Holme Valley Vision Kirklees Local Plan

Kirklees Local Plan Response to the policies and strategies by

Holme Valley Vision Network

CONTENTS Summary

3

1

Introduction

6

2

Place shaping

7

3

Economy

9

4

Housing demand

15

5

Transport

19

6

Carbon Emission Reduction

23

7

Visual appearance across the Valley

24

8

Quality of life and attractiveness

26

9

Green belt

27

10

Neighbourhood Plan

27

11

Rejected sites

28

12

Vision for the Holme Valley

28

13

Conclusions

30

2

SUMMARY This document has been compiled by the network of people and community groups in the Holme Valley who work together on the Holme Valley Vision project to raise issues of concern regarding Kirklees Council’s Local Plan. The document is therefore focused on the high level policy end of the Local Plan and does not comment on site specific proposals. This is not to say that some of the site proposals do not cause us concern: this is not the case.

However, we see that it is far more productive for us, the people and groups who are involved promoting the Holme Valley through the Vision project together with the Council and the Holme Valley Parish Council, to comment on the policies and strategies outlined in the Local Plan. At this stage, we are of the view that the Local Plan fails to address some of the issues facing the Valley and indeed would, if implemented as it stands, be detrimental to some of Kirklees’ strategic imperatives.

Our reasons for drawing this conclusion are set in below.

We appreciate that there is a timescale to which the Council needs to work to satisfy the Planning Inspectorate’s requirements for the production of a Local Plan that is sound and ensures that the developments that take place over the next 15 years are sustainable. We would therefore appreciate the opportunity to work with the Council and Parish Council to find ways of addressing the areas we consider fail to address the issues. These, for ease of reference are listed below: 1.1

We ask the Council to specify how it will be “sensitive to the local character of the places which make up Kirklees” and what action it intends to take to ensure that the distinctive characteristics of the Valley and its component towns and villages are maintained while approving appropriate and needed developments.

1.2

How does the Council propose to address the failure to include the countryside and tourism as an economic asset?

1.3

Will the Council work with the Holme Valley Vision network and local businesses to revitalise the Valley’s town centres and ensure they remain vibrant and viable?

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1.4

Will the Council discuss further how the economy of the Valley could be further developed for the benefit of all?

1.5

Will the Council give more detailed consideration to how a more diverse housing mix can be achieved in the Holme Valley and how the points raised in the report might be addressed?

1.6

Will the Council engage in discussions so that local concerns about existing transport issues, likely increases to traffic volume, infrastructure provision and the lack of realistic mitigation plans can be fully considered?

1.7

Will the Council explore possibilities with local people how carbon reduction might be achieved? We do not think that the Council should rely on private developers to ensure that adequate action is taken.

1.8

We believe a more proactive approach is required to protect the distinctive features of what is important to the Valley in terms of visual amenity and would like to see the Local Policies strengthened through the development of strong planning development briefs, that will promote quality development for individual sites. Will the Council discuss with us in greater detail what this might entail?

1.9

The Holmfirth Conservation group is about to start an appraisal of the Town of Holmfirth Conservation Area, in partnership with the Parish Council and other interested parties. Kirklees Council is invited to be part of this.

1.10

We would appreciate clarity from Kirklees regarding its interpretation of the National Planning Policy Framework regarding the Green Belt.

1.11

We await information from the Parish Council about its plans for consulting local people and groups and look forward to co-operating on the Neighbourhood Plan’s development. However we believe that not all of the matters raised here can be dealt with in the Neighbourhood Plan as some relate to Kirklees wide policies and indeed Leeds City Region’s policies.

1.12

We would appreciate the opportunity to compare with the Council the merits of some of the rejected sites with those put forward in the local plan as we believe that some of the former could be less detrimental than some of the latter.

4

1.13

Finally, we invite Kirklees to work more closely with us and other parts of the local community to deliver the vision.

5

1

INTRODUCTION

1.1

The Holme Valley, as defined by the Civic Parish Council boundaries, is much more than a residential commuter belt. It is enclosed by impressive hill ranges, has a rich history and comprises a number of towns, villages and settlements, each with its own identity, centres, schools and local services.

The Holme Valley is the base for significant economic activity, much of which is not visible. It also has some social problems and people who are isolated; these are masked by the perception of middle class wealth.

The Holme Valley Vision project 1 aims to make the Valley a great place to

1.2

live and work, and to visit. Three surveys, of businesses young people and residents, were conducted in 2012 and 2013. Copies of the results have been made available to Kirklees Council and will be provided again if this will be helpful. Around 4,000 residents, young people and businesses responded and expressed their concern about keeping the environment clean, encouraging more businesses and support from entrepreneurs to increase job opportunities, and from young people in particular to improve local bus services.

1.3

In addition to the survey results, the people involved in the project have drawn on their experience, independent research and knowledge of the area in making this response to Kirklees’ draft local plan. The document has also benefited from input from a cross section of local residents. Their contribution is much appreciated and demonstrates how much they care about the Valley and its future.

1

The Holme Valley Vision project has been devised by a network of local groups, businesses

and individuals who care about the future of the Valley and want to see it develop in ways that are appropriate and sustainable while retaining the qualities that make the area so special.

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1.4

We have previously responded the Economic Strategy consultation document and look forward to doing so again when it is revised. We also look forward to a continued dialogue with Kirklees Council’s Planning Department, other officers and Holme Valley Parish Council so we can work together to develop the Valley in a way that meets local people’s needs and visions as well as satisfying Kirklees Council’s strategic imperatives.

2 2.1

PLACE SHAPING The plan identifies a key role for local authorities as place shaping which includes amongst others “building and shaping local identity, representing the community, working to make the local economy more successful and understanding local needs and preferences and making sure that the right services are provided to local people”. We find little evidence of how these laudable aims are to be achieved in the Holme Valley, and seek further discussion to provide clarification.

2.2

The Holme Valley is clumped for administrative convenience under the Kirklees Rural locality. The locality covers the rural parts south of the Huddersfield conurbation and each distinct area has very different characteristics and its own communities of interests. We seek to work with these where our interests coalesce and respect each other’s differences.

2.3

The plan recognizes that the settlements in the Upper Holme Valley often join together. We wish to ensure that there remains distinction between settlements to avoid the perception of ribbon development and urbanization as we believe that these will have a negative impact on both the quality of life and the visitor economy, as discussed further below.

2.4

The topographical challenges are recognized but these are key parts of the Valley’s attractiveness and the visual impact of developments, as seen from the other side of the narrow valley must be included as a planning consideration.

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2.5

We are puzzled by the failure to mention the River Holme and its tributaries in the strengths and find it an interesting omission which we request is rectified.

2.6

The poor quality of the Holme Valley’s transport connections should be seen as both an opportunity as well as a problem. As there is limited scope for improvement, the only realistic way of dealing with traffic congestion is to reduce the volume of traffic on the roads. This would also contribute to carbon reduction targets. We would like to see greater emphasis being placed on this aim and more consideration given to the reasons why people have to rely on their cars. The provision of services and jobs in closer proximity to housing is one way: the converse i.e. the provision of houses closer to services and jobs is another way of reducing the reliance on cars.

2.7

More focus needs to be given to the type of housing as well as the number of properties. The comparative high levels of income mask the distribution of household wealth and composition and the comparative high house prices is seen as a main contributor to the dysfunctional population profile.

2.8

The loss of employment land to housing is referred to in the Employment Market Strength Assessment final report. This may not necessarily be a problem nor a challenge to growth if greater cognizance were paid to the changing nature of employment in the Valley.

2.9

There is no mention of the characteristics of the area or the factors that people seek from their community. We see that these are major factors in place shaping and the quality of life for local people. We accept the plan is about land allocation and agree it “cannot resolve some of our social/community issues on its own� but we request that more consideration is paid to the nature of the place as well as its physical make-up.

2.10

For example, some of the housing land allocations, particularly in the outlining villages (e.g. Scholes and Holmbridge) are of such a size that, if the proposed number of houses were to be built, the character of the village would 8

be fundamentally altered in ways that may not be acceptable to existing residents. Some villages e.g. Holmbridge, have already seen a considerable amount of housing development in recent years.

2.11

We ask the Council to specify how it will be “sensitive to the local character of the places which make up Kirklees” and what action it intends to take to ensure that the distinctive characteristics of the Valley and its component towns and villages are maintained while approving appropriate and needed developments.

3 3.1

ECONOMY Holmfirth is an internationally known brand, renowned for its stunning countryside and character as well as being the setting for a long running television series. Indeed, the very reason for the series to be based here was due to the visual attractiveness of the area. The duration of the programme and its international popularity still draws visitors. More recently, the area’s programme of festivals and other attractions have provided more contemporary visitor draws and global exposure has again been gained by the use of the Holme Moss climb in the Tour de France. We are puzzled by Kirklees’ failure to market the brand as part of its tourism strategy.

3.2

It is no surprise, therefore, to find that one of the main types of economic activity in the area is tourism. The last known information about the value of the visitor economy was reported in a paper presented to the Valleys Area Committee Tourism Task Group “Kirklees’ visitor economy is worth an estimated £300 million supporting 8,000 jobs annually. Tourism (including hotels, camping sites, restaurants, bars, travel agencies, libraries and museums, and sporting and other recreational activities) is a particularly important economic driver to The Valleys, with Holmfirth being the lead destination and key driver for tourist footfall across Kirklees. Approximately 70 accommodation businesses operate in the Valley, plus hundreds of other

9

attractions, retail and food/drink establishments that rely on trade from visitors to survive.”

3.3

Neither the Economic Strategy nor the Employment Market Strength Assessment Final Report pay any attention to this key sector, which is surprisingly short-sighted given the Local Plan is intended to endure until 2030.

The Economic Strategy prefers to focus on attractions beyond the Local Authority area and the Employment Market Strength Assessment final report makes no mention at all of tourism. Buoyant tourism in the Holme Valley would have a ripple out and positive effect for the whole of Kirklees. We would like to see proposals to improve access to land in the Upper River Valley to create more opportunities for organised sport and informal leisure. As well as having economic benefits in the form of increased tourism and associated economic activity, there would be health and welfare benefits.

3.4

The failure to include the countryside and tourism as an economic asset is of great concern and we ask that this omission is remedied. We consider that, without a cohesive tourism strategy to support the great festival, sports and leisure opportunities, the tourism potential of the Valley will be severely limited. (The development of attractions in the countryside would have benefits for residents and visitors alike and would include promotion of increased physical activity as well as a greater appreciation of the environment and heritage.)

3.5

Holme Valley Vision’s analysis of databases bought to provide contact details for the 2012 survey provides a rounded profile of the Valley’s economy. We accept these are possibly somewhat out of date but probably under-report the numbers, particularly of small traders, not registered as businesses. These databases show that there are 900 businesses in the area accounting for over 6,000 employees. (Information obtained from the Kirklees Observatory’s web site gives the number of employees in the Valley as 6,900.) A significant

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proportion of these companies (nearly three quarters) are micro or small enterprises.

3.6

Our data base, compiled from sources of information available to us, including the purchased databases, shows that over 100 businesses are classed as professional services, with a similar number in the construction business and in retail. Other main employing sectors are hotels and restaurants followed by hairdressing, the motor trade wholesale, primary schools and health and social care. There is scope for growth given the right levels of support, facilities and encouragement.

3.7

We believe that there are also opportunities for new enterprises to start up to complement the existing business stock, fill gaps in the tourism offer and develop into new areas of economic activity to meet changes in socioeconomic trends.

3.8

Some businesses are located in areas that would be better suited now to housing and or mixed use, for example the transport company in the middle of Honley. Consideration should be given to ways of encouraging relocation to more appropriate locations.

3.9

Key to grasping these opportunities are improvements to broadband services, collaborative approaches between businesses, the local authority and residents, creative problem solving and innovation.

3.10

Specifically, we request attention is given to the following points:  The allocation of land as being suitable for employment purposes is predicated on the notion of people working in business premises. The Nomis web site, provided by the Office of National Statistics, shows that, in 2011, 14.5% of the working age population in Holme Valley South was self employed and 11.8% in Holme Valley North (including Meltham) compared to 9.7% in Kirklees and 10.4% in Great Britain. This significant

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mode of employment for a significant proportion of the Valley’s population cannot be ignored. It is of great concern to find that the Employment Market Strength Assessment Final Report does not recognise the important contribution made by the self-employed to the local economy. The failure to recognise this increasing mode of employment casts doubt on the credibility of the report.  The development of mixed use sites may be more appropriate with the provision of small office units. The Employment Market Strength Assessment Final Report considers that South Kirklees, being predominantly rural, would be more suitable for local demand. This appears to ignore the businesses in the area that already trade nationally as well as internationally. The authors appear not to recognise the potential for greater world trade through e-commerce or the increasing importance of home working and those working from home. The provision of high quality fast broadband and the availability of appropriate office space is key to developing these modes of working. Decent and modern office space would also encourage more people to walk or cycle to work and contribute to increasing town and village centre footfall by having more people around in the Valley during the day. It may also encourage more start-ups and help the self-employed population to expand locally and grow their companies thus creating more employment opportunities.

Mixed use sites may also encourage developers to build smaller and lower cost dwellings as well as increasing the number of homes on a given area of land.  The lack of beds has long been accepted as a weakness in the Valley’s tourism offer. It is therefore surprising to find a lack of emphasis on the use of agricultural land for camping and caravan sites. Careful thought would need to be given to location to avoid excessive disruption to local residents and detracting from the attractiveness of the landscape.

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 There is also an acknowledged need for more hotel accommodation; we would like to see the identification of an appropriate location for such a development and the active recruitment of a developer. As well as increasing employment opportunities in their own right, a new hotel would provide custom and other facilities for local businesses.  We understand why the Borough’s position in relation to the Leeds City Region is stressed, but from a tourism perspective, strengthening the relationship with the Peak Park is important as is recognizing the proximity of the Sheffield and Manchester regions’ populations as target tourism audiences. Attention is given to the neighbouring district council areas as competitors. They are also markets which local businesses can serve and residents who make use of the Valley’s facilities. (It should also be remembered that many local people travel to these cities and act, in effect, as ambassadors for the Valley.) The Employment Market Strengths Assessment Final Report states that “With its location between Leeds, Manchester and Sheffield within one hour, Kirklees has a population of over 8 million people”. These are all potential visitors!  Tourism also has significant opportunities for expansion as there are many known gaps in the current offer, particularly accommodation and the use of the outdoors for leisure, recreational, tourism and health gains. The Local Plan nods in these directions but does not give the Holme Valley a strategic place in achieving the Council’s economic objectives.  The River 2015 project has ambitious plans for opening up the River Holme to give access to the river and to create a footpath, cycle way and bridle path from the upper reaches to its junction with the Calder in Huddersfield. This includes environmental works, and infrastructural developments as well as educational, cultural and heritage projects. The benefits for local people will be considerable as leisure, health and wellbeing interests will be met; it will also enhance the visitor economy offer.

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It is understandable that the Local Plan makes no reference to this project as the River 2015 charity is newly established but the revised Plan should remedy this omission.  Holmfirth was defined as a Specialist Town by the High Street 2020 project which found that while it was doing alright, it could do better.

One of its distinctive selling point is the quaintness and character.  The area has a rich heritage grounded in, but not restricted to, the district’s textile origins. Much more than is being proposed in the Plan could be done to recover the lost history and make much more of it in promoting the Valley as a place to visit, live and do business. There is, therefore, potential for the development of a local museum and or arts and cultural centre.  Holmfirth town centre and beyond is defined a large conservation area with nearly 40 listed buildings and is considered to be risk by Historic England. Other village centres, especially Honley, have the same distinction but have no current appraisal. The lack of management plans for these areas is a serious omission from the Local Plan. We consider that this deficit should be rectified so that due consideration to conservation imperatives can be given to planning applications.  There are currently five public buildings in the middle of Holmfirth whose future is uncertain. Four of these (the Market Hall, Civic Hall, Library and the building currently housing the Tourist Information Centre and Parish Council officers) have significance from historic and functional perspectives. Granting any application for change of use should give consideration to the overall contribution these buildings could make economically as well as socially.

3.11

We ask the Council to work with the project and local businesses to revitalise the Valley’s town centres and ensure they remain vibrant and viable.

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3.12

Similarly other aspects of the Valley’s tradition could make a significant contribution to the overall economy of Kirklees. These include its rich cultural tradition, the growing programme of events and festivals, the night time economy which attracts people from a wide area, the interest in arts and crafts as well as the value of the stunning and widely-known countryside.

3.13

We also consider that the proposed Farnley Country Park would have a beneficial and complementary effect on the Valley. It would also provide opportunities for local businesses to develop and be started.

3.14

We conclude that promoting the economic activity of the Valley would have other sequential benefits as people, encouraged to stay longer through the provision of more accommodation and offerings would visit other parts of the district. Kirklees Business and Economy Team estimates that two people spent over £36 each per night they stay. An increase of only 3,500 nights would increase income to the local economy of over £250,000. This would be additional to any increase in business rates raised.

3.15

We would like to discuss further with the Council how the economy of the Valley could be further developed for the benefit of all.

4 4.1

HOUSING DEMAND We understand the Council’s need to increase the housing stock. However, we note that of the 20,000 new homes over one quarter of them are allocated in the rural area of Kirklees. We are not convinced that the likely population growth will occur in the areas where the housing expansion has been allocated. We would therefore like to work with Kirklees to model population predictions more precisely before the final version of the Local Plan is agreed.

4.2

The Local Plan is silent on the type of houses that will be built on the land allocated for them. It discusses design and has based the numbers needed on predictions about population growth in the local authority area. It does not

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appear to have made a finer analysis of housing market demand or considered the impact developments would have on the local area. In effect, it is a plan for building houses rather than developing communities. As mentioned about the number of houses proposed in some of the outlying villages, such as Holmbridge and Scholes would destroy the intimacy these communities currently enjoy.

4.3

The Kirklees Observatory profile provides some interesting statistics about the demographic make-up of the Holme Valley.

4.4

The population age profile is distorted by the proportion of older people. This is neither healthy or sustainable. We believe that the development of this profile has, in part, been as a result of planning policy and decisions, which has resulted in the construction of larger, higher priced dwellings. The consequences of this can be seen in the mean house price and the make-up of the housing stock. The Civic Parish profile taken from the Kirklees Observatory shows that:  33% of houses are detached compared to Kirklees’ average of 20% and only 5% are flats compared to Kirklees’ average of 11%.  13% of the population are aged 16 - 29 compared to Kirklees profile of 20%;  18% are aged 30 - 44 compared to 20% in Kirklees  31% are aged 45 - 64 compared to 25%  19% are aged over 65 compared to 16%. The number of people in this last age band will increase as the 45 - 64 group ages.  The number of school children and younger (0 – 15) represent 19% of the population compared to 20% in Kirklees

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4.5

The Kirklees Observatory shows that 302 of the 334 school leavers aged 16 18 are in full-time education. This means that this number is “bused out” of the Valley each day as there is no local post-16 education provision.

4.6

The population of the Valley has grown from around 25,000 in 2001 to 27,278 in 2011, an increase of 9%. Much of this, it can be argued is as a result of house building and new people moving into the area. The Local Plan proposed a further increase of around 3,000 people in the Civic Parish area (1,252 houses x 2.35 residents). This would amount to a population of around 31,000. No consideration appears to have been given to the impact such a growth would have on the nature of the Valley. Moreover, the population increase statistic has been applied across the whole of Kirklees assuming homogeneity. In reality population growth in the next 15 years will depend on the current age profile.

4.7

We ask the Council to give more detailed consideration to how a more diverse housing mix can be achieved in the Holme Valley and address the following:  While the Local Plan allocates land for employment, the number of jobs predicted will not cater for the increase in population. Closer examination shows that the Local Plan contains provision for more employment expansion in areas to the north of Kirklees than in the south and more housing proportionately in the south than the north. It follows that there will be an increase is commuting and more traffic on the roads. The Infrastructure Delivery Plan allocates resources to deal with difficulties in the north, such as the need for road improvements, but does not address the problems the Local Plan will cause in the south. The effect of the Local Plan will make the issues identified worse. We would like to see a greater balance between the location of jobs and provision of housing.

Town centre developments in Huddersfield, Dewsbury and Batley should be more actively considered.

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 That said, we accept that more housing is needed in the Valley but we would like to know more about the Council’s proposals to ensure that the traffic load in the Valley is reduced, adequate infrastructure provision is made and sufficient jobs for the increased population are provided.

Without such provision the Local Plan cannot be deemed to be sustainable.  How can appropriate provision be created so that 16 year olds are not forced to leave the Valley to continue their development and education?  What more can be done to promote the Valley as an attractive place for younger people to live?  In our view, as discussed above, the allocation of sites for mixed use will facilitate the generation of more of the type of jobs already found in the Valley. We also consider that this action will facilitate the construction of lower cost houses in locations closer to the town centre and Valley bottom, thus enabling more people to walk and cycle and increase footfall.

Will the Council allocate more land for mixed development? Doing so would enable some of the more contentious sites allocated for housing to join the list of rejected sites.  What can the Council do to mitigate the danger of more of the same type of housing being built if choices over type of development is just left to the market? We understand why developers go for the easiest sites and greatest profit. Surely planning is about more than giving permission to build. There is a significant lack of affordable housing in the Valley; there is a need to keep in and attract younger people to the Valley - we believe this can be achieved through the provision of jobs, facilities and houses that will attract them.  How can the Council encourage more lifetime homes to allow the members of the ageing population group to downsize if they so choose?

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More provision for smaller dwellings, we believe, will free up existing larger out of town centre properties as well as reducing the load on the care and health sector.  Does the Council include consideration of the effect education and health care provision have on employment? These two sectors are already major sources of employment in the Valley. Planning to increase services for young and older people can only have wider benefits.  What consideration will the Council give to the impact the proportionate growth will have on the nature of the Valley? There is a significant risk of settlements merging and villages becoming part of the larger conurbation.

If this happens, it will have a visual impact as well as sociological impact on the Valley. We are very concerned about the way in which population growth will impact on the nature of the Valley and the quality of life of existing residents. We intend to work with the Parish Council during the development of the Neighbourhood Plan to ensure this consideration is central to it and would welcome the opportunity to discuss this in greater depth with the Council.

5 5.1

TRANSPORT We accept that some parts of Kirklees experience significant traffic problems far worse than in the Valley. We note, however that in the Local Plan, the Council encourages development that is strategically placed along the core routes at the same time as seeking “to improve and maintain, reduce congestion and … encourage a modal shift from private car use”.

5.2

The Local Plan locates the A616, A6024 and A625 (sic) in the Kirklees road network. None of these roads are adequate for the current volume of traffic at peak times, never mind an increased load. They do not encourage the use of other modes of transport: their narrowness is not attractive to cyclists or walkers. Alternative routes, for example along the river corridor would need 19

to be provided. The Local Plan does not promote this in a positive way and we cannot see private developers investing in something that would not provide them with a direct return.

5.3

There are three significantly difficult junctions on the Valley road network: the middle of Holmfirth, Honley Bridge and New Mill Square. In addition there are problems on the arterial roads out of the centres, particularly the A6024, A635, B6106, and A616, caused by the narrowness of the roads, volume of traffic and lack of parking places for local residents. Side roads tend to have poor sight lines because of the topography. Many roads cannot be improved or widened due to the existing location of buildings and the fact that many minor roads are former horse and cart tracks.

5.4

A Planning Inspector has already stated that any increase in the volume of traffic in New Mill Square is not acceptable. Various alternative configurations have been proposed but none give a convincing case for change. In any case, funds for making improvements have not been forthcoming, even though the problem, that this junction is already overcapacity, has been known about for a number of years. No reference is made in the Local Plan to the difficulties at this junction even though a number of sites allocated for housing will increase the traffic load on it. The Employment Market Strengths Assessment Final Report discusses some sites allocated for employment use but gives no recognition of traffic problems in the area. For example, employment sites are identified on New Mill Road, Honley and says that there are no access issues. This fails to recognise the difficulties in accessing the sites from New Mill.

5.5

Honley Bridge is also a complex junction which will experience increased load from the housing land allocations. Again, no mention of this junction is found in the Local Plan.

5.6

The middle of Holmfirth has seen alterations to the traffic lights to give greater emphasis to pedestrians. Local opinion is that these have made matters 20

far worse for all users, including pedestrians and the junction works better when the lights are out of action.

5.7

The Infrastructure Delivery Plan lists this junction in the top 20 most congested junctions and where the impact of new development will be the greatest by 2020. However “no funding opportunity identified to date�.

5.8

Attention is also needed at the Sovereign Junction on the A629. This is a known accident point and is the location of long queues on the A635 both morning and evening. Many people from the Valley commuting, particularly to Leeds and Wakefield use this junction. The cost and practicalities of reducing the risk are understood: reducing traffic volumes by the provision of more local jobs rather than the development of commuters’ housing surely a more cost-effective and sustainable way forward.

5.9

Parking provision in Holmfirth and Honley already causes difficulties for those wishing to use the town centre facilities. This does not help to increase footfall and can act as a deterrent to visitors. We accept that the lack of space in these two conservation areas make the allocation of more land for car parking difficult. The answer therefore is more imaginative solutions which we would happily explore with the Council, given the opportunity.

5.10

It is both puzzling and concerning that the known traffic problems are not recognized and given due consideration. It is also of concern that the Local Plan policy will serve to make matters worse.

5.11

Changes to the local bus routes mean that services across the Valley have been reduced. This again hardly encourages people to adopt more sustainable modes of transport.

5.12

The Local Plan gives very little attention to the Penistone railway line.

Improvements to access and parking provision should be included in the Local Plan.

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5.13

The topography does not encourage cycling or walking for the less fit and older members of the population. We agree with the policy imperative of increasing walking and cycling as well as protecting bridleways and note the reference in the Local Plan to the Kirklees Walking and Cycling Delivery Plan 2015 - 2026. Sight of this document would be appreciated. We would also like discussions with the Council to ensure that our plans, particularly those being developed by River 2015, are taken into account, as we note the proposed walking and cycling route leaves the river corridor between Holmfirth and Mytholmbridge.

5.14

The location of land for housing, the type of houses most likely to be built and the distances to local schools will increase the school run. There appears to be little if any attention is given to the increased demand for school places other than by leaving it to others to provide. For example, the housing development proposed for Scholes would probably increase the demand for primary school places when it is known there is currently no local capacity. (Information contained in the Examiner in October 2014 shows that applications for places in local primary schools in Holmfirth and Scholes exceeded the places available.)

5.15

We would like to see a more proactive approach to ensure that housing provision and school places are increased in the areas where population growth is more likely. The Local Plan as it stands risks a mismatch. The increase in housing and the commensurate increase in population and the lack of plans to increase local employment and school provision will encourage more commuting. The Local Plan will, in our view, contribute to carbon emissions, not reduce them.

5.16

Similar concerns exist about the availability of health care provision in the form of general practice based services, dental and community care. We appreciate that these are not within the control of the Council but are of the

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view that greater consideration should be given to the ways in which the increased population’s increased demands will be satisfied.

5.17

We would appreciate further discussions with the Council so that local concerns about existing transport issues, likely increases to traffic volume, infrastructure provision and the lack of realistic mitigation plans can be fully considered.

6 6.1

CARBON EMISSION REDUCTION The Local Plan refers to climate change and the delivery of renewable and low carbon technology developments. We feel that far more could be done and would welcome the opportunity to discuss our proposals with the Council.

6.2

These relate to the creation of jobs in the green economy, the increase in local employment generally, the creation of new jobs in environmental conservation that would enhance the visitor appeal of the Valley, as well as reduction in traffic.

6.3

We do not feel that this important matter can be left to the introduction of “the concept of developers monetizing the damage caused from their developments” alone. Our fear is that this is an open door to poor quality development in relation to climate change; we believe that Kirklees should proactively define the requirements for delivery of renewables and low carbon developments.

6.4

We have similar concerns about the capacity of the drainage and sewage systems. We are aware that work has been done to improve the drainage in New Mill and at the bottom of Dunford Road in recent years but have serious concerns about the ability of the drainage system and capacity of the sewage works to accommodate the increased effluent from the number of people who will move into the Valley if all the houses proposed in the Local Plan are built.

The increased area covered in non-porous material will also add to the amount

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of water in the surface water drainage system. We seek reassurance from the Council that the foul and surface water drainage system has sufficient capacity for the proposed level of demand. We would also like to know how Kirklees proposes to capitalise on effluent waste.

6.5

The Infrastructure Delivery Plan identifies the risk of flooding in the River Holme corridor and in New Mill. This issue was explored extensively during the Tesco appeal in relation to the potential for flooding at the Reins Mill site.

We accept that some of our proposals for mixed use sites introduces the possibility of house building in areas where the risk of flooding is higher than on the hill tops. We consider the risk, given the rapid development in thinking regarding risk mitigation measures, is worth taking.

6.6

Work is underway, under the auspices of the River 2015 to open up access to the River Holme along its length to the junction with the River Calder. This project provides the opportunity for innovative thinking on how increasing access and the associated environmental improvements could be linked with flood risk mitigation measures to increase the usability of land in the Valley bottom.

6.7

We would welcome the opportunity to explore possibilities with the Council.

However, we do not think that the Council should rely on private developers to ensure that adequate action is taken. We would wish to see a more proactive stance from Kirklees.

7 7.1

VISUAL APPEARANCE ACROSS THE VALLEY We note that the Local Plan quotes the National Planning Policy Framework as giving great importance to preventing urban sprawl and says that it is important that development “is not harmful to the visual amenity of the green belt” and that “a design is sensitive to its green belt setting”. We would argue that similar consideration should be given to all developments in the Holme

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Valley, given the strategic importance of the Valley’s appearance and its value as an economic asset.

7.2

Again, in our view, a more proactive approach is required to protect the distinctive features of what is important to the Valley in terms of visual amenity and we would like to see the Local Policies strengthened and the development of strong planning development briefs, that will promote quality development for individual sites.

7.3

One of the area’s distinctive features, indeed the major distinctive feature, is the narrowness of the Valley and the steepness of its sides. These provided the water power that led to the area’s development as a centre for the textile industry as well as providing the stunning countryside as a back drop for cinema and television. They were also responsible for the amount of damage caused by the floods.

7.4

Checks will need to be made to ensure that the sites allocated for house building and employment purposes do not constitute a “blot on the landscape” and that the design of new builds is truly complementary to the character of the Holme Valley. An example of a site whose development would spoil the visual amenity is the one in Holmbridge.

7.5

We note that no consideration appears to be given to the matter of light pollution that will be caused by the development of even small housing estates on sites that are visible from other parts of the Valley. For example the large site on Ryecroft Lane Scholes is high and will create visible light at night. We would welcome the Council’s views on this matter.

7.6

Paying lip service to street level appearance as some of the recent developments have done is simply not good enough. We will seek to discuss this matter further with the Parish Council during the development of the Neighbourhood Plan.

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7.7

Holmfirth Conservation group, in partnership with Holme Valley Parish Council, residents and all stakeholders in Holmfirth, is about to start an appraisal process of the Conservation Town of Holmfirth which has never been appraised by Kirklees Council but deemed at risk by Historic England. Other villages within the civic parish boundary without appraisals are Hinchliffe Mill, Honley, Netherthong, Upperthong, Woodale, Scholes, Totties and Hepworth.

They will benefit from the expertise gained as a result the appraisal process as they are also conservation areas which may be compromised by development of the Valley.

8 8.1

QUALITY OF LIFE AND ATTRACTIVENESS The area is a popular place to live and attracts people who seek a semi-rural way of life. Its draws people into the Valley from other parts of the country and therefore has an economic benefit to the Council. The effect of this can be in the population profile and other key statistics.

8.2

There is a danger that the attractiveness of the place would be spoilt by developments in the wrong place and some of the fundamental issues highlighted above not being addressed. For example, traffic jams and insufficient parking will deter visitors as much as reducing the quality of life for residents. Increased commuting will mean the area becomes a dormitory for other locations rather than being an exciting place to live where lots of community and social activities take place.

8.3

The allocation of land for housing will join the villages in settlements, particularly along the area enclosed by New Mill Beck and the River Holme at Thongsbridge to Honley. The infilling of these areas will serve to urbanise the Valley and in particular housebuilding along Woodhead Road between Thongsbridge and Honley and Honley to Brockholes will, in effect, constitute ribbon development. This is contrary to the policy imperative of retaining the distinctiveness of the local communities.

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8.4

We and many other local organisations have worked hard on a voluntary capacity for a number of years to make the Valley a great place to live and work in, and to visit. We share similar aims to Kirklees Council and want to retain the Valley, its towns, villages and settlements as places of character.

We seek to retain their distinct identities and this requires that the Valley remains a functioning economic entity.

8.5

We invite Kirklees to work more closely with us and other parts of the local community to deliver the vision.

9 9.1

GREEN BELT The National Planning Policy Framework states: ”A local planning authority should regard the construction of new buildings as inappropriate in Green Belt” and “The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.” We note that some of the land allocated for housing invades the green belt (for example in Scholes and Cinderhills).

Surely negates this land from the development plan?

9.2

We would appreciate clarity from Kirklees regarding its interpretation of the NPPF in this case.

10 10.1

NEIGHBOURHOOD PLAN We are aware that the Holme Valley Parish Council intends to formulate a Neighbourhood Plan, that this will be done in consultation with local people and groups and will eventually go to a referendum. The purpose of the Neighbourhood Plan, as we understand it, is to provide greater granularity within the scope of the Local Plan’s policies and parameters. As such, it will be constrained by what is laid down in the Local Plan but will still give more scope for definition.

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10.2

We await information from the Parish Council about its plans for consulting local people and groups and look forward to co-operating on the Neighbourhood Plan’s development.

11 11.1

REJECTED SITES The Local Plan lists sites that have been put forward by land owners and developers. Some of these have the potential for very large developments.

We have considerable concern about the chances of these and some of the safeguarded sites being brought forward for development. They will not have received the same degree of scrutiny during the public consultation process yet their impact could be more damaging and detrimental than those proposed in the Local Plan.

11.2

That said, some are small plots and their use would protect some of the more sensitive sites that have been allocated for housing in the Local Plan. We note that in the Sustainability Appraisal Report some of the reasons for rejection could be open to questioning.

11.3

We would appreciate the opportunity to compare with the Council the merits of some of the rejected sites with those put forward in the local plan as we believe that some of the former could be less detrimental than some of the latter.

11.4

We believe that some of the proposed residential sites are of a large scale compared with their landscape context and could have a significant impact on the landscape character and will have a significant visual impact. Further detailed exploration of this is important to ensure long term successful integration of proposed development sites into the Valley’s environment.

12 12.1

VISION FOR THE HOLME VALLEY Rather than comment in detail on individual sites here, we would prefer the opportunity to discuss its overall vision for the Holme Valley with Kirklees 28

Council. We would welcome a full and wide debate on building development and land use and their impacts on residents of the Valley and nature of life here.

12.2

Every individual has their own interpretations of what “making the Valley a great place to live and work in, and to visit” means in practice. Our research and work over the years has identified several widely shared themes:  We care about the environment.  We want to preserve the Valley as an independent, economic entity with all that it entails, including the provision of local shops, facilities and services, sufficient to mean most people’s usual needs, local jobs and support for local businesses.  We want to see appropriate and sustainable development.  We want to retain the towns’ and villages’ characters and individuality; we do not want to see urban sprawl.  We would like to see more and better jobs, services, facilities and housing so more young people stay and are attracted here.  We value the stunning nature of our countryside and want to share it with others. We do not want to wrap it up in aspic; we recognise the value it brings to the Valley and Kirklees as an economic asset.

12.3

We would like to see Kirklees Officers take an open approach to LDP agreement with residents by holding question and answer public meetings where public concerns can be addressed directly. (We have experience of this in the lead up to the Tour de France.) Such public meetings would be in the spirit of democracy and open government to which we all (Kirklees Council included) are committed.

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13 13.1

CONCLUSIONS The Local Plan identifies 16 issues. Our examination indicates to us that the policies and land allocations fail to address those issues, as follows: Issue 1 The housing site allocations will lead to urban sprawl, ribbon development and merger of settlements (for example in Scholes and Holmbridge, along Woodhead Road and linking Thongsbridge, New Mill and Brockholes).

Issue 2 No consideration is given to how new jobs will be created and insufficient jobs will be created in the Holme Valley to meet the needs of the increased number of residents.

Issue 3 The housing allocation locations are not in the areas where we consider population growth is likely to occur. We believe better demographic predictions against current population profiles should be made before the Local Plan is finalised.

Issue 4 There is an imbalance between the jobs growth and increased housing allocations.

Issue 5 We consider that some of the rejected sites may be less detrimental than the sites allocated for housing. We also consider that insufficient consideration has been given to using land allocated for employment as mixed development sites.

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Issue 6 We believe that insufficient consideration has been given to place shaping and despite the language used in the Local Plan there is little understanding of the distinct characteristics of the areas that fall within Kirklees’ remit.

The Local Plan in our view will be detrimental to the quality of the lives of existing residents.

The Local Plan does not recognise how the countryside could be used more to promote leisure and healthy activities; nor does it recognise the economic benefits the countryside in and around the Holme Valley could bring to Kirklees.

Issue 7 The Local Plan proposes extension of urban areas and removal of some green belt land. Over all we see the increased housing stock in a semi-rural and rural area as being detrimental to wild life - both and the environment.

Issue 8 As with issue 6.

Issue 9 We believe the Local Plan will add to climate emission not reduce it. The number of houses proposed coupled with insufficient provision of jobs school places and other essential services will increase traffic volumes.

Issue 10 Increased traffic volumes will increase congestion. There are no proposals to deal with known problem junctions. The land allocations will make matters worse.

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Issue 11 Without local jobs, people will not and given the topography of the area, cannot be expected to use alternative modes of transport.

Improvements of the Penistone line and better parking provision are omitted.

Issue 12 The Local Plan fails to recognise the value of the internationally known brand of “Holmfirth� and the economic value tourism and related visitor activities could bring to the area.

The Local Plan and its associated sources documents do not sufficiently analyse the make-up of the local business population to recognise the importance of self-employment. Insufficient attention is given to how the potential of home based working, and micro and small businesses could contribute to economic growth.

Issue 13 The Local Plan does not appreciate that local employment is an essential ingredient to footfall in small town and village centres.

More balanced population profiles are also required to maintain local shops and facilities. The Local Plan in our view will not achieve a better mix unless more control is exercised over the type of housing.

The centres are, in the main conservation area. More could be done to protect their distinct characteristics and exploit the rich heritage of the area.

Issue 14 The emphasis on manufacturing takes attention away from some of the other economic strengths of the area, particularly the visitor economy.

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Issue 15 Mineral extraction should take account of the visual amenity of the area and any adverse impact it would have on residents and the nature of the place.

Issue 16 The main waste that causes us concern is foul water. We have significant concerns regarding the drainage system’s ability to cope with the increased load that will be placed upon it if all the proposed houses are built.

13.2

We therefore conclude that the Local Plan is inadequate and will not meet the future needs of the Holme Valley. We understand the pressure facing Kirklees to produce a Local Plan that is sound and sustainable but believe that the draft document as it stands is neither.

13.3

We recognise there is the need for more housing and that change is inevitable.

However, we believe there are better options than those proposed in the Local Plan and would appreciate the opportunity to work with Kirklees Council on these.

13.4

We look forward to working with the Holme Valley Parish Council on the development of the Neighbourhood Plan but as we know that this has to conform with the Council’s Local Plan, we believe that the Local Plan must first be right.

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