SW22/H - Baldwin Lane, Clayton

Object

Representation ID: 4300

Received: 23/03/2021

Respondent: Mr John Fox

The potential impacts of flood risk and pollution to adjacent land cannot be mitigated. Also, given the surrounding topography makes surface water disposal in a controlled manner an extreme challenge and in reality, unsustainable.
Add to this the impact of additional loading placed on the existing public sewer system already under stress demonstrated by the need for additional attenuation facilities having to be put in place to accommodate recent developments.
Add into the mix: increased traffic congestion, access and highway safety issues (key challenge on to already very busy Baldwin Lane); Additional pressure on schools, health centres and other key infrastructure & the further loss of an important social amenity & further damage to the area’s character, wildlife, and environment.

Support

Representation ID: 7137

Received: 10/03/2021

Respondent: David Hill LLP

We are pleased to see that the above sites are allocated for housing in the Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021. The landowners are keen to progress with developing the sites and we would like to confirm their availability.

Object

Representation ID: 8169

Received: 24/03/2021

Respondent: CPRE West Yorkshire

In line with our comments on policy SP5, we object to these site allocations:

SW5/H
SW6/H
SW10/H
SW18/H
SW22/H
SW33/H

In particular, site SW33/H appears to be proposed for extremely low development density, which is unsustainable in any location and not compatible with the strategy. Our position is that sites that are not suitable for policy-compliant densities should not be allocated, irrespective of whether they are brownfield, greenfield or Green Belt.

Comment

Representation ID: 19898

Received: 01/04/2021

Respondent: Natural England

The site lies in proximity to the South Pennine Moors (Phase 2) SPA and has potential to lead to the loss of functionally linked land for SPA birds.

We welcome the approach taken in the draft plan, SPD and assessments to loss of functionally linked land.

The council has a copy of a model to identify the suitability of sites for SPA golden plover and recommend that allocations are screened against this dataset taking the following approach:

• Maximum Training Sensitivity plus Specificity (MTSS) layer: full survey for Golden Plover likely to be required. The WY Ecology Service SPA Bird Survey Methodology should be followed.

• Minimum Training Presence (MTP) layer or 10 Percentile Training Presence (10PTP) layer: scoping survey to determine if a full Golden Plover full survey required. A desk based survey may be sufficient for sites within the MTP whereas a walkover survey may be required for sites within the 10PTP;

• Not within an area of predicted presence: No survey required for Golden Plover.

Where loss of functionally linked land cannot be ruled out at this stage we recommend that allocation requirement text in the plan sets out survey and mitigation requirements clearly.

Object

Representation ID: 21756

Received: 24/03/2021

Respondent: Patchett Developments Ltd

Number of people: 2

Agent: Johnson Mowat

The red line boundary for SW22/H includes land controlled by Charles Patchett (land following the alignment of the railway tunnel).

Our client does not provide approval / consent for this land to be used as part of allocation SW22/H. Approval / consent is also not given for the construction of an access road over this land during this local plan period. Accordingly, the red line boundary for SW22/H needs amending.

A highways technical appendix and assessment is supplied. This suggests that there are a number of issues relating to achieving a suitable access to this site given the limitations of the current extent of its frontage and the need to maintain a 30M offsetting / separation between the access point and from the current access to Frayaleigh Kennels and Cattery opposite the site and to the east of Baldwin Lane.

Object

Representation ID: 21761

Received: 24/03/2021

Respondent: George Upite

Number of people: 2

Agent: Johnson Mowat

The red line boundary for SW22/H includes land controlled by Charles Patchett (land following the alignment of the railway tunnel).

Our client does not provide approval / consent for this land to be used as part of allocation SW22/H. Approval / consent is also not given for the construction of an access road over this land during this local plan period. Accordingly, the red line boundary for SW22/H needs amending.

A highways technical appendix and assessment is supplied. This suggests that there are a number of issues relating to achieving a suitable access to this site given the limitations of the current extent of its frontage and the need to maintain a 30M offsetting / separation between the access point and from the current access to Frayaleigh Kennels and Cattery opposite the site and to the east of Baldwin Lane.

Comment

Representation ID: 28915

Received: 24/03/2021

Respondent: Environment Agency

Site in Flood Zone 1 ONLY
Mitigation should be set above the 1 in 100 plus cc level for the site as suitable for the proposed vulnerability classification (EA standing advice should cover this).

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.

For developments 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 possible the sites within close proximity to Flood Zones 3b, 3 and 2 may be subject to future risk identified within the SFRA (to follow) which may affect its allocation or how development should be sequentially laid out on the site.

Consideration must be made to making space for water and providing betterment in terms of flood risk management where ever possible.

Object

Representation ID: 29247

Received: 29/03/2021

Respondent: Historic England

There are several Listed Buildings to the north, east and south of the site. Whilst we welcome the inclusion of a reference to the proximity of designated heritage assets in the vicinity of as a Constraint in the sites pro forma, if allocated, the Plan should make it clear that development proposals for this area would need to ensure that those elements which contribute to the significance of this heritage asset are not harmed.
Site SW22/H, add the following additional Development Consideration to the site pro forma:
‘Development should conserve and, where possible, enhance those elements which contribute to the significance of heritage assets in the vicinity of the site.’