Bolton Crofts -

RE: Full Planning Permission for Residential Development of 27 Dwellings and Associated Infrastructure/Land To The East Of Bolton Avenue Richmond North Yorkshire

ZD23/00449/FULL

We object strongly to the proposal because of the danger and inadequacy of access roads and the loss of a significant green field site in a Conservation Area along with its magnificent views.

Sustainability and Accessibility (CP3, CP4, CP11)

The Transport Statement provided by Andrew Moseley Associates contains errors and inaccuracies and as a result is partial and misleading.

For example:

2.2.4 states Quakers Lane has a speed limit of 30mph. It is 20 mph.

2.2.4 states there are pedestrian footways either side of Quakers Lane. This is inaccurate - for most of Quakers Lane there is a footpath only on the northern side.

This misunderstanding of the local highway network demonstrates a lack of knowledge of associated local access and highways issues.

The proposed design solution with regard to access at the pinch-point at the head of the current Bolton Avenue cul-de-sac has major flaws:

Site access is so difficult it requires a narrow, single-file entry (‘pinch-point’). In an attempt to address concerns from Highways, the Applicant has proposed a ‘Give Way’ road-marking and signposts. This is positioned within an existing turning space. Vehicles waiting to enter the development would block the road. It would be difficult for car owners at 56, 58, 77 and 79 Bolton Avenue to exit their drives; they would not be able to see vehicles emerging from the new development.
Vehicles waiting to enter the development would also create an obstruction for vehicles attempting to use the turning space for its designated purpose.
The suggested ‘Give Way’ road workings would lead to idling traffic and associated pollution.
Cars park along Bolton Avenue. This will cause problems and render the proposed central white, give way lines academic.
It would inevitably necessitate the damage to, and probable loss of, a mature tree at 79 Bolton Avenue, protected within the Conservation area. The plans show levelling of the land and paving and hard-surfacing across the indicated ‘root protection zone’ for the tree in question.

Prior Avenue is a hazardous, steep hill (25% gradient). It is not gritted in winter and there are periods of ice and snow when it is too risky for residents of Prior and Bolton Avenues to move their vehicles. Black ice is a particular hazard. There are days when residents park their cars overnight on Quakers Lane as they know that Prior Avenue will be impassable. The occupants of any new houses on Bolton Crofts would need to be aware of this and would be similarly inconvenienced. Accidents and near-misses occur not only in winter but throughout the year.

2.3.2 of the Transport Statement states ‘there were no collisions recorded’ in the last five years. This doesn’t mean that there have been no collisions or incidents. We have previously provided a record of incidents.

The original application referred to 69 car parking spaces on Bolton Crofts. Such an increase in traffic volume would add extra risk of accident in addition to congestion problems along the avenues and at pinch points at the top and bottom of Prior Avenue, as well as on Quakers Lane. The increase in air and noise pollution would be detrimental (more so when the extra traffic generated by delivery, postal and waste collection vehicles and visitors, is factored in).

We question the validity of the data on trip generation. Again, this shows no awareness of the local situation, with data drawn from different areas of the country with different topography. 5.2.6 suggests ‘one additional vehicle on the local network every four minutes’.

Local residents carried out traffic surveys last autumn to generate reliable illustrative data and this suggested far greater levels of traffic. There are obvious implications for increased traffic on nearby roads which lead into the town centre (already heavily congested at peak times).

Much is made in the Application of Bolton Crofts being well-sited to deliver sustainably located development within easy walking/cycling distance of the town’s amenities. The fact is that, given the steepness of Prior Avenue, most existing residents use their vehicles to access the town. Thus a major increase in traffic is inevitable.

The developer claims that cycle routes will be enhanced. In reality, the steepness of the site means that only a few cyclists engage in cycling for sport/exercise, not to access local amenities. Richmondshire Local Plan CP3 states that ‘Development should be located to minimise the need for travel. Convenient access should be provided via foot, cycle and public transport.’ In this scheme the requirement cannot be met.

Green Howards Road is a busy, narrow road used by HGVs, vans and cars. It is not practical or safe to have an ‘emergency’ road leading from it into Bolton Crofts (especially from a dangerous entry point just beyond a blind spot). It is dangerous for cyclists and pedestrians with only a narrow footpath. It will not benefit existing residents on Bolton Avenue as claimed by the Applicant.

Housing Supply (CP3, CP6)

Bolton Crofts (Site 214) is identified under the Council’s 2019 SHLAA as suitable for development but this does not in itself give permission for development to take place as asserted by the Applicant. Latest Government Planning Policy states ‘the assessment does not in itself determine whether a site should be allocated for development.’ Furthermore, the time scale for consideration of any potential development of Site 214 is given as 11-15 years from 2019 – it should not therefore be considered until 2030.

Richmondshire DC has a still-relevant land supply calculation which shows a 5-year housing supply which is in excess of requirement.

The priority for future housing within the Town’s centre should still focus on brown field sites and conversion of existing properties. Richmondshire Local Plan CP3 states, ‘Development will be encouraged to utilise previously-developed land first (brownfield land) … in preference to greenfield sites.’

The draft NY Council Housing Strategy 2024-29 also prioritises the need to unlock brownfield housing sites and to bring empty properties back into use. It recognises the need to protect greenfield sites.

The revised design solution provides 8 ‘affordable’ units out of the total 27. This is less than 30% and thus less than the required target.

Heritage (CP3, CP4, CP12)

The Applicant commissioned a report from Humble Heritage which acknowledges the importance of Bolton Crofts, quoting the draft Richmond Conservation Area Appraisal:

‘Bolton Crofts is an area of steeply rising ground providing an impressive backcloth to the town. The green swathe cut by Bolton Crofts and reaching deep into the heart of the town, including Ronaldshay Park, the Cricket Fields and Friary grounds, is still a particularly striking and important characteristic of Richmond.’

In Para. 5.02 the Humble Heritage report maintains ‘the most significant view towards the town and castle from Green Howards Road through the trees to the south of the site has been identified and a view corridor through the site has been created, allowing unobstructed views.’

This is a beautiful view of the town but will only be seen through a narrow ‘view corridor’ between housing.

However, of most significance is the iconic, panoramic view of castle and town on the footpath to the east of the site which generations of Richmond citizens have enjoyed.

In Para. 5.04 the report says this ‘southeast corner of the application site has been left free of dwellings to allow the maintenance of views towards the town and castle from the existing footpath.’

The amended Site Plan shows that one property has been removed from the original scheme and others have been re-configured. The plans still show that houses are to be built in this area which will have a detrimental impact on the view. A narrow ‘view corridor’ will not mitigate the irrevocable loss to future generations of a sweeping, magnificent view.

The photomontages provided are of poor quality and misleading. Those seeking to admire a view of the castle and town from Green Howards Road will not enjoy an unspoilt view across green fields through a narrow ‘corridor’: they will instead be distracted by the roof tops and brick walls of 27 new buildings and the tarmac which links them.

In Para 5.05 Humble Heritage refers to the views from the castle. It states ‘from the castle the dwellings will be visible but the degree of visibility will be limited due to the trees that partially screen the site. There is less screening at the east end of the application site, but this is partly mitigated by the undeveloped far east corner of the proposed layout. ‘

Our photograph (see below) shows that housing will be seen across the entire site. Contrary to the Humble Heritage report, there will be development in the south east corner, removing a large part of the green sward. Furthermore, there will be a visible ‘sinuous ‘road leading up to Green Howards Road.

CP4 states that ‘development should not impact adversely on the character of the settlement or its setting, important open spaces and views…and the character of the landscape.’

The report from Humble Heritage quotes the National Planning Policy Framework: ‘the level of harm will be at the lowest end of less than substantial (Para. 202)’. We consider this to be wrong.

The National Planning Policy Framework states (Para. 201): ‘where a proposed development will lead to substantial harm to … a designated heritage asset, local planning authorities should refuse consent.’ We consider that this is the appropriate assessment of Bolton Croft as an important heritage asset within its Conservation Area.

Environment and Ecology (CP4, CP12)

As a town, we should not be losing precious greenfield sites and habitats, especially when 97% of meadows in England have disappeared post-War.

Loss of biodiversity at Bolton Crofts will only be fulfilled by improving an ‘impoverished ‘field off-site at Hornby, 5½ miles from Richmond. This benefits neither the fauna and flora nor the people of Richmond. Instead, the town stands to lose a greenfield, species-rich site and an ancient meadow in a designated Conservation Area.

The Richmondshire Local Plan states, ‘Development should be directed away from the most sensitive environments, including areas of biodiversity importance.’

A response from NY Council Principal Ecologist questions the reliability of the amended report from MAB-Ecology. The recommended measure to address Biodiversity Net Gain by improving an impoverished field 5 ½ miles away is unsatisfactory:

‘…our advice is that even if successful, grassland enhancement at Hornby would not compensate for the loss of habitat at Richmond due to isolation from other herb-rich grasslands.’

MAB-Ecology recommend planting 22 trees at Bolton Crofts. The Principal Ecologist considers planting trees would be inappropriate and that there would be significant loss/degradation of habitat and a species-rich grassland.

The applicant has not completed a proper bat survey. The habitat includes bats.

Furthermore, the National Planning Policy Framework states (Para. 180):

‘If significant harm to biodiversity resulting from a development cannot be avoided (through locating on an alternative on an alternative site with less harmful impacts), adequately mitigated, or as a last resort, compensated for, then planning permission should be refused.’

We strongly maintain that this is the case with the Biodiversity Net Gain assessment of Bolton Crofts.

Community Engagement

The Applicant initially submitted a Statement of Community Engagement. The figures cited in their ‘survey’ were misleading. Most residents did not reply because their leaflet had limited information, was anonymous, unofficial and gave no context of the planning process. Only 30 people replied and therefore it was unreasonable to draw any conclusions from that limited ‘community engagement’.

Subsequently, during the formal consultation period, 183 people responded, of whom 179 opposed the development (98%). The people who opposed gave wide-ranging reasons linked to the above key points and based, crucially, often on local knowledge and experience.

Conclusion

The application, as amended, still fails to comply with planning policy.

It also lacks the following:

There is no Construction report. How construction vehicles would access such a difficult site is a serious concern.
The plan does not show a reconfiguration of the water main. Yorkshire Water strongly advised that ‘prior to determination… the site layout is amended to allow for adequate protection of the main.’ Responding to the resubmission, Yorkshire Water stated ‘The presence of the main may affect the layout of the site and therefore is considered to be a material consideration in the determination of this application.’
There is no proper bat survey.

A previous application to build on Bolton Crofts was strongly rejected by the Council in 1985. The reasons for that rejection stand today:

the dangers and inadequacy of access roads
the importance of preserving spectacular views over a rural, historic town
the need to give the strictest protection to a greenfield site at the town’s heart
the need to prioritise brownfield and conversion sites.

The 1985 report also stressed that any development on Bolton Crofts would set a dangerous precedent for developing other sites on this northern skyline.

Bolton Crofts must remain a valued and treasured green space. These meadows must not be lost.

For the reasons set out above, the amended application proposal fails to comply with development plan policies, particularly CP3, CP4, CP6, CP11 and CP12, and associated Richmondshire Spatial Strategies, due to its impact on transport, sustainability, land and housing supply, ecology and heritage. It also fails to meet National Planning Policy Framework requirements.

Residents

13^th March 2024

Supporting Photographs

Demonstration of how the proposed ‘Give Way’ system would obstruct traffic at the head of Bolton Avenue cul-de-sac:

Two cars paused where white lines would be, giving way prior to entering the development.

Green car at No. 58 has difficulty exiting drive and cannot see traffic coming from the development.

Black car at No. 79 has difficulty exiting drive and cannot see traffic coming from the development (even if facing forwards).

The turning circle is obstructed by waiting cars.

Author of The Orchid Hunter and Where the Wildflowers Grow

"I'm an author and botanist and I'm really passionate about connecting people with Britain's wild plants. I love telling the stories of our wild flora to inspire people about this often-overlooked corner of nature.

I recently learnt of the proposed planning permission to build Bolton Crofts on the ancient wildflower meadow in the heart of Richmond, something that makes me deeply worried. I was born in Yorkshire, into a highly nature-depleted country, and I've only watched it get progressively worse ever since. Now 29 years old, I'm increasingly worried about my future and the future of what little nature we have left here in the UK.

We're in a crisis at a tipping point and we simply cannot afford to lose any more nature, so I strongly object to the proposed development in Richmond and implore you to reject these plans. The importance of healthy wild plant and insect populations for our future food security cannot be understated. So many people think nature is just a hobby, or something nice to look at, but without nature the biosphere collapses, and that's it for life as we know it.

I know this meadow in Richmond might not seem very significant, but building here will mean fewer crops are pollinated, impacting local farmers. It will mean the likelihood of flooding will increase, impacting local residents. It will reduce the amount of green space available, increase levels of pollution in the town and give further power to other financially driven developers who see nature as unimportant. Please make the correct decision for our future and reject the proposed planning permission.
Leif,"

Leif Bersweden is a writer, botanist and nature communicator

Bolton Crofts, Richmond

Information for NY Councillors and Concerned Parties

Page content.

Residents Letter to Richmond Town Council Planning Committee

Key Objection Letters – Links to the North Yorkshire Planning portal

Photographs

Friends of Bolton Crofts

We are a group of Richmond residents who are united to protect our local environment.

Important Update from North Yorkshire Council

BUILDING CONSERVATION ADVICE

Sharon Kelly, Principal Conservation Officer North Yorkshire Council