Miller Homes Response to Proposed Development
Miller Homes response to Kirklees Council re the proposed 4,000 home development at Sands Lane Mirfield / Ravensthorpe Road Dewsbury / Lady Wood is reproduced below for those people that may not have access to the Kirklees Council planning portal. Note Miller Homes' comment "...The site is controlled by Miller Homes and is able to be commenced in the short term, particularly as part of the site is an existing UDP housing allocation and part is safeguarded as Protected Open Land." The control that they refer to is exclusive options to purchase the land from some of the current land owners. Miller Homes have a registered option on the land currently owned by Saville Estates, and MF Strategic Land Ltd, a subsidiary company of Miller Homes, have an option on the land that is owned by Lees Hall Farm. Lady Wood, incidentally, is owned by our friends Kirklees Council.
DLP Allocations and Designations.
Event Name DLP Allocations and Designations
Comment by Miller Homes ( )
Comment ID DLP_AD8742
Site Allocation – Dewsbury Riverside (H2089)
Please add your comments here:
Miller Homes supports the allocation of the Dewsbury Riverside site (H2089) – Land to the south of Ravensthorpe/Lees Hall Road, Dewsbury
Miller Homes considers that Kirklees Draft Local Plan is sound.
Miller Homes supports the allocation of the site at Land to the south of Ravensthorpe/Lees
Hall Road, Dewsbury.
A Masterplan and Delivery Framework, accompanied by technical reports, are currently being prepared and will be submitted in due course, which will demonstrate the deliverability of the proposed scheme. The Vision for Dewsbury Riverside is to create up to 4,000 new homes in an urban extension to the south of Dewsbury, which will be a driver for this regeneration. The overall scheme will create sufficient economic impetus to deliver new roads, rail and pedestrian and cycle infrastructure, regenerate Dewsbury Town Centre and the Riverside and begin to positively connect the new homes to a realigned central core of Ravensthorpe which focuses on the Riverside and canal.
The Dewsbury Riverside project forms an essential element of the regeneration plans for
Dewsbury. The project aims to:
Deliver the regeneration and urban renaissance of Dewsbury and Ravensthorpe through
housing delivery of sufficient quantity to generate transformational change.
Rejuvenate Dewsbury Town Centre through creation of distinctive quarters, new
linkages and reconnection with the Riverside.
Re-focus the central core of Ravensthorpe on the river and canal side to optimise the
potential for economic growth through the re-use of existing natural assets.
Address all sectors of market demand and affordable housing need in south Dewsbury
Enhance the level of service provision and recreation and leisure opportunities.
Open up the potential for the delivery of improved rail, road and pedestrian and cycle
connections whilst extending and enhancing green corridors and linkages
The aim is to regenerate Dewsbury to the benefit of residents, employers, investors and visitors. The aim is to position Dewsbury as a quality place to attract new investors, employment opportunities and housing. The scheme aims to reduce future forecast congestion in Dewsbury and Ravensthorpe and deliver environmental improvements. It will reinstate Dewsbury as a place of economic and cultural activities in the Leeds City Region. In its wider context, the project will act as a catalyst for further investment and development across the Leeds City Region.
The vision for Dewsbury Riverside is to deliver transformational change and investment in this area and create a high quality gateway. The key element being to drive forward the economy in the region, enhance the residential offer, regenerate the Town Centre, improve the environment, create excellent transport connectivity and improved access to employment opportunities. The redevelopment of the area will accelerate the urban renaissance of Dewsbury and enhance the connectivity between the existing communities and the environment beyond. Through opening up access to the waterside and surrounding area, new active leisure opportunities could be provided within Dewsbury, promoting
healthy living and an improved environment. In addition, new river frontage would create enhanced land and property values and increased inward investment into the area and provide a catalyst for cultural activities. The renewal of Dewsbury would help the town to achieve its economic growth aspirations over the coming decades. Consequently, it would enhance the effectiveness of previous and ongoing investment to revitalise Dewsbury Town Centre, as well as providing the opportunity to help support and enable housing growth. In addition, the redevelopment of Dewsbury offers the opportunity to develop the town’s road network, improving connectivity and access to neighbouring communities and the Town Centre. It would also allow the coordination of public transport services in the area, enabling better access to employment opportunities across the District and Leeds City Region as a whole. Through such sustainable redevelopment, Dewsbury Riverside will deliver economic, social and environmental benefits and improve the quality of life for its local population and beyond.
Overview of the proposals
The proposed urban extension to the south of Dewsbury has the capacity for around 4,000 new homes, alongside community facilities, open space, new schools and local centre in order to create a sustainable community.
It is anticipated that in addition to the new local centre which has been located to tie into the heart of the existing Ravensthorpe settlement (to promote cohesion between the new and existing communities), there will be other smaller local centres, close to housing to support walkable neighbourhoods.
Existing green links and corridors will be extended through the proposed residential site and these will connect the green space infrastructure. The green links could also accommodate pedestrian and cycle routes, with an emphasis on safe routes to school. Sustainable urban drainage features will create further amenity for the open space as well as creating new habitat for links to promote diversity of wildlife species.
Development principles and benefits
The site is located in a sustainable location and is well defined by existing housing, roads and tracks. Part of the site is an existing UDP housing allocation and part of the site is Protected Open Land. The site is located on the edge of Dewsbury and Ravensthorpe, which provides shops and services, and also access to public transport facilities, with bus stops located on Lees Hall Road and Huddersfield and a train station at Ravensthorpe. As part of the scheme there is the potential to expand and enhance the bus routes and railway station.
Having concluded that the site is appropriate in locational terms for development, it is now relevant to assess it against the criteria for identifying allocations in the National Planning Policy Framework, which states that local planning authorities should identify sufficient deliverable sites to deliver housing in the first five years. To be considered deliverable, sites should be available, suitable and achievable.
The site is available, suitable and achievable and is deliverable in accordance with the Framework and represents a sustainable residential opportunity on the edge of an established residential area. Miller Homes intends to develop the site themselves which further demonstrates the site’s deliverability.
The site is controlled by Miller Homes and is able to be commenced in the short term, particularly as part of the site is an existing UDP housing allocation and part is safeguarded as Protected Open Land.
The proposed development can make an efficient and attractive use of the land. Although Green Belt land the site does represent an excellent opportunity for future housing and development. This site would allow housing to be delivered within an appropriate and sustainable location within Dewsbury. The development of this site would assist in creating a logical boundary to the Green Belt.
The site is located within a highly sustainable location on the edge of Ravensthorpe and Dewsbury. The site’s development would clearly accord with the emphasis set out in the NPPF, particularly concerning the need to make more efficient use of land. The site benefits from being located close to a range of services and facilities, including local shops, public houses, primary school and other community facilities. The site is also within walking distance to bus routes to Wakefield and Leeds and the train station in Ravensthorpe. Furthermore, the site is a suitable Green Belt change, providing a more logical, robust and defensible green belt boundary for the future.
It is considered that development on this site is achievable. There are no known constraints to its development.
It is considered that a safe and suitable accesses can be created into the site, and that the development would not have a significant detrimental impact on the local highways network. There is therefore no insurmountable constraint with regard to impact on local highways and access. It is noted that Transport Technical Paper (November 2015) indicates that proposed development can be accommodated on the network, which is supported.
Other environmental matters
A full suite of technical information has been undertaken and there are no known environmental constraints to site delivery.
Effective Use of Land
Although the site is greenfield, the proposed scheme will utilise and enhance existing infrastructure. Although the site is not previously developed it is currently under-utilised, part of the site is an existing housing allocation and part is Protected Open Land for long term development. The site is easily accessible and the site can be accessed through a number of routes, including off Ravensthorpe Road and Lees Hall Road and via the proposed Ravensthorpe Relief Road. The scheme is therefore making an efficient and effective use of land and infrastructure.
Delivering a Flexible Supply of Housing
The Framework requires Local Planning Authorities to meet their full objectively assessed housing need. The Dewsbury Riverside site will reinforce the housing supply for the short, medium and long term and address the Districts housing needs throughout and beyond Plan period.
A Positive Response to the Key Objectives of the Framework
The Framework sets out that the Governments key housing policy goal of boosting significantly the supply of housing and proactively driving and supporting sustainable economic development to deliver homes, business and industrial units, infrastructure and thriving local places that the country needs. The Framework explains that the supply of new homes can sometimes be best achieved through planning for larger scale development, such as extensions to towns, and creating mixed and sustainable communities with good access to jobs, key services and infrastructure. Sites should also make effective use of land and existing infrastructure.
The proposal responds positively towards national guidance
The site is appropriate for accommodating housing growth, being an expansion of an existing settlement.
The proposed site is accessible to existing local community facilities, infrastructure and services, including public transport.
The site has been assessed and is available, suitable and achievable for development.
The development of the site would provide significant benefits. The site would provide housing that would meet the needs of Kirklees. Therefore this site provides a unique opportunity in a sustainable location and without compromising the Green Belt function and purpose.
In accordance with the Framework Miller Homes has shown that the sustainable urban extension to the south of Dewsbury can deliver a mix of housing types and tenures and generate significant new benefits:
• Enable the regeneration and urban renaissance of Dewsbury and Ravensthorpe.
• Assisting in the provision of the Ravensthorpe Relief Road.
• Create significant new job opportunities and economic growth in the area
• Create the critical mass to assist with enhancing Ravensthorpe Station and
• Create a high quality housing environment.
• There is the potential to accommodate a range of housing types and tenure,
increasing choice and mix in the area and improving affordability.
• Delivery of new Community Hubs
• Delivery of landscape and environmental enhancements.
• Creating a robust and defensible urban edge and new Green Belt boundary
• No Change
Landscape Character Assessment – Land
South of Ravensthorpe Road, Dewsbury
Miller Homes objects to the approach towards the Landscape Character Assessment undertaken on the Dewsbury Riverside site.
Miller Homes considers that Kirklees Draft Local Plan is unsound.
Miller Homes object to the Landscape Character Assessment undertaken on the Dewsbury Riverside site - Land South of Ravensthorpe Road, Thornhill Road, Dewsbury.
TPM Landscape has reviewed the relevance of the Landscape Character Assessment prepared by Kirklees Council with regard to its suitability to be used to inform the decision making process as to whether certain parts of the landscape are more sensitive to change than other areas, and consequently whether there are parts of the landscape where development may be acceptable without significant harm to the landscape or where development should be avoided.
For information, it is worth noting that TPM Landscape is preparing a Landscape Visual Impact Assessment for the Dewsbury Riverside site, which will be submitted in due course.
Report Structure Generally
The approach to the report categorises sites on a ‘site allocation’ basis, rather than landscape character alone. With this approach, each site is subdivided into local landscape character ‘types’ rather than character ‘areas’. The consequence of this approach is that conclusions are drawn without regard to the relative importance of the landscape character area in the wider landscape context (ie a site might be subdivided into areas to ‘conserve’ or ‘enhance’ however it is not possible to understand the relative importance of these categorisations to the wider landscape).
Landscape Capacity Study
An alternative approach is to carry out a Landscape Capacity study which can be applied on a field by field basis rather than large swaithes of land in Landscape Character Assessment. In Landscape Capacity studies the landscape characteristics of an individual field are considered with relative importance against important criteria of the wider landscape and a sensitivity applied (High/Medium/Low) to each field. Such an approach has been undertaken for Doncaster Metropolitan Borough Council where conclusions are drawn on the capacity of individual fields to accommodate new development based on a combination of elements systematically defined for Landscape Character/ Landscape Value/ Landscape Sensitivity/ Visual Sensitivity
Where Landscape Character Assessments sub-divide areas into Landscape Units (such as this report), a conclusion needs to be drawn as to the sensitivity of the site/ area in relation to the wider landscape area, in order for it to be used as a tool to identify areas where potential development may have greater or lesser impacts on important landscape characteristics. Other reports of a similar nature (for instance Redcar and Cleveland Landscape Character Assessment) categorise wide areas (including sub-sets of different character units) into ‘sensitive’ or ‘restoration’ landscapes. It describes the important elements of the landscape to that area, and even in ‘sensitive’ areas it does not state that development should be avoided, just that it needs to be sensitive to the important elements.
In contrast, the Kirklees report identifies areas where the landscape management objective should be ‘creation’, ‘restore’ ‘enhance’ and ‘conserve’ at a relatively small scale and the criteria used to arrive at the conclusions is not clearly defined, and the relative importance of the conclusions to the wider landscape is not apparent.
In considering the important elements on the wider landscape the report references wider scale landscape character assessments for the area (National Character Area No. 37 and Kirklees Character Profile Area E7) but does not state what the important landscape characteristics of these areas are, whether the identified site has any of these characteristics, or how these characteristics form part of the identified assessment process of ‘creation’, ‘restore’ ‘enhance’ and ‘conserve’.
The conclusions in the report are drawn into a ‘matrix’ which could be misconstrued as being synonymous with a ‘capacity’ or ‘sensitivity’ study; i.e. an observer might be inclined to conclude from the report that areas identified as ‘conserve’ are equivalent to the highest sensitivity, where the landscape is particularly sensitive to change and change would significantly harm parts of the landscape. Areas such as this would normally form part of a designated landscape such as National Park or Area of Outstanding Beauty, or even a local landscape designation such as Special Landscape Area. The report matrix appears to confer a hierarchy which is not consistent with the
descriptions of the character types. For example: ‘Landscape Type 2: Traditional Farming’ is assessed as being a ‘conserve’ landscape which would suggest that these areas are the highest sensitivity which do not have any capacity to accommodate development, and yet are relatively ordinary fields adjacent to existing housing which would most likely translate to a ‘Medium’ sensitivity landscape.
‘Landscape Type 3: Open Plateau is described as being a ‘Strengthen and Enhance’ landscape where the underlying character is ‘weak with no defining structure, and where positive action is needed to create an improved landscape structure’. The conclusion states that ‘this landscape character area is of weak landscape character and declining condition, there is the case for strengthening the character of the area through sympathetic development which will enhance the area’. The conclusion drawn from this statement is that residential development of the upper hillside will be an improvement to the existing character.
The only criteria within the matrix where areas where there is opportunity for a radical change in the landscape (which a large urban extension would be) are ‘creation’ landscapes. There are no ‘creation’ landscapes within the study area, and if the report were accepted as being a tool to inform new development, then the landscape would not have any areas which were capable of accommodating new development, including areas which have already been identified by the local authority as ‘safeguarded’ sites. The only sites ever likely to meet these criteria are brownfield sites in urban locations, which is not helpful where a requirement for large areas of land to meet housing supply have been identified.
For the above reasons it is not considered that this Landscape Character Assessment forms a suitable tool to inform the decision making process as to which parts of the landscape are more sensitive or susceptible to change and should be ‘conserved’ and which parts of the landscape could accommodate development without significant harm. For this report to be a useful tool in the decision making process it needs to be developed to define and assess sensitivity to change for a wider scope of landscape (incorporating assessment of Landscape Value and Visual Sensitivity), or for a Landscape Capacity Study to be prepared which defines sensitivity on a field by field basis.
To overcome the objection and address soundness matters, the Council should:
• Review the Landscape Character Assessment undertaken on the Dewsbury Riverside
site and address accordingly.