Addingham Civic Society Responses to Planning Applications
Response to planning application 23/00829/MCF
Application Summary
Address: Horn Crag Quarry Off Fishbeck Lane Silsden Keighley West Yorkshire
Proposal: Re-opening of Horn Crag Quarry for the purposes of releasing a proven locally distinctive building stone resource
These comments are made on behalf of Addingham Civic Society.
The Society strongly objected to the earlier application principally on hydrological, environmental and traffic grounds. Re-submission 23/00829/MCF offers nothing new in respect to these issues:-
- The lack of a properly designed, comprehensive, site groundwater monitoring scheme, coupled with failure to address the increasing impact of "Climate Change", completely undermine the assertion that working will be restricted to 1m above water table. The entire scheme of working and restoration is dependent on accurately determining water table level, both during quarrying and following restoration. The effect of "Climate Change" on seasonal water table levels is not even mentioned!
- There is also a conflict between restricting quarrying to 1m above water table and creating a permanent water body in the southern part of the restored landform, as described in the "Schematic Restoration Document" and illustrated on the "Schematic Restoration Scheme Features Drawing". The creation of permanent open water will greatly increase the pollution risk to local private groundwater domestic supplies which are dependent on this aquifer. This needs to be properly clarified and addressed.
Reference is made in the application to the site being active in the 1850's and 1980's. In bygone times there were considerable numbers of very local small quarries and landfills. Over the years the vast majority of these have ceased operation because they are deemed unacceptable due to adverse effects on the environment. This is especially true for transport, which was often minimal undertaken by small lorries and carts. Today this task is performed by large tippers and articulated lorries. Whilst quarrying may have been acceptable back in the 1980's, this site is located too far away from the main road network, in a sensitive ecological rural environment and is thus incompatible with modern quarry practice.
Silsden does not need this further development, nor does Addingham need the additional lorry traffic. The Society therefore wishes to see this application refused.
Response to planning application 22/04094/FUL
Application Summary
Address: Marchup Height Silsden Road Addingham West Yorkshire LS29 0LQ
Proposal: Demolition of existing dwelling/stables, construction of residential development of 2 no dwellings with associated parking and construction of new stable block/barn
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These comments are submitted on behalf of Addingham Civic Society and concern the management of surface water and drainage on site.
- With the considerable amount of land associated with this property all surface water should be retained on site through the application of SuDS, both from the proposed semi-detached houses and from the stable block. None should enter the sewer and none should be discharged the beck.
- The application does not contain any detailed proposals regarding storage and disposal of manure and urine from the stables. All organic waste needs to be secured to avoid the ingress of rain water and prevent wash off of organic matter or subsoil transfer of nutrients into the beck.
Response to planning application 22/03295/MAO
Application Summary
Address: Land At Parsons Lane/Turner Lane Addingham West Yorkshire
Proposal: Outline application for residential development of land requesting consideration of access
These comments are made of behalf of Addingham Civic Society (ACS) which objects to this application on the following grounds:
- It is contrary to Addingham’s Neighbourhood Plan (NP) and the National Planning Policy Framework (NPPF). The NP states that development of Brownfield Land should be prioritised wherever possible and despite claims to the contrary in this application, there is potential undeveloped Brownfield Land within the village. Bradford Council in its Regulation18 Consultation proposed site AD8/H (8 dwellings) and ACS in its response identified “Motel Site, Ilkley Road” (12 dwellings). These potential sites also negate the “exceptional circumstances” argued by the applicant for removing the application site from Green Belt at this stage. the NPPF also requires that removal is done “through the preparation or review of the Local Plan” and this process needs to be followed.
- The NP states that proposed new housing should reflect “local need”, including truly affordable houses and social housing, particularly for young families and older people. No evidence of a “local needs survey” has been provided.
- This application is premature as Bradford’s Local Plan process has yet to be concluded, including the final allocation and distribution of housing numbers. ACS argued strongly in its Regulation 18 response that the proposed increase in Addingham’s allocation from 75 to 175 dwellings was unsubstantiated, unjustified and should be reduced back down to the previous proposed figure of 75. It will continue to strongly argue this point and if successful this proposed site may not be required.
- The final LP housing allocation for Addingham will be for a period of 15 years until 2037. ACS therefore sees no justification to override the LP process and grant premature planning permission for this site.
Whilst the reasons outlined above are more than sufficient to refuse the application, ACS has further comments on the application details:
- The “community involvement” process conducted earlier in the year fell short of the high standard claimed as ACS was not formally notified. If it had been it would have registered an earlier objection.
- The section dealing with traffic generation mentions a development of 14 dwellings in the text, but only 5 in the accompanying table. What figure does form the basis of the calculations? The Traffic Report states 9 two-way journeys, whereas the Planning Case Report states 8? In addition, the peak period of 15.00 – 16.00 chosen in the traffic generation modelling is unrealistic; a period from 15.00 – 18.00 covering both school and commuter traffic would have been more representative.
- Although the consultant’s ecological appraisal lists how the development could achieve net biodiversity gain on site, it is not borne out on the plans. Locations of native species hedges and wildflower patches are absent, as are suggestions on how gardens could be designed to be wildlife friendly.
- Proposals to divert surface water straight into public sewers are unacceptable. The consultant’s report about the unsuitability of SuDS should be examined closely. For any development in this location to be acceptable, surface water should be retained on site using permeable paving and rain water collection systems. If it is necessary to route surface water into nearby watercourses, retention tanks need to be constructed and be of sufficient capacity to ensure that runoff occurs as slowly as possible. Runoff water is not only dirty water adding pollutants to Town Beck, which is already in poor condition, but surface water running off rapidly causes surges in beck flow creating extreme downstream turbidity and damage to freshwater life.
- The NP explicitly requires that any new development proposals should be sustainable, incorporating measures to combat Climate Change. Developers need to demonstrate full adherence especially with reference to energy efficiency and carbon neutrality, for example ensuring all homes are ready for solar panels, are oriented to maximise solar receipt, are insulated to the highest standard and are heated by air source heat pumps. No reference is made to these issues in this application.