Kirklees LDF amendments: Party by party

LDF core strategy proposals for cabinet consideration on 8/11/11 Amendments pro forma: Labour

1 Overall job requirement 2 Jobs requiring employment land 3 Jobs requiring office space 4 Source of new employment land required

4a including provision for business relocation to enable c 4000 brownfield homes 5 New office space required 6 Locations for employment land

7 Locations for new offices 8 Housing requirement 9 Housing in green belt

10 Settlement hierarchy & share of new housing by settlement tier 1 Huddersfield 2Dewsbury & Batley 3 Other N Kirklees towns 4 S Kirklees towns 5 Larger villages 6 Smaller villages

Recommended to cabinet 37,500 9,400

12,200 118 ha from current permissions & allocations plus 144 hectares of new land 72 hectares

Proposed amendment 36,350 8,250

194,700 sq m Cooper Bridge 42 ha

194,700 sq m 42 ha

Chidswell 35 ha Ainley Top 5 ha Cleckheaton area 16 ha Birstall area 16 ha Clayton West 15 ha Honley/B’holes 10 ha Meltham 5 ha Town centres 25,400 South Dewsbury 1500 Chidswell 500 Ainley Top 500

35 ha 0 10 ha 15 ha 15 ha 0 5 ha Town centres 22470 950 0 0

38% 30% 12% 10% 6% 4%

36% 27% 13% 13% 7% 4%

12,200 118 ha + 122 ha new

72 hectares

Labour plan for 36,000 jobs and just 63 houses per year in the green belt The Kirklees Labour group has published its proposal for a Local Plan to provide jobs and homes over the next 15 years.

We understand the need for balance when planning for a growing number of homes and the creation of conditions which will attract jobs and investment, while taking care to maintain the character of Kirklees.

Our long term vision will build on the proud fact that Kirklees is the 3rd most important district in England for manufacturing. These proposals meet the needs of current and future businesses, improves residential amenity and preserves the unique character of the district.

Housing Our plan – which will be discussed at full council on Wednesday – makes provision for up to 22,470 homes, and identifies land use for 36,000 jobs. This is compared to 25,400 homes and 37,500 jobs suggested by council officers.

We believe that green belt land should be used for 950 homes in south Dewsbury, this will act as a catalyst for further investment on brown field sites close to the town centre, followed by investment in infrastructure to help boost the local economy, and provide jobs We would like to see the majority of new homes built where the infrastructure already exists, so our bigger centres shoulder the most new houses, in line with the officer document. These proposals will meet the needs of a growing and ageing population and seeks to tackle the acute shortage of affordable housing as evidenced by significant problems experienced by first time buyers and 17,000 individuals on housing waiting lists.

Employment Unemployment has more than doubled in Kirklees since 2007, reaching 12,082, with a rise of 12% in the last year alone. In the last decade, our neighbours in Wakefield have attracted 11,000 jobs, but we have not attracted any new private sector jobs in the same period. The plan provides for attracting 36,000 new jobs over the life time of the plan. Job creation is extremely to tackle high youth unemployment and to rebalance the economy between the retraction in the public sector and growth in private sector jobs.

We have maintained the officer proposal for 42 hectares of employment land at Cooper Bridge as this is key to our strategy, close to the M62 and attractive to employers.

In Dewsbury, the use of green belt land is the key to attracting future investment – if we can attract more employers who will generate wealth locally, and invest in infrastructure, we will be some way towards creating the conditions for Dewsbury and the north of Kirklees improve economically.

We have broadly maintained proposals for employment use for land in Birstall, Cleckheaton, Clayton West and Meltham, in line with the council officer plans. This will provide for employment close to some residents homes and cut down on excessive car journeys.

Our strategy will support the expansion of low carbon technologies and we will work with business and commerce to develop zero carbon solutions on specific locations.

It is important that our strategy creates the conditions for higher skill and higher wage jobs.

Green belt The loss of green belt land is kept to a minimum, it is estimated that 75% of the district is in green belt land and we sugguest that less then 1% of the green belt land is released to create jobs, opportunity and improve housing conditions. This plan proposes an average of just 63 houses new houses per year to be built in the green belt. We are committed to developing brownfield sites, but it is clear that if we are to continue to attract investment in jobs and homes, we need to release some green belt land for development. However we have removed the proposal for land use at Ainley Top after reflecting on the fact that the site would require substantial investment in infrastructure to create just five hectares of employment land, and this meets the concerns of residents regarding roads infrastructure, the impact on amenities and air quality.

Where we propose releasing green belt land, this is designed to be the catalyst for further economic impact.

Town and district centres The future role of our town centres is another key issue for the plan. Labour supports the proposals to provide opportunities for new office employment in the main centres and also support their shopping and leisure functions. Selective release of green belt in Dewsbury will provide a substantial boost for Dewsbury Town Centre. In this context we also need an effective policy basis for controlling the proliferation of hot food takeaways.

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LDF core strategy proposals for cabinet consideration on 8/11/11 Amendments pro forma: Conservative Group

1 Overall job requirement 2 Jobs requiring employment land 3 Jobs requiring office space 4 Source of new employment land required 4a including provision for business relocation to enable c 4000 brownfield homes 5 New office space required 6 Locations for employment land

7 Locations for new offices 8 Housing requirement 9 Housing in green belt

10 Settlement hierarchy & share of new housing by settlement tier 1 Huddersfield 2Dewsbury & Batley 3 Other N Kirklees towns 4 S Kirklees towns 5 Larger villages 6 Smaller villages

Recommended to cabinet 37,500 9,400

12,200 118 ha from current permissions & allocations plus 144 hectares of new land 72 hectares

194,700 sq m Cooper Bridge 42 ha Chidswell 35 ha Ainley Top 5 ha Cleckheaton area 16 ha Birstall area 16 ha Clayton West 15 ha Honley/B’holes 10 ha Meltham 5 ha Town centres 25,400 South Dewsbury 1500 Chidswell 500 Ainley Top 500

38% 30% 12% 10% 6% 4%

Proposed amendment 34,200 6,100 12,200 (no change) 118 ha from current permissions & allocations 0 – brownfield land to be retained for employment except where neighbourhood plans provide for relocation 194,700 sq m (no change) Delete Delete Delete Delete Delete Delete Delete Delete Town centres (no change) 18,000 Delete Delete Delete

Shares to be determined in neighbourhood plans taking the tier shares as a starting point

KIRKLEES CONSERVATIVE GROUP ‐ KIRKLEES LAND USE ALLOCATION PLAN

INTRODUCTION The Conservative Group accept the need for a new land use allocation plan to replace the Unitary Development Plan involving a complex process of reviewing land use and need across the Borough.

We believe that due to the way the process has been conducted the Kirklees LDF process has become a toxic brand in the eyes of the public and as a consequence the Kirklees Conservative Group proposals for land use allocation has been relabelled as the ‘Land Use Allocation Plan’.

Previous consultation has failed to engage effectively with the public and has led to discontent with both the process used by Council and of the detail of the Council’s proposals. We believe in a real consultation process which gives real choices to the public and which is committed to listen to the views raised by local residents who will live with the consequences of the Council’s plans. We are committed to developing a neighbourhood planning process which engages and involves local people and communities with real decisions about their neighbourhoods.

RATIONALE BEHIND CONSERVATIVE PLANS IN RESPONSE TO THE COUNCIL PROPOSALS The Council proposals lack a clear vision of the future, creativity and forward thinking. We believe the Core Strategy has been based on flawed criteria used to justify targets in the Regional Spatial Strategy. The strategy fails to embrace the need of Neighbourhood Plans, and also fails to embrace the principles laid down in the NPPF. The strategy has failed to justify what it considers to be acceptable as ‘sound’ by the Planning Inspector, and it fails to offer alternatives and challenge what some would consider ‘sound’.

The strategy also suggests a determination to utilise Green Belt and greenfields as an easy option, raises the possibility of brownfield neglect in the future, and fails to be balanced and fair to residents throughout the borough. The strategy fails to offer up ideas to improve Kirklees as a place to live, just putting in place a strategy with which future generations will have to live. Our view of this and comments received from residents have helped shape the Conservative principles and views outlined in the remainder of this document.

CONSERVATIVE GROUP KEY PRINCIPLES The following principles represent the key proposals of the Conservative Group: 1. Green belt boundaries will only be changed where the change has been shown to bring both neighbourhood and strategic gains and is included in an adopted neighbourhood plan 2. Use of brownfield land will be the priority for accommodating employment and housing needs

KIRKLEES CONSERVATIVE GROUP ‐ KIRKLEES LAND USE ALLOCATION PLAN

3. Provision for new employment will be made through the use of remaining UDP allocations and re‐use or redevelopment of existing employment land and premises and by promoting office development in town centres 4. Re‐use/redevelopment of existing employment land and premises to be achieved by a. preventing proposals which would introduce new uses incompatible with employment except where a neighbourhood plan makes compensatory provision for employment, and b. by establishing enterprise action zones where site acquisition and amalgamation, marketing and infrastructure improvements will be supported by an enterprise fund 5. Provision will be made for 18,000 new homes through a. the implementation of all outstanding planning permissions which have a capacity of 9,600 homes b. the re‐occupation of 3,500 long term vacant homes, and c. the identification of sufficient land for 4,900 homes from brownfield and greenfield sites including UDP provisional open land (POL) sites 6. Town centres will provide a. high quality transport connections b. high quality office accommodation for large and small businesses c. “family quarters” containing restaurants and leisure attractions d. attractive opportunities for town centre living 7. Transport links from all parts of Kirklees to Leeds, Sheffield and other neighbouring cities and towns will be improved 8. The core strategy will provide guidance on the application of the above principles to facilitate the preparation of neighbourhood plans based on electoral wards (but subject to review) 9. Neighbourhood plans will be capable of 5 yearly review in response to changing local needs with the support of local people 10. Local Development Orders providing a more flexible planning regime will be used to encourage investment in areas in need of regeneration, for example in Dewsbury.

SUMMARY OF CHANGES PROPOSED TO THE COUNCILS CORE STRATEGY In addition to the principles outlined above, the following specific policy changes are proposed to the Council’s Core Strategy: 1 2 3

Policy SCS4: The requirement for renewable and low carbon energy capacity should be refocused from wind turbines towards hydro and solar Policy SCS5: The policy should include a stand‐off requirement for wind turbines of 1 km and emphasise their damaging impact Policy SCS7: Include consideration of flood risk from watercourses above site

KIRKLEES CONSERVATIVE GROUP ‐ KIRKLEES LAND USE ALLOCATION PLAN

4 5 6

7

8 9 10 11 12 13

Include policy for tourism with reference to NPPF paragraph 81 Include policy for agricultural diversification with reference to NPPF Policies SCS19 & 20: Remove discrimination against rural communities with reference to NPPF paragraphs 84 & 88 (and indicate in the strategy the importance of links from south Kirklees to Barnsley and Sheffield) Minerals area of search at Birdsedge is not acceptable. There should be co‐ ordination with neighbouring authorities to meet the needs across the geographical region to reduce the impact of mineral extraction in Kirklees as per NPPF Housing density is a matter for neighbourhood plans not the core strategy Parking standards should be revised upwards.

Parking to take account of long stay for tourist visits Housing mix, to distinguish between housing for frailer older people and sheltered housing for over 55’s, closing loophole.

Accommodation for travellers , the need for sites and the allocation of sites to be determined by neighbourhood plans.

Replacing some named POL sites, to be determined by way of neighbourhood plans

JUSTIFICATION FOR KEY PRINCIPLES AND POLICY CHANGES Business & Industry ‐ proposals for allocation of all Green Belt land for Business & industry at all strategic sites listed be scrapped. The Council have failed to justify that the land is needed and there are brownfield alternatives that can be redeveloped. Land in the Bradford Road corridor between Batley & Dewsbury and Leeds Road (Huddersfield) be designated as enterprise action zones for priority business and industry development. The Council will develop an enterprise fund to support site acquisition and amalgamation, marketing and infrastructure development. The Council has proposed to use 70 hectares of brownfield land for housing – but Conservatives are of the view that this should be retained for business employment use which partially replaces the 142 hectares the Council has included. Our proposals are more productive than the Councils in terms of jobs per hectare allocated.

Housing ‐ the rationale from Officers regarding the need for increased housing is flawed and indeed based on flawed RSS criteria. Kirklees does not need 24500 houses by 2028 and we don’t believe they would be built if the land was allocated. There are approaching 10,000 permissions granted for building homes which have not yet been commenced, and there are around 3,500 long term empty homes in Kirklees today which should be brought back into occupation. Until such time as these options are addressed there can be no case for allocating Green Belt land for housing purposes. We believe that a total housing land allocation of 18000 houses is sufficient to meet the needs of the Council and this is the figure that should be included in the Core Strategy for the period of this plan, given that house completions over the last plan averaged only 1000 pa.

KIRKLEES CONSERVATIVE GROUP ‐ KIRKLEES LAND USE ALLOCATION PLAN

Town Centre Development Plans ‐ there is insufficient commitment in the Council proposals which gives any real vision to our town centres and their futures. We believe the Council proposals should be strengthened and include a more detailed strategy producing Town Centre Development Plans, especially in relation to Batley, Dewsbury, Holmfirth and Huddersfield. Such proposals should: encourage town centre living; promote business locations into town centres; ensure high quality office setting for small business and high quality connectivity and transport links for our town centres; promote ‘family quarters’ in town centres to encourage restaurant and leisure attractions rather than night time drinking establishments.

Neighbourhood Plans – are given insufficient importance in the Council proposals. Although perhaps not required in detail in the core strategy there needs to be some acknowledgement of their importance and the part they will play in the future, in terms of communities and neighbourhoods being able to influence development in their localities.

Climate Change, Mitigation and Adaptation ‐ the proposed target of 53 MW for renewable and low carbon energy by 2028 is unrealistic and unachievable without a massive further increase in turbines proposed in Council plans. The onus on wind generation would mean a minimum of 14 commercial onshore wind turbines (110m high), 200 small scale wind turbines (12 to 25m high), solar PV to 6000 domestic properties, 4 hydro schemes and some biomass. The Council should concentrate its efforts on solar and hydro power and implement the 1km stand off distance for onshore turbines already approved by Council.

Tourism – is neglected in Council proposals. We believe the Council should be committed to developing land to increase the tourism offer. For example a policy to release land for golf courses, camp sites, caravan sites, and building hotels ought to be included. NPPF supports the rural economy and so should the Council. Tourism is important throughout Kirklees, and there needs to be Council commitment to developing it.

Agriculture and Farming ‐ the Core Strategy needs to show commitment to help farmers expand, or diversify. Kirklees needs policies to help create farm shops and associated facilities and it is an unacceptable omission in an area which has 70% of its land in the Green Belt for Council proposals to fail to address this issue.

CONCLUSION The Conservative Group are of the view that much of the information used in the Cabinet Report and Core Strategy is flawed and that in developing it in many cases Officer views have been too rigid and are unacceptable interpretations.

We are of the view that little notice has been taken of previous consultations and that public views sought have not been listened to, and we also consider that some issues have not been fully addressed whilst others have not been addressed at all.

LDF core strategy proposals for cabinet consideration on 8/11/11 Amendments pro forma: Liberal Democrat

1 Overall job requirement 2 Jobs requiring employment land 3 Jobs requiring office space 4 Source of new employment land required

4a including provision for business relocation to enable c 4000 brownfield homes 5 New office space required 6 Locations for employment land

7 Locations for new offices 8 Housing requirement 9 Housing in green belt

10 Settlement hierarchy & share of new housing by settlement tier 1 Huddersfield 2Dewsbury & Batley 3 Other N Kirklees towns 4 S Kirklees towns 5 Larger villages 6 Smaller villages

Recommended to cabinet 37,500 9,400

12,200 118 ha from current permissions & allocations plus 144 hectares of new land 72 hectares

Proposed amendment 36,350 8,250

194,700 sq m Cooper Bridge 42 ha

194,700 sq m 42 ha

Chidswell 35 ha Ainley Top 5 ha Cleckheaton area 16 ha Birstall area 16 ha Clayton West 15 ha Honley/B’holes 10 ha Meltham 5 ha Town centres 25,400 South Dewsbury 1500 Chidswell 500 Ainley Top 500

35 ha 0 10 ha 15 ha 15 ha 0 5 ha Town centres 22470 1500 500 0

38% 30% 12% 10% 6% 4%

34% 32% 12% 11% 7% 4%

12,200 118 ha + 122 ha new

72 hectares

Liberal Democrat Group – Alternative proposals for Local Development Framework Amendment to Motion to council on November 23rd

Policy approach 1. Liberal Democrats accept that the number of households in Kirklees will grow over the plan period for the LDF Core Strategy ie from adoption and until 2028. This is largely a consequence of many more people living well into their 80s and 90s.

2. We also accept the basis of the analysis in determining the numbers of new homes to be built which is on the basis of need from ONS information combined with a measure of deliverability which is based on the average of what has been built in the past 10 years, setting aside 2006/7 and 2007/8. We have not had any convincing evidence to challenge this analysis.

3. We have asked for evidence on empty homes. We have detailed information that there are 3,479 homes that have been empty for more than 6 months. Indeed, claims of 9,000 empty homes in Kirklees do not survive basic investigation of accuracy. We are proposing an Empty Homes Strategy to bring more empty homes back into use.

4. Liberal Democrats want more residents, and particularly residents of the Dewsbury/Batley area, to be able to access higher wage / higher skill jobs within the district. This approach combines an aspiration for people to become more prosperous with a desire for less out‐commuting. The current unemployment figures, and especially unemployment levels for young people, demand a positive response from the Council.

5. We accept that if more jobs are to be created then more land has to be made available for that inward investment.

6. Land usage is critical. Simply allocating more green land for development means developers are less likely to re‐develop previously used land, so‐called brownfield sites. Re‐using brownfield sites for both housing and business is vital if our towns are to re‐new themselves for the 21st century.

7. So a key policy approach for Liberal Democrats is that brownfield sites will be used first before greenfield sites. However, there is a strong argument for allowing some strategic green land release for new business at the start of the plan in order to encourage immediate inward investment to provide essential new jobs for young people.

8. In order to ensure that brownfield sites are developed first, we want a clear and explicit policy that makes that happen.

9. We also want a phased approach to the release of housing sites that takes into account the currently very sluggish state of the housing market. To achieve this we do not want any green field sites to be considered for release until the “5 year supply of housing sites” rule is triggered.

10. We will have a policy that creates Business Action Zones. Some former industrial / business land is under used and in desperate need of regeneration. For example on Bradford Road between Batley and Dewsbury. The costs of regeneration are probably too high for businesses to meet without support from the public sector. We propose having a policy to create Business Action zones which provides substantial support towards the costs of site clearance and remediation as well as incentives to businesses such as business rates holidays. For too long some parts of our towns have been scarred with the remains of industries that have long gone. Liberal Democrats are determined to provide the policy platform for action to be taken to bring new life to these areas.

Policy proposals 1. Phased approach to housing sites: brownfield sites to be used first by explicitly tying site release to the 5 year supply rule.

2. Empty houses: policy proposals to tackle long term empty homes and bring back into use 3. Business Action Zones: policies to regenerate areas of long term industrial decline with little prospect of action without intervention from the public sector 4. Town centres: policies to define a range of goods and services that make for a vibrant and attractive town which also provide a basis for controlling the proliferation of Fast Food take‐aways.

5. Emphasis on regeneration in Dewsbury and Batley: the strategy must provide the basis for substantial improvement in job prospects and housing conditions.

Strategic Covering Note for Green Party/Independent amendment to the Kirklees Local Development Framework The 16200 figure presented in the Green Party/Independent amendment has a strong evidence base supported by economic projections, past performance on housing completions, the impact of Coalition Government policies on the construction and housing sectors and the Communities and Local Government Paper, 'Estimating Housing Need' (2010).

Current economic projections for growth show 1.5% this year and 2.5% next year according to the government's own Office for Budget Responsibility. Historically these figures have been highly optimistic. This projection compares to the an annual growth rates averaging 2.68% between 1992–2007 according to the IMF. The British Chambers of Commerce Economic Forecast in March this year said:

“Further forceful cuts in the budget deficit, the unresolved problems in the banking sector, and the financial fragility in the household sector will delay a return to pre‐crisis growth rates. Over the next 4‐5 years, growth of UK GDP is likely to average just over 2% per annum, considerably less than the 3.0% average growth recorded in the 15‐year period 1993‐2007”

Coalition Government cuts of 60% in the Homes and Communities Agency is going to significantly reduce the levels of social housing and shared ownership housing available.

The viability of younger people being able to enter the housing market will be increasingly stifled due to the impact of tuition fees which will mean that when students leave college and start receiving the sort of salaries they would need to consider the purchase of a property they will start having to repay those fees.

While we recognise that there is an increasing social need for more housing, the mere projection of house building figures in the absence of interventionist social and economic policies will not create the construction of needed housing units. Rather it will give greater licence to the speculative builder of executive properties on green field sites. Without changes in government policy which will support the development of social housing, an open supply‐side private housing market cannot solve this problem, but only create distortions of excessive building on green field sites whilst leaving the overall stock of needed housing low.

Simply making land available in its own terms will not deliver new housing so the LDF’s own targets are not realisable due to the underlying economic conditions the UK is in and the lack of policies to stimulate an economic revival and develop social housing.

Past performance on housing completions does not support the targets given in the LDF document. The average number of completions between 2000 and 2010 was 1248 per year and even this level is skewed due to particularly high years. Expectations of mainly 1500 completions per year across the plan are clearly unattainable.

If our figures were to be adopted this would require no housing development on land that is currently in the greenbelt. We wish to see development in Grimescar, Honley, Meltham and Brockholes taken out of the plan. Just as the Local Development Framework has

proposed to remove greenbelt status from nominated areas we would add land below Castle Hill bordered by High Lane and New Laithe Hill which is directly adjacent to greenbelt land and part of the backdrop to the historic and iconic Victoria Tower on Castle Hill.

Like the Government asserts we also believe in Localism and support the concept of Neighbourhood Development Plans where communities establish what land they would like to see developed in their area above and beyond those targets set in the LDF. Our fear is that the Government's belief in localism is only skin deep and that the Government through the Planning Inspectorate would favour developers rather than communities.

We believe that where previously undeveloped land is to be developed that this should be constructed to a higher environmental standard than those proposed in building regulations in terms of energy performance and sustainable urban drainage.

We recognise that there is value in the juxtaposition of new design and new technology with heritage assets such as modern glass atriums on church buildings and solar panels being utilised on older properties and we would expect the LDF to include policies that support that approach.

Overall the Kirklees Local Plan should not only consider the urban settlements on a quantitative basis, but qualitatively take into account their unique features of these different communities taking into account their urban, rural and environmental factors .

Hence more detailed and specific polices should be developed for the Huddersfield Hub, Dewsbury, North Kirklees and the valleys in the South of Kirklees.