NE23/E - Apperley Bridge / Esholt (Former Filter Beds - Water Treatment Works) Strategic Employment Area

Object

Representation ID: 2325

Received: 19/03/2021

Respondent: Ms Dianne Green

This site is a perfect opportunity to enhance the area by turning it back into a natural environment, extending the green open spaces around Esholt, which are accessible from the area. In terms of its designation as an employment area my comments are the same as those for NE22/E. There already exists a business area in this locality; how utilised is this and is the Council confident it can attract 'green' companies to this site?

Support

Representation ID: 17120

Received: 24/03/2021

Respondent: Caddick Developments Ltd

Agent: DPP Planning

We support the allocation of sites NE22/E and NE23/E and agree with the indicative site areas and capacities.

We also support the assessment that NE22/E provides an opportunity to strengthen access links between the road network, railway station, and NE23/E and therefore is of strategic importance to the region.

We would suggest that a better form of development would be achieved if an element of class C3 residential development was included in the allocation.

Object

Representation ID: 18079

Received: 24/03/2021

Respondent: Harworth Group & Nufarm UK Ltd

Agent: Johnson Mowat

At 31.55 ha representing 45% of the total employment land supply, the ‘Esholt Strategic Employment Area (SEA)’ is disproportionate to the overall distribution of employment land, the nature/sector of the uses indicated, and the suitability of the location for large numbers of HGV movements.

The SEA is located approximately 10km from the motorway network (M606)

Site NE23/E currently subject to a planning application does not therefore require an allocation to deliver employment development of an appropriate nature.

There is no justification for the allocation of site NE22/E (4.94 ha) other than its location between site NE23/E and the A658 Harrogate Road.

Sites NE22/E and NE23/E do not serve to meet the demand from occupier businesses and inward investors for employment development sites that are located close to the motorway network.

Draft Policy EC1 part D should be omitted (i.e. to omit sites NE22/E and NE23/E as employment allocations) and the proposals map amended accordingly.

Comment

Representation ID: 28779

Received: 24/03/2021

Respondent: Environment Agency

Flood Zones 2, 3 and the current/draft 3b/3a(i) within site boundary - Adjoins the current 3b and 2019 draft extent

There is to be no development with the 3b/3a(i) extent unless considered water compatible or essential infrastructure. Where this is the case the development must demonstrate no increase in risk to others, no loss of Functional Floodplain and suitable mitigation measures for use and the lifetime of the development.

Development on site should follow a sequential layout so as to prevent unnecessary development within Flood Zones 3b, 3 and 2 wherever possible. If the site is considered Greenfield then surface water discharge rates post development should be restricted to the pre development Greenfield discharge rate.

If the site is considered Brownfield then there should be a 30% reduction in surface water discharges, or restricted to Greenfield rates, there should be no increase in brownfield surface water discharge rates post development. So as to support prevention of cumulative increases to flood risk and should be in line with SuDs design principles. Some SuDs principles such as storage ponds should not be solely relied upon within areas at risk of fluvial flooding as they may not be operational during a flood.

Development must be shown to be safe for the lifetime of the development. See the Adept Guidance of Access and Egress plans. Hazard ratings may need to be assessed as part of the proposal.

Mitigation such a proofing measures and raised Finished Floor Levels, must be set above the 1 in 100 plus Climate Change level for the site. Current Guidance is on .gov.

The applicant must ensure there is no increase in risk to others for the lifetime of the development (including climate change). Where on Greenfield sites compensatory storage must be actively sought.

Consideration must be made to making space for water and providing betterment in terms of flood risk management where ever possible. For development near ordinary watercourses we would recommend an 8 metre easement strip along the length of the riverbank, or a 45degree angle from the bed in the case of culverts, to be kept clear of permanent structures such as buildings. This is to maintain access to the riverbank for any improvements or maintenance. A Flood Defence Consent may be required for the LLFA for works in/affecting an ordinary watercourse.

For main rivers, we generally require an 8 metre easement strip along the length of the riverbank to be kept clear of permanent structures such as buildings, or a 45degree angle from the bed in the case of culverts. This is to maintain access to the riverbank for any improvements or maintenance. Environmental Flood Risk Activity Permits may be required for development near rivers.

It is likely these sites are going to show changes/increases in flood risk as a result of climate change.

The SFRA (to follow) is going to consider future flooding including future Functional Floodplain this may identify sites at more future risk than others which may affect its allocation or how development should be sequentially laid out on the site.

Comment

Representation ID: 29022

Received: 25/05/2021

Respondent: Bradford District Ward Councillor (Liberal Democrats)

Number of people: 2

Site presents a major opportunity to deal with the threat from climate change and pollution of seas/waterways.

It is the largest/most important site in the Plan. It goes some way to outlining what future generations can expect but is not detailed enough or linked through to existing green spaces/waterways to give residents confidence in the benefit of the outcomes.

Development framework reads more like an advertising specification than how it will make a real contribution to the planet’s health, reducing global warming and technical innovation required to ensure nothing from sewerage waste enters the river or atmosphere. Challenging to be more specific however Council must do more to ensure this is what it will achieve.

Schedule of works shows building starting this year without detailed masterplan being available. This must address visual aspect of development. Extensive tree canopy providing visual amenity must be protected.

There is some housing proposed with significant environmental benefits. Providing developers develop the scheme to the standards stated then we are supportive.

Object

Representation ID: 29165

Received: 29/03/2021

Respondent: Historic England

There is a requirement in the 1990 Act that “special
regard” should be had to the desirability of preserving Listed Buildings or their setting or any features of special architectural or historic interest which they possess. Although this requirement only relates to the determination of planning applications, failure to take
account of this requirement at this stage may mean that, when a Planning Application is submitted, even though a site is allocated for development in the Local Plan, the need to pay special regard to the desirability of preserving a Listed Building or its setting may
mean that either, the site cannot actually be developed or the anticipated quantum of development is undeliverable.
In order to demonstrate that the allocation of this area is not incompatible with the requirements of the NPPF, as part of the Evidence Base underpinning the Plan there needs to be an assessment of what contribution this area makes to those elements which contribute to the significance of these heritage assets and what effect development might have upon their significance.
Before allocating this site for
development:
(1) An assessment needs to be undertaken
of the contribution which this site makes
to those elements which contribute
towards the significance of the
Conservation Area and Listed Buildings in
its vicinity, and what impact development
might have upon their significance.
Before allocating this site for
development:
(2) If it is considered that the development
of this site would harm elements which
contribute to the significance of the
Conservation Area and Listed Buildings,
then the measures by which that harm
might be removed or reduced need to be
effectively tied into the Plan.
(3) If, at the end of the process, it is
concluded that the development would
still be likely to harm elements which
contribute to the significance of the
Conservation Area and any of these Listed
Buildings, then this site should not be
allocated unless there are clear public
benefits that outweigh the harm (as is
required by NPPF, Paragraph 195 or 196).

Comment

Representation ID: 29673

Received: 24/03/2021

Respondent: Leeds City Council

Other key sites the plan proposes to allocate will result in encroaching into the green belt: NE22 and NE23/E – Apperley Bridge/Esholt.

These sites have an ongoing planning application on them which Leeds City Council are in dialogue on through the planning application consultation process, raising issues on impact on greenbelt, air quality, traffic impacts, etc) and we wish these discussions to continue through that process and also through the duty to cooperate, where appropriate.

Support

Representation ID: 29713

Received: 24/03/2021

Respondent: Keyland Developments Ltd

Agent: Barton Wilmore

As noted elsewhere within these representations our Client supports the allocation of site NE23/E as a proposed employment site given its strategic importance to the District. The landowner has demonstrated through the live planning application ref: 19/02504/MAF that the site is suitable, available and achievable and represents a deliverable site, that is sequentially preferable when considering land to be released from the Green Belt given it comprises of previously developed land.

Our Client fully supports the Council’s position that ‘exceptional circumstances’ have been demonstrated to warrant to release of land from the Green Belt to meet the Council’s employment needs.

The Council’s existing employment land supply is generally of poor quality and small in scale meaning that indigenous businesses wishing to scale up their operations may have to leave the District due to lack of choice in the market. The Esholt development is large in scale and offers a unique location in terms of site characteristics (flat topography; development platforms in situ; previously developed land; attractive landscape surrounds) and well as being highly sustainable due to the proximity of Apperley Bridge railway station, bus routes and the local road network.

The Esholt development is hugely important to the Council and it is essential that it is allocated in order for the Council to meet their employment targets over the plan period.

We note that the proposed allocation does not included the land which is currently being proposed for the vehicular access to serve NE23/E and we would advise that the boundary is revised to safeguard an area around the proposed access route, as without this, it could be argued that the land which his allocated is not achievable as there is no suitable access within the confines of the Site.