Sustainability Appraisal & Strategic Environmental Assessment - Appendix E - SUE Assessments

Support

Representation ID: 28165

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

We welcome the fact that analysis is given within the SA of the collective SUE as well as the individual site assessments.

Object

Representation ID: 28169

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

The Holmewood SUE receives a minor adverse effect against the Climate Change resilience objective (Objective 4), however individually, the Holme Wood South sites all score a minor positive effect against this objective.

We disagree with the overall minor adverse effect which relates to the overall long-term impacts of greenfield land being replaced with built form and the potential effects on the local extent of surface water flood risk. Holme Wood South lies in Flood Zone 1, and the site’s climate change resilience could be improved with the inclusion of Green Infrastructure, as illustrated on the Masterplan. The inclusion of SUDs and appropriate drainage strategies via comprehensive masterplanning will ensure that there is no increased surface water flood risk. The SUE score against this objective should be a minor positive.

Object

Representation ID: 28170

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

The SUE receives a major adverse effect against the Cultural Heritage Objective (Objective 8), however the individual sites of Holme Wood South score a neutral effect for sites SE19/H and SE49/H and a minor adverse effect for sites SE46/H and SE47/H against this objective. There are no listed buildings within Holme Wood South. Reference to there being six Grade II Listed Buildings, each being historic farm buildings, as well as the Grade II* listed Ryecroft Hall is incorrect and refers to a larger site SE/100 which is not proposed in full in the Draft Local Plan. There are no listed buildings within the Holme Wood South sites. The scoring needs reassessing and marked neutral.

Object

Representation ID: 28171

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

We disagree with the SA scoring against Objective 10: Transport which is predicted a minor adverse effect. This is unduly negative, considering the proximity of Holme Wood South to existing bus stops along Westgate Hill Street, the existing and proposed connections into the existing Holme Wood estate, and the proposed bus route, as indicated on the Masterplan. It is considered the score should be amended to a minor positive at least.

Object

Representation ID: 29962

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

SUE Assessments - Holme Wood / Sites at Holme Wood

Chapter 6 of the Sustainability Appraisal (2021) is dedicated to assessing the SUE options. One of the sites assessed is that of the proposed Holme Wood SUE site (ref: SS/005). The Holme Wood SUE site encompasses the seven individual housing sites which make up the Holme Wood North and Holme Wood South sites, as depicted within Appendix F, focusing on the South Bradford Urban Area.

Clearly the overarching assessment for the Holme Wood SUE site contradicts the assessment of the smaller individual sites.

Object

Representation ID: 29963

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

SUE Assessments - Holme Wood / Sites at Holme Wood

Reasonable Alternatives

In line with NPPF and PPG guidance we note that BMDC have reviewed both the draft sites and reasonable alternatives for the SUEs, with a summary of assessments for reasonable alternatives shown at Appendix E.

Yet Raikes Hall Farm, Holme Wood (SE/163) had been omitted as part of the SUE reasonable alternatives with no rationale. By ignoring Raikes Hall farm from the assessment of reasonable alternatives BMDC are not in accordance with the requirements of the NPPF and a point of legal procedure, in ensuring all reasonable alternatives are assessed.

We have therefore provided a Savills Assessment for both sites incorporating all the SA objectives to enable a comparison between the two, in accordance with the NPP - it highlights that there is nothing to split the two sites apart. The assessment clearly highlights our client’s land under SE/163 is a sustainable option with the added benefit over SS/005 of significant regeneration credentials to Holme Wood. The SUE should therefore be reallocated and extended to include more growth at Holme Wood North and assessed on this basis.

Comment

Representation ID: 30193

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

We agree with the major positive scores awarded to the Housing, Accessible Services, Social Cohesion, Education, Employment and Economy objectives for the SUE (Objectives 11, 12, 13, 17, 18 and 19). However, we there is an error in the scoring of the individual site scores against the Education Objective for sites SE46/H, SE47/H and SE48/H which all incorrectly state that the nearest secondary school is Tong Leadership Academy, when in fact the nearest Secondary School is Tong High School, located to the immediate west of Holme Wood South as indicated on the Opportunities and Constraints Plan at Appendix 1. These scores need revisiting.