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Leeds Girls High School

Leeds Girls High School moved to Headingley into purpose built premises (pictured above and now known as the Main School Building http://www.flickr.com/photos/25393012@N04/2445504648/ in 1906. The building was constructed to the design http://leedsgirlshighonline.com/wp-content/uploads/2010/10/Chorley-2.jpg of architect H S Chorley http://www.flickr.com/photos/25393012@N04/2445738745/ of the firm Connon and Chorley (also responsible for the Hotel Metropole http://www.flickr.com/photos/26065935@N03/2447040804/ and was opened by Queen Victoria’s daughter, Princess Louise http://www.flickr.com/photos/25393012@N04/2449706283/ . The listed building Rose Court http://www.flickr.com/photos/25393012@N04/2444706011/ was acquired in 1912. In 2008, following a merger with Leeds Grammar School http://www.flickr.com/photos/25379774@N03/2393129918/ the site was closed, and the School re-located five miles away to Alwoodley, into new buildings constructed on the greenbelt. Immediately after this, the following planning applications were submitted to develop the School’s old Headingley site:

08/04214/OT https://publicaccess.leeds.gov.uk/online-applications/applicationDetails.do?activeTab=documents&keyVal=K3ZM13JB0FZ00

08/04216/FU https://publicaccess.leeds.gov.uk/online-applications/applicationDetails.do?activeTab=documents&keyVal=K3ZM13JB0FZ00

08/04219/FU https://publicaccess.leeds.gov.uk/online-applications/applicationDetails.do?activeTab=documents&keyVal=K3ZWYQJB0JD00

08/04220/LI https://publicaccess.leeds.gov.uk/online-applications/applicationDetails.do?activeTab=documents&keyVal=K3ZX7WJB0FZ00 and

08/04217/CA https://publicaccess.leeds.gov.uk/online-applications/applicationDetails.do?activeTab=documents&keyVal=K3ZQL5JB0FZ00

Leeds City Council’s failure to determine these applications, led to the submission of the current appeals (references APP/N4720/A/10/2140564, APP/N4720/A/10/2140572, APP/N4720/A/10/2140575, APP/N4720/A/10/2140578 and APP/N4720/A/10/2140587).

For further background information, please refer to Leeds Girls High Online http://leedsgirlshighonline.com/

Friends of Woodhouse Moor

Friends of Woodhouse Moor was formed by local people in March 2006 in reaction to a plan by Leeds City Council to build a large pay and display car park on the park to serve visitors to the university. Although, the plan was eventually scrapped by the Council’s Executive Board on the 17th May 2006, the Friends have remained as a group dedicated to maintaining the Moor as a sustainable amenity for the local community, in the spirit in which it was originally purchased by and for the citizens of Leeds.

Woodhouse Moor is the most intensively used park in the city. Large numbers of students live in the vicinity of the park and use it to play football and rugby on. They do this because the university’s own sports facilities are several miles away at Bodington Hall http://www.flickr.com/photos/25059858@N02/2370224745/ The result is that in Winter, large areas of the park are churned into mud. Friends of Woodhouse Moor believes that this intensive use of the park is unsustainable and that relief needs to be provided in the form of additional local green space where sports can be played. The Leeds Girls High School site could provide this additional green space. (Woodhouse Moor is likely to be subjected to even greater use when the university sells Bodington and transfers its sports facilities to Clonmore Farm http://www.flickr.com/photos/25059858@N02/2370968860/ even further away from the university campus than Bodington, and not even on a bus route).

The severe shortage of playing fields in the area means there is the additional danger that the university might try to use section 106 agreements to establish formal playing fields on Woodhouse Moor. That is something the university tried to do quite recently when it was given planning permission to build on the former Grammar School site http://www.flickr.com/photos/25059858@N02/2371350687/ adjacent to Woodhouse Moor. The risk of this happening again would be reduced if the Leeds Girls High School playing fields could be made available for public use.

Finally, as residents of the area, Friends of Woodhouse Moor are opposed to the current proposals as we believe they would alter the character of the conservation area for the worse, and would constitute over development.

We believe the appeals should be rejected because :

  1. UDP Policy N3 http://leedsgirlshighonline.com/wp-content/uploads/2009/10/UDPMAP-ADJ-9.pdf states, “Priority will be given to improving greenspace provision within the priority residential areas identified on the proposals map, or in locations readily accessible on foot to those residing in those areas.” The Leeds Girls High School site abuts a priority residential area, as can be seen from the UDP Proposals Map http://leedsgirlshighonline.com/wp-content/uploads/2009/10/UDPMAP-ADJ-9.pdf
  2. The foreword to PPG17 http://appeals.leedsgirlshighonline.com/wp-content/uploads/2011/02/PPG17-Foreword.pdf makes “health and well being” a planning objective of PPG17 http://www.communities.gov.uk/documents/planningandbuilding/pdf/ppg17.pdf The Leeds Girls High School playing fields are adjacent to an area with a large Asian population. This ethnic group face greatly increased risk of diabetes and cardiovascular disease, and South Asian children are recommended to acquire the exercise habit from an early age.
  3. Paragraph 10 of PPG17 http://appeals.leedsgirlshighonline.com/wp-content/uploads/2011/02/PPG17-Para-10-a.pdf states, “Existing open space, sports and recreational buildings and land should not be built on unless an assessment has been undertaken which has clearly shown the open space or the buildings and land to be surplus to requirements. For open space, ‘surplus to requirements’ should include consideration of all the functions that open space can perform.” There has not been a valid PPG17 assessment. The Leeds Girls High open space performs the following functions; it acts as a ‘green lung’ within a densely built up inner city area, it provides the setting for the listed building Rose Court, and it adds character to the Headingley Conservation Area.
  4. Paragraph 10 of PPG17 http://appeals.leedsgirlshighonline.com/wp-content/uploads/2011/02/PPG17-Para-10-b.pdf states with regards to proposals to build on open space, “Developers will need to consult the local community and demonstrate that their proposals are widely supported by them.” Over 1,300 local residents, both MPs, all six local councillors and Leeds Civic Trust have objected to these proposals.
  5. Paragraph 13 of PPG17 http://appeals.leedsgirlshighonline.com/wp-content/uploads/2011/02/PPG17-Para-13.pdf states, “Equally, development may provide the opportunity to exchange the use of one site for another to substitute for any loss of open space, or sports or recreational facility. The new land and facility should be at least as accessible to current and potential new users, and at least equivalent in terms of size, usefulness, attractiveness and quality.” The Leeds Girls High open space provides a ‘green lung’ within a densely built up inner city area, it provides the setting for the listed building Rose Court, and it adds character to the Headingley Conservation Area. The replacement open space at Alwoodley provides none of these functions. Also, the replacement open space at Alwoodley was already open space before the School moved there, so it can’t be said to be replacement open space.
  6. Paragraph 15(iii) of PPG17 http://appeals.leedsgirlshighonline.com/wp-content/uploads/2011/02/PPG17-Para-15.pdf states that playing fields can be replaced in a “suitable location.” PPG17 leaves “suitable location” open to interpretation. Leeds City Council’s UDP policy N6(i) considers a “suitable location” to be “the same locality of the city”
  7. UDP Policy N6(i) http://leedsgirlshighonline.com/wp-content/uploads/2009/10/UDPMAP-ADJ-9.pdf states, “Development of playing pitches will not be permitted unless there is demonstrable net gain to overall pitch quality and provision by part redevelopment of a site or suitable relocation within the same locality of the city, consistent with the site’s functions.” The appellant is claiming that he has provided replacement playing pitches at Alwoodley. But Alwoodley is five miles away from Headingley and therefore the new pitches cannot be said to be in the same locality.
  8. UDP policy N6(ii) http://leedsgirlshighonline.com/wp-content/uploads/2009/10/UDPMAP-ADJ-9.pdf states, “Development of playing pitches will not be permitted unless there is no shortage of pitches in an area in relation to pitch demand locally.” That there’s a shortage of pitches in the area adjacent to the Leeds Girls High School site is demonstrated by the fact that the six schools within one mile of the site have just 29% of the playing pitch requirement of the Education (School Premises) Regulations 1999 (SPRs) http://leedsgirlshighonline.com/test/ In addition, a technical appraisal http://hydeparkandwoodhouseonline.com/?p=1198 (identical to a PPG17 audit) using figures for participation in the game of tennis, Lawn Tennis Association recommendations, and local population statistics, shows that Headingley, Hyde Park and Woodhouse need 8 or 9 more tennis courts, which means that the 7 on the Leeds Girls High site are not surplus to requirements.
  9. UDP policy N6(ii) http://leedsgirlshighonline.com/wp-content/uploads/2009/10/UDPMAP-ADJ-9.pdf states, “Development of playing pitches will not be permitted unless there is no shortage of pitches in an area in relation to pitch demand locally.” That there’s a demand for pitches in our area is demonstrated by the fact that the heads of five of the six schools within one mile of the Leeds Girls High site have asked the Council to acquire the pitches for the use of their pupils http://appeals.leedsgirlshighonline.com/letters-from-the-head-teachers/
  10. The proposed change of use and structural alterations to Rose Court would cause the loss of important internal features http://www.flickr.com/photos/40680851@N05/sets/72157625912918107/ and diminish the architectural value of the building and therefore be contrary to UDP policies N15, N17 http://appeals.leedsgirlshighonline.com/wp-content/uploads/2011/02/UDP-Polices-N14-N17.pdf and PPS5 http://www.communities.gov.uk/documents/planningandbuilding/pdf/1514132.pdf
  11. The sub-division of the curtilage of the listed building Rose Court would devalue the historic interest of the site which would be contrary to UDP Policy N12 http://headingleytennisclub.com/ashgrovetimes/files/2010/10/UDP-Policies-N12-and-N13-New-Buildings-should-respect-the-character-of-the-Neighbourhood-and-incorporate-disabled-access.pdf (compare the proposed new Rose Court boundary http://leedsgirlshighonline.com/wp-content/uploads/2010/11/Rose-Court-3.jpg with the original boundary http://leedsgirlshighonline.com/wp-content/uploads/2010/11/Rose-Court-Map-3.jpg ).
  12. The proposed alterations to Rose Court to create 8 flats would adversely affect the character of the listed building and comprise over-development which would be contrary to UDP Policies N13 http://headingleytennisclub.com/ashgrovetimes/files/2010/10/UDP-Policies-N12-and-N13-New-Buildings-should-respect-the-character-of-the-Neighbourhood-and-incorporate-disabled-access.pdf and UDP Policies N14–17 http://appeals.leedsgirlshighonline.com/wp-content/uploads/2011/02/UDP-Polices-N14-N17.pdf
  13. The new build proposals are an over-intensive use of the site and as such detract from the Conservation Area and the settings of the various listed buildings both on the site itself, and on the other sides of Headingley Lane and Victoria Road. The proposals are therefore contrary to UDP Policies N12 and N13 http://headingleytennisclub.com/ashgrovetimes/files/2010/10/UDP-Policies-N12-and-N13-New-Buildings-should-respect-the-character-of-the-Neighbourhood-and-incorporate-disabled-access.pdf and UDP Policy N19 http://headingleytennisclub.com/ashgrovetimes/files/2010/10/UDP-Policy-N19-New-Buildings-in-Conservation-Areas.pdf
  14. The design for the Main School Building was decided by competition. The winner was H S Chorley of Chorley and Connon, architects responsible for listed buildings such as the Metropole Hotel http://www.flickr.com/photos/26065935@N03/2447040856/ Quebec Street Liberal Club http://www.flickr.com/photos/40680851@N05/5440952343/ Spring Bank, Oulton Hall, St Edward’s Vicarage, and Ida Hospital at Cookridge, all of which are listed. UDP Policy N12 http://headingleytennisclub.com/ashgrovetimes/files/2010/10/UDP-Policies-N12-and-N13-New-Buildings-should-respect-the-character-of-the-Neighbourhood-and-incorporate-disabled-access.pdf states “The best buildings of the past should be retained”.
  15. The planning applications http://www.flickr.com/photos/40680851@N05/5442037152/sizes/l/ wrongly indicate that the intention is to retain all of the original Main School Building and state that the School Hall and other areas to the rear are later additions. In fact, the School Hall, and other areas to the rear are part of the original building. The original plans http://leedsgirlshighonline.com/wp-content/uploads/2010/10/Chorley-2.jpg show the extent of the original building that was given planning permission in March 1905.
  16. Page 63 of the Design and Access Statement http://hydeparkandwoodhouseonline.com/wp-content/uploads/2011/02/Page-63.jpg dated 29 June 2010 states, “All new buildings will have a contemporary look…” This conflicts with our own view and the view of Stephen Varley http://leedsgirlshighonline.com/wp-content/uploads/2010/11/Stephen-Varley-Memo-05.09.08.pdf the council’s Principal Urban Design Officer who has said, “In basic terms, the housing on the ‘Main Site’ should be of very traditional nature.”
  17. The newbuild proposal includes a 4 storey block. But according to the Council’s Principal Urban Design Officer Stephen Varley, in his memo dated 5 September 2008 http://leedsgirlshighonline.com/wp-content/uploads/2010/11/Stephen-Varley-Memo-05.09.08.pdf “The housing should not be more than 2 storey, especially opposite the Rose Court building. Any flats / apartments should not be more than 3 storey.”
  18. The School’s consultant Roger Wools states at paragraph 6.7 of his report dated 27 June 2008 http://appeals.leedsgirlshighonline.com/wp-content/uploads/2011/02/Roger-Wools-report-para-6.7.pdf “The stone gymnasium . . . makes a modest positive contribution (to the Conservation Area) as does the main school building”. UDP Policy N18A http://appeals.leedsgirlshighonline.com/wp-content/uploads/2011/02/UDP-Policies-N18A-N22.pdf states, “There will be a presumption against any demolition of a building or parts of a building which make a positive contribution to the character and appearance of a conservation area.”
  19. Disturbance caused by children and adults playing on the open space that would remain http://www.flickr.com/photos/40680851@N05/5441490555/sizes/l/ (labeled ‘Landscaped Amenity Space’) in the area in front of the Main School Building would detract from the amenity of the residents of the proposed surrounding blocks of flats owing to their close proximity to the open space. This would be contrary to UDP Policy BD5 http://headingleytennisclub.com/ashgrovetimes/files/2010/10/UDP-Policy-BD5-Loss-of-Amenity.pdf
  20. The proposed development could potentially house 570 residents in mostly flatted accommodation. This would further increase the proportion of non-family housing in the area and also increase population density in this already densely populated area. The proposals are therefore contrary to UDP Policy H15 http://headingleytennisclub.com/ashgrovetimes/files/2010/10/UDP-Policies-H15-and-H15A-Student-Housing.pdf (Area of Housing Mix, which seeks to redress the balance between family and non-family accommodation), against PPS1 http://www.communities.gov.uk/documents/planningandbuilding/pdf/planningpolicystatement1.pdf (“support existing communities”, “contribute to the creation of safe, sustainable, liveable and mixed communities”) and against PPS3 http://www.communities.gov.uk/documents/planningandbuilding/pdf/planningpolicystatement3.pdf (“create sustainable, inclusive, mixed communities”, “deliver a mix of housing”).

Proposed Conditions and S106 Agreement

Friends of Woodhouse Moor would like to have some input into any conditions or
section 106 obligations that are presented to the inquiry.

Documents

Friends of Woodhouse Moor is likely to refer to the following documents to support its case. This is not intended to be a complete list of the documents that we will rely on at the inquiry.

  1. Consultant Roger Wools report dated 27 June 2008
    http://appeals.leedsgirlshighonline.com/wp-content/uploads/2011/02/Roger-Wools-report.pdf
  2. Design and Access Statement dated 29 June 2010
    http://appeals.leedsgirlshighonline.com/wp-content/uploads/2011/02/DandA.pdf
  3. Leeds City Council’s Conservation Officer Rob Murphy’s memo dated 5 August 2008
    http://leedsgirlshighonline.com/wp-content/uploads/2010/10/LGHS-SDU-Conservation-01.08.04217.CA.pdf
  4. Leeds City Council’s Conservation Officer Rob Murphy”s memo dated 8 August 2008
    http://leedsgirlshighonline.com/wp-content/uploads/2010/10/LGHS-SDU-Conservation-08.04219.FU.pdf
  5. Leeds City Council’s Principal Urban Design Officer Stephen Varley’s memo dated 5 September 2008
    http://leedsgirlshighonline.com/wp-content/uploads/2010/11/Stephen-Varley-Memo-05.09.08.pdf
  6. Leeds UDP (Revised)
    http://appeals.leedsgirlshighonline.com/wp-content/uploads/2011/02/UDP.pdf
  7. Letters from head teachers
    http://appeals.leedsgirlshighonline.com/letters-from-the-head-teachers/
  8. PPG17
    http://www.communities.gov.uk/documents/planningandbuilding/pdf/ppg17.pdf
  9. PPS1
    http://www.communities.gov.uk/documents/planningandbuilding/pdf/planningpolicystatement1.pdf
  10. PPS3
    http://www.communities.gov.uk/documents/planningandbuilding/pdf/planningpolicystatement3.pdf
  11. PPS5
    http://www.communities.gov.uk/documents/planningandbuilding/pdf/1514132.pdf
  12. The Education (School Premises) Regulations 1999
    http://appeals.leedsgirlshighonline.com/wp-content/uploads/2011/02/SPRs.pdf
  13. The Main School Building 1905 ground plan
    http://leedsgirlshighonline.com/wp-content/uploads/2010/10/Chorley-2.jpg
  14. Various drawings
  15. Various photographs