Consultation Question 6

Object

Representation ID: 5910

Received: 24/03/2021

Respondent: Baildon & Shipley Friends of the Earth

Baildon & Shipley FOE – SP5
1. See NPPF paragraphs 133-137
2. If the local plan is to demonstrate exceptional circumstances for Green Belt change, this must be set in the context of the need to address climate action as set out in SP1; and to achieve significant environmental net gains through development as required by NPPF, and the scale of car traffic reduction needed, as confirmed by the WYCA CERP report.
3. Maintenance of Green Belt will need no “mitigation measures”, but it would make sense to see what mitigation might apply in a certain case (such as providing additional green space nearby), and apply it anyway, for even more ‘net gain.’ See also FOE’s submission under EN1.

Support

Representation ID: 6762

Received: 18/03/2021

Respondent: Mrs Jean Cawkwell

We support the idea that exceptional circumstances exist to release Green Belt.
We OBJECT to part B of the policy in that it does not identify Queensbury Golf Course for Green Belt release. The Queensbury Golf Course site is available, suitable, achievable and deliverable.

Comment

Representation ID: 7530

Received: 08/03/2021

Respondent: Mr W Willan

Agent: Townsend Planning Consultants

The housing proposals at or near to Holme Wood are far more scaled back than that proposed in previous consultations. The representation site was previously identified as part of previous development proposals and identified as an area to potentially be removed from the Green Belt.

It is considered that the site should be allocated as previously intended as the site forms a logical extension to the settlement and would assist the Council meeting its housing need

Comment

Representation ID: 9798

Received: 12/03/2021

Respondent: Bradford District Ward Councillor (Labour)

SP 5 identifies 2 areas in my ward. Obviously, we are attached to both, though Black Hill would be more acceptable. The problem overall is the declining use for agriculture, and I wonder if as an adjunct to the bad bits we should be looking at re-wilding projects in the undeveloped greenbelt.

Comment

Representation ID: 10328

Received: 24/03/2021

Respondent: Barratt Homes and David Wilson Homes Yorkshire West

Agent: Sheppard Planning

Green Belt.

We generally support the content of Draft Policy SP5, including the removal of site QB7/H.

However, we are concerned about this policy on two grounds:
1) The Plan does not identify enough land to meet OAN, as it does not provide for the 35% uplift as noted elsewhere in this representation. Therefore, it does not remove enough land from the Green Belt to provide for the needs of the current Plan Period.

2) The Plan does not provide for Safeguarded Land, as such it does to provide for longer term development needs, beyond the current Plan Period.

Object

Representation ID: 10943

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We support the Council’s position that exceptional circumstances exist to release land from the Green Belt. However, we object to part B of the policy in that it does not identify land at Queensbury Golf Course for development.

We recognise that this is because the site has not previously been put forwards as a suitable and available site for redevelopment - we can confirm that the site is fully available, suitable and deliverable and should therefore be fully considered in the Council’s evidence base and SA going forward with the view to allocate the site for housing development in the regulation 19 Plan.

To not do so would represent a major departure from the adopted Spatial Strategy for the area where Queensbury was allotted a target of 1,000 homes. Departing from this is not currently justified.

The Council has not sought to identify safeguarded land - this is contrary to NPPF para 139.

Object

Representation ID: 11015

Received: 17/03/2021

Respondent: The Strategic Land Group

Agent: Walsingham Planning

The Council should define the areas for proposed Green Belt release required to enable the revised minimum annual local housing need figure of 2,300 new homes/year to be met/exceeded.

The adopted Core Strategy outlines that around 11,000 homes are required to be delivered within the Green Belt to meet the minimum housing requirement outlined in that document. Adopting a minimum annual local housing need figure of 2,300 new homes/year for the new proposed plan period will require a similar scale of Green Belt release.

Within such a context, Site Reference NW/020 – Haworth Road, Sandy Lane should evidently form one of the allocated Green Belt release sites for housing.

Safeguarded Land - In any document proposing allocations or Green Belt release locations should also include indications of proposed Safeguarded Land to meet future needs, or to provide flexibility should any of the allocated sites provide undeliverable during the plan period.

Comment

Representation ID: 11375

Received: 17/03/2021

Respondent: Mr Robert Felstead

Wish to understand Council’s definition of “exceptional circumstances” in the context of the NPPF. Arguable where all other reasonable options for meeting housing needs have been fully examined. Accept that some elements of brownfield are unviable. Queried as to why these sites remain unviable after 16 years post identification.

In calculating the housing requirement figure ahead of finding new land allocations, the number of vacant dwellings should be subtracted from the overall total, together with provision that could come from unviable brownfield sites. Creates a different perspective on where housing and regeneration should be directed.

Meeting employment land requirements in neighbouring areas, wouldn’t contribute to the district employment needs because, “3.31 ... Bradford District is a self-contained housing market area.

Object

Representation ID: 12166

Received: 19/03/2021

Respondent: Highways England (Yorkshire & North East Team)

It is recommended that Highways England does not support the release of sites within the Green Belt as they are likely to be unsustainable in terms of their location and reliance on singleoccupancy private vehicle trips.

However, should these sites emerge through the Local Plan process then they should be supported by a robust transport evidence base.

Object

Representation ID: 13320

Received: 24/03/2021

Respondent: Mitre Residential LPP

Agent: DPP Planning

In the context of the acute and intense need for housing, it is considered that Policy SP5 is not fit for purpose and the Landowner objects to the proposed policy as it does not allocate enough housing to meet the needs of the District and the 35% uplift. We suggest that additional sites should be released from the Green Belt and allocated for housing and believe that this can be done without materially harming any of the five purposes of the Green Belt.

Object

Representation ID: 13808

Received: 20/03/2021

Respondent: John Finnigan

-Inappropriate to propose Green Belt release/site allocation before viability and line of the SEBAR have been established.
- Inappropriate to propose Green Belt release to the south or east of the line of the SEBAR if it is intended to form the “defensible long-term boundary to the SUE”. (SE37/E & SE38/H)

Object

Representation ID: 15755

Received: 24/03/2021

Respondent: Anne Arana

I wish to register my objections most strongly to all building in the Local Plan which infringes on the Green Belt and does not use the many Brownfield sites available throughout the District. In particular I wish to object to HA1H, HA2H, HA3H, HA4H.

Object

Representation ID: 15757

Received: 24/03/2021

Respondent: Mr John Thompson

Addingham is designated a SMALL SERVICE CENTRE and as such does not have the infrastructure to support large numbers of additional housing especially at the western side of the village.

The need for developing these Green Belt sites has not passed the National Planning Policy Framework (NPPF) policy test of "exceptional circumstances". These exceptional circumstances do not exist locally.

What is the thought process behind designating land as green belt if this designation has no bearing on building plans? It would appear to me that this housing allocation plan has been drawn up with little logic. I am therefore worried that any argument derived from logic or reason will have no weight as there may be ulterior motives at play.

Object

Representation ID: 16265

Received: 22/03/2021

Respondent: Robbie Feather

Agent: ID Planning

Safeguarded Land

The supporting text of the policy refers to Safeguarded land and states that land has not been safeguarded in the plan to reduce the harm to the Green Belt as a result of reducing the amount of land released from the Green Belt. In addition, paragraph 3.5.27 of the plan states that the Governments focus of housing uplift of 35% shows a greater intent for the development in urban areas rather than in greenfield/ green belt locations.

We object to the statement in two respects. Firstly, the plan should identify areas of safeguarded land on the Policies Map to meet longer term development need for housing and ensure that Green Belt boundaries can endure beyond the plan period.

Secondly, the statement at paragraph 3.5.27 of the Plan conflicts with the policy text which details that exceptional circumstances exist for the release of Green Belt. Clearly if there were suitable, deliverable and available sites in urban areas there would not be exceptional circumstances to support the release of Green Belt.

Additional Green Belt sites and Safeguarded land should be allocated to support the delivery of the housing in the district over the plan period. As a result of the full Green Belt review carried out, Safeguarded land should be allocated to ensure the longevity of the Green Belt and avoid the need for future partial reviews of the plan.

Required Change
The policy and policies map should be amended to provide additional releases of Green Belt sites and Safeguarded land allocations to ensure the longevity of Green Belt boundaries whilst ensuring the housing requirement is met.

Object

Representation ID: 16336

Received: 24/03/2021

Respondent: Newett Homes

Agent: Quod North

Newett Homes agree that Exceptional Circumstances exist for the removal of Green Belt land to accommodate BCC’s housing and infrastructure needs.

However, BCC do not go far enough to sufficiently satisfy Paragraph 136 of the NPPF. The proposed approach (to not allocate sufficient homes to meet the Standard Method + 35% housing requirement) will not ensure the endurance of new Green Belt boundaries beyond the plan period and will make the DBLP’s provisions unsustainable.

Newett Homes are promoting two neighbouring sites in Wilsden, with one having been rejected as a potential allocation by Officers on grounds of landscape impact. This is despite having previously been demonstrated by Newett Homes as suitable for development and having a negligible impact on Green Belt objectives.

Exceptional Circumstances exist to release this (and similar sites) to ensure important development and infrastructure needs are met over the plan period and covered by a robust supply of land.

Comment

Representation ID: 16604

Received: 24/03/2021

Respondent: Jude Hamon

I'm emailing in response to the plans for new-build houses in Ilkley, however I would appreciate it if you would consider my thoughts for any new housing areas you are planning to build in the years ahead.

Although I'm not massively in favour of building new houses, I appreciate that they are needed due to the ever increasing population in the UK. My initial concern would be to avoid greenbelt land but I think we're pretty well only left with that now so the main point I'd like to raise is the possibly of building houses which are carbon neutral, are designed with environmentally friendly boilers, solar panels etc and also are nature friendly so include swift bricks etc.

Object

Representation ID: 16718

Received: 24/03/2021

Respondent: Shipley Town Council

The draft local plan identifies over 65 housing sites in the current Green Belt.

We do not agree that Bradford Council has justified the exceptional circumstances for building on the Green Belt on the edge of Shipley. There is underutilised land in Shipley nearer Shipley Town Centre that could be used for development. See our specific comments on the proposed housing sites for more detail.

Also analysing some of the Green Belt sites indicates net densities averaging around 26 dpha – well below the draft Plan’s policy HO2 of a minimum of 35 dpha, and even further below the 50 dpha that we consider all site allocations should be required to achieve. There is no sound rationale for releasing Green Belt land if the result will be 5,000 homes developed at non-policy compliant densities.

We also cannot see how developments on Green Belt and greenfields will lead to the biodiversity net gain as the Council sets out it wants to achieve in Policy EN2: Biodiversity.

Object

Representation ID: 16747

Received: 24/03/2021

Respondent: Addingham Civic Society

There are no exceptional circumstances for the number of green belt sites identified for housing development in Addingham. The increase in the housing target for Addingham when other settlements have had their targets reduced is unjustified and contrary to some of the principles set out for Local Service Centres.

Object

Representation ID: 16958

Received: 23/03/2021

Respondent: Avant Homes

Agent: ID Planning

Object (para 3.5.27): We consider the 35% housing uplift should be applied to the requirement; this would require greater greenbelt release to ensure sufficient sites are provided to meet the requirement. The plan should identify additional green belt sites to meet a higher requirement based on the 35% uplift. In addition, areas of safeguarded land should be shown on the Policies Map to address under-delivery and be available if a five year housing land supply cannot be met. Areas identified for Safeguarded land will meet longer term development needs for housing and ensure that Green Belt boundaries can endure beyond the plan period.

Required Change
The policy and policies map should be amended to provide additional releases of Green Belt sites and Safeguarded land allocations to meet the housing requirement and ensure the longevity of Green Belt boundaries whilst ensuring the housing requirement is met.

Object

Representation ID: 16986

Received: 18/03/2021

Respondent: Bingley Town Council

BMDC Local Plan Policy SP5 Green Belt states that: ‘All sites identified as being released from the Green Belt will be required to offset the impact of removing land from the Green Belt through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land.’ Surely it is incumbent on Bradford Metropolitan District Council to define exactly how and when this should be achieved. The destruction of the Green Belt and requirement for mitigation cannot be left to vague promises without any firm resolution or requirement for action from developers.

Support

Representation ID: 17113

Received: 24/03/2021

Respondent: Caddick Developments Ltd

Agent: DPP Planning

We support the need to release land from the Green Belt under Policy SP5 and we agree that exceptional circumstances exist to amend the Green Belt.

In particular and with regard to the need provide a strategic employment allocation we strongly support the release of land from the Green Belt at Apperley Bridge, namely NE22/E and NE23/E.

However, we have reservations about the housing requirement and housing distribution set out in Policy SP8 and the knock-on effects this might have to Policy SP5.

We would suggest the housing requirement should be increased and that the Plan should decrease the proportion of the housing requirement being directed to Bradford City Centre and increase the amount of land to be released from the Green Belt for housing development.

Object

Representation ID: 17125

Received: 24/03/2021

Respondent: Countryside Properties Yorkshire

Agent: DPP Planning

In the context of the acute and intense need for housing we consider that the Site should be allocated for development and that such an allocation would not materially harm any of the purposes of the Green Belt.

We suggest that additional land should be released from the Green Belt and allocated for housing. In this context we object to the omission of the Site from the list of allocations in Policy SP5. We also strongly object to the stance of the Council in not allocating safeguarded land or allocating sufficient land to ensure that the Green Belt, when redefined, will be permanent.

Object

Representation ID: 17132

Received: 24/03/2021

Respondent: Addingham Civic Society

This proposed increase in housing target for Addingham will result in the partial development of the “Sailor Fields” between the village and the A65 by-pass. It will destroy the linear nature of the village and the setting of its 129 listed buildings and monuments. It will also negatively impact the distinctive Dales landscape and bring new development into the South Pennine SAC/SPA Protection Zone.

The Green Belt was established to protect the “Sailor Fields” and this important function was confirmed by the Planning Inspectorate and BMDC itself. No “exceptional circumstances” have been put forward for these Green Belt changes.

These proposals are contrary to Addingham’s Neighbourhood Plan

Support

Representation ID: 17164

Received: 24/03/2021

Respondent: The Norris & Holmes Families

Agent: Savills

In order to meet its housing requirement as defined under Policy SP8 and employment requirement as set out under Policy SP6 and with all reasonable alternatives having been explored, we agree with the Council’s conclusions that exceptional circumstances do exist which justify and require a change to the general extent of the Green Belt as set out in the Plan.

Detailed comments are made with regards to the green belt site assessment of NE19/H which differ in some respects from the Council's assessment.

For example it considered that the site does not perform any role with regards to safeguarding the countryside from encroachment.

Recommendation 3: We support our client’s land, site NE19/H, as a residential allocation and its subsequent
release from Green Belt.

Object

Representation ID: 17171

Received: 24/03/2021

Respondent: Jones Homes (Yorkshire) Limited

Agent: Savills (UK) Ltd

Recommendation 6: Policy SP5 on Green Belt is amended to allow for greater release of Green Belt land to meet the stated ‘acute and intense need for housing’ identified.

Recommendation 7: The land south of Shipley Golf Course, previously referenced within the 2015 SHLAA as CO/006 ‘Hazel Beck, Cottingley Bridge’ should be included within both Policy SP5 and the Proposals Map for release from the Green Belt, as a sustainable site with a very weak contribution to the existing Green Belt.

An assessment of the site against the 5 green belt purposes is provided.

Support

Representation ID: 17421

Received: 23/03/2021

Respondent: Mr & Mrs . Pyrah and Saunders

Number of people: 4

Agent: ID Planning

Support subject to amendment.

We support the proposed Green Belt releases to provide sustainable sites to deliver the current identified housing requirement.

The supporting text of the policy refers to Safeguarded land and states that land has not been safeguarded in the plan to reduce the harm to the Green Belt as a result of reducing the amount of land released from the Green Belt. In addition, paragraph 3.5.27 of the plan states that the Governments focus of housing uplift of 35% shows a greater intent for the development in urban areas rather than in greenfield/ green belt locations.

We object to the statement the plan should identify areas of safeguarded land on the Policies Map to meet longer term development need for housing and ensure that Green Belt boundaries can endure beyond the plan period.

Required Change
The policy and policies map should be amended to provide additional releases of Green Belt sites and Safeguarded land allocations to ensure the longevity of Green Belt boundaries whilst ensuring the housing requirement is met.

Support

Representation ID: 17516

Received: 23/03/2021

Respondent: Barratt Homes and David Wilson Homes

Agent: ID Planning

We support (with amendments) the proposed Green Belt releases to provide sustainable sites to deliver the current identified housing requirement.
The supporting text of the policy refers to Safeguarded land and states that land has not been safeguarded in the plan to reduce the harm to the Green Belt as a result of reducing the amount of land released from the Green Belt. In addition, paragraph 3.5.27 of the plan states that the Governments focus of housing uplift of 35% shows a greater intent for the development in urban areas rather than in greenfield/ green belt locations.
We object to the statement in two respects. Firstly, the plan should identify areas of safeguarded land on the Policies Map to address under-delivery and be available if a five year housing land supply cannot be met. The identified for Safeguarded land meets longer term development need for housing and ensures that Green Belt boundaries can endure beyond the plan period.
Secondly, the statement at paragraph 3.5.27 of the Plan conflicts with the policy text which details that exceptional circumstances exist for the release of Green Belt. Clearly if there were sufficient suitable, deliverable and available sites in urban areas there would not be exceptional circumstances to support the release of Green Belt. Additional Green Belt sites and Safeguarded land should be allocated to support the delivery of the housing in the district over the plan period. As a result of the full Green Belt review carried out, Safeguarded land should be allocated to ensure the longevity of the Green Belt and avoid the need for future partial reviews of the plan.
Required Change
The policy and policies map should be amended to provide additional releases of Green Belt sites and Safeguarded land allocations to meet the housing requirement and ensure the longevity of Green Belt boundaries whilst ensuring the housing requirement is met.

Support

Representation ID: 17685

Received: 23/03/2021

Respondent: Bannister Investments Limited

Agent: ID Planning

Support subject to amendment.
We support the proposed Green Belt releases to provide sustainable sites to deliver the current identified housing requirement.
The plan should identify areas of safeguarded land on the Policies Map to address under-delivery and be available if a five year housing land supply cannot be met. The identification of Safeguarded land meets longer term development need for housing and ensures that Green Belt boundaries can endure beyond the plan period.
We consider the 35% housing uplift should be applied to the requirement. This would require greater green belt release to ensure sufficient sites are provided to meet the requirement. The plan should identify additional Green Belt sites to meet a higher requirement based on the 35% uplift.
Required Change
The policy and policies map should be amended to provide additional releases of Green Belt sites and Safeguarded land allocations to meet the housing requirement and ensure the longevity of Green Belt boundaries whilst ensuring the housing requirement is met.

Object

Representation ID: 18031

Received: 24/03/2021

Respondent: Harworth Group & Nufarm UK Ltd

Agent: Johnson Mowat

Please also refer to our comments on Policy EC1

Harworth and Nufarm object to the inclusion of sites NE22/E and NE23/E within the list at part C of draft Policy SP5 as these sites should not be allocated as employment sites.

Site NE22/E (see Section 5), this should be removed outright.

Site NE23/E should be developed for employment use only if planning permission is granted on the basis of ‘very special circumstances’ being demonstrated. Given a planning application is currently being considered by the Council, it is not necessary to remove this site from the Green Belt and allocate it as an employment site.

Alternative wording for Part D of draft Policy SP5 relating to NE23/E is given (see submission document). The proposals map should also be amended.

A further change to the Green Belt is justified in the location south and east of the Nufarm UK Ltd factory at Wyke to accommodate a strategically located allocation for employment development and to safeguard additional land.

Object

Representation ID: 18034

Received: 24/03/2021

Respondent: Harworth Group & Nufarm UK Ltd

Agent: Johnson Mowat

Safeguarded Land:

A safeguarded land designation may be appropriately used in the location broadly south and southeast of the Nufarm UK Ltd factory and north of the land we propose for employment allocation at Whitehall Road, Wyke

This will serve to allow a single, rational change to be made to be made to the Green Belt boundary in this location, whilst limiting the extent of the suggested employment allocation area to that which is currently deliverable in a manner compatible with the existing Nufarm UK Ltd business. It then allows flexibility for allocation of further employment land in this location at a future plan review stage without change to the Green Belt and on the basis of satisfactory relationship with the Nufarm UK Ltd business.