scale developments in the form of housing and industrial estates will ruin the Valley and make it the same as many others around the country. Such development will stop the Holme Valley being stunning and special.
Developments that are appropriate are those with mixed use, different types and sizes of building (a muddle or a mess to some modern eyes) in stone with stone roofs and chimneys. Footpaths are narrow, steep, cobbled and winding. Trees are stunted and bent, hedgerows are hawthorn, nettles, brambles, docks and thistles. Boundary walls are stone.
Tree planting (thickets and woods, not forests) would help to mitigate the flood risk. Housing development up the hill side would increase it. Housing is disjointed. Joining up the settlements would ruin a key characteristic of the Valley.
The communities are small and neighbourly. They can be, as they have things in common – football clubs, small primary schools, pubs, church and community halls and shops where people meet up. If there were buses, these would include bus stops.
People do things together because they care and they can. They speak and help each other when it snows. They know who is isolated and struggling and who lives alone. The postman and milkman still call and there are window cleaners.
The Holmfirth Conservation Group has recently funded and conducted an appraisal of the Holmfirth Conservation Area. There is concern that, for example, features such as pumps, troughs and wells could easily be sacrificed for road improvements and the mixture of building types, many early Victorian, scattered in the Valley bottoms and on the hillsides could be dwarfed by modern estates and ribbon development.
The results of the Conservation Group’s appraisal will be ready by and available for the Planning Inspector at the Public Examination.
We fear that the effects of the Local Plan, increasing the population above 30,000, merging settlements, changing small rural communities into urban environments, increasing traffic and the risk of run-off flooding, failing to increase economic activity and neglecting climate change, will alter our Valley for ever and mean that it will no longer be the place that is renowned internationally for its stunning beauty.
Unsustainable pressure will be placed on local infrastructure and the existing support facilities will require development, which even if they are part funded by developers through the CIL there will still be a need for investment from the public purse. We appreciate that other parts of the District have far greater need than the Holme Valley and have no wish to compete with them for scarce resources. However, we cannot see how the local need for essential services will be met without some publicly funded investment.
Some of the sites identified for housing will have an adverse effect on local wildlife and flora, will add to light pollution and compromise the vistas across the Valley.
Above all the aspect of the Plan that concerns us the most is the impact such significant growth in house and population numbers will have on the nature and identity of our community. We do not think the Local Plan is sustainable and the character and heritage of our Valley will be changed for ever.
We agree there is a need for more housing, particularly smaller properties, suitable for those entering the property ladder and those wishing to downsize. We do not agree with larger scale developments, comprising mainly of semi-detached and detached houses. We want to see mixed development and action to develop the local economy so people are able to live nearer their work. We want to reduce emissions and reverse climate change and we want to share the Valley with others so we can continue to make a positive contribution to the overall well-being of Kirklees.