Sustainability Appraisal & Strategic Environmental Assessment - Appendix F - Airedale

Object

Representation ID: 11482

Received: 24/03/2021

Respondent: Tracy Mosley

I would like to share my concerns regarding section 5.8.33. Here it is mentioned that the four Baildon primary schools are under capacity. By what extent? Detail is not provided. I would regard this as both an oversight and essential information considering the claimed major positive effect on the education SA objective for these proposed development areas.

Ref to the assessments of sites BA1/H, BA2/H, BA4/H, BA5/H & BA6/H

Object

Representation ID: 18417

Received: 24/03/2021

Respondent: The Wright Trust

Number of people: 2

Agent: Johnson Mowat

Regarding sites BA2/H and BA6/H

The site-specific text summarises the Sustainability Appraisal assessment, which refers to the predicted effects of development. The scores against the objectives are identical for both sites.

Over half of the 17 objectives of these sites are given a positive score, these relate to climate change resilience, transport, housing, social cohesion, culture and leisure, health, education, employment and economy. The minor adverse effects relate to the range of natural environment themed objectives as a result of the proposed development taking place on greenfield and Green Belt land. A minor adverse effect is predicted against cultural heritage, which is discussed in detail below.

A major adverse effect is predicted against the biodiversity and geodiversity objective, which we consider is negatively scored. There are significant opportunities to improve ecological connectivity at the site as well as provide new Green Infrastructure and significant new open space and landscape features. Existing trees are proposed to be retained. The opportunities here are not reflected in the negative SA scoring against objective 6, and should be revisited.

Object

Representation ID: 29514

Received: 24/03/2021

Respondent: The Illingworth Family

Agent: Johnson Mowat

The site-specific text summarises the Sustainability Appraisal assessment, which refers to the predicted effects including adverse effects relating to cultural heritage and positive effects for most socio-economic themed objectives and those relating to the location of the site in terms of proximity to transport links and services and facilities.

It is recognised that there are heritage considerations with the development of this site, due to the proximity of the site to the setting of Whinburn Lodge and gardens, and yet the site is included as a preferred allocation. We are confident that any heritage constraint can be factored in to the design of a deliverable scheme. It is noted that the Council’s Heritage Impact Statement for this site refers to the mitigation measures and opportunities to enhance the significance, which refers to strengthening the landscaped/ tree boundary along the north western and south-western boundaries of the site and retaining / rebuilding the dry-stone boundary walls.

Object

Representation ID: 29544

Received: 24/03/2021

Respondent: The Thompson Family

Agent: Johnson Mowat

The site scores only a minor positive against contributing to satisfying Bradford housing needs. It is considered this is a major positive.

We disagree with some of the negative scores against the following objectives:

• Land and buildings
• Water resources
• Biodiversity and geodiversity
• Landscape and Townscape
• Cultural Heritage
• Air Quality
• Accessible Services

Object

Representation ID: 29550

Received: 24/03/2021

Respondent: The Black Family

Agent: Johnson Mowat

The site scores only a minor positive against contributing to satisfying Bradford housing needs. It is considered this is a major positive.

We disagree with some of the negative scores against the following objectives:

• Land and buildings
• Water resources
• Biodiversity and geodiversity
• Landscape and Townscape
• Cultural Heritage
• Air Quality
• Accessible Services

Object

Representation ID: 29857

Received: 24/03/2021

Respondent: Mr & Mrs A Kemp

Agent: Heritage Planning Design Ltd

Site BI3/H (SLA ref - BI/011)

Objections are made to the following assessments:

Objective 6 - Biodiversity & geodiversity
The (major negative) assessment is presumptuous and maybe overly pessimistic.

Some of the site is planted with Norway Spruce and Scots Pine trees, which were planted as crops around 20 years ago and are harvested from time-to-time. It is believed that the site’s ecological value is low and could be maintained or enhanced by compensatory planting of native trees and shrubs that are known to support biodiversity and which would help to maintain ecological connectivity. Furthermore, my Client also owns the land edged blue on the plan attached as appendix 2, which could be made available for off-site ecological enhancement proposals, such as a new semi-natural waterbody.

The existence of protected trees and woodland to the east is noted. However, these areas do not include public rights of way and are not publicly accessible. The likelihood of harm arising from the development of BI3/H is negligible.

At worst, the site should be assessed as - (minor negative) against this objective. However, there is scope for a neutral or even positive impact upon biodiversity, a matter that will be addressed by the forthcoming pre-application enquiry.

Objection 8 - Cultural Heritage
The site is assessed as (minor negative) against this sustainability objective as there is said to be potential for a “minor adverse alteration” to the setting of Greenhill Crag, which is a grade II listed building, located around 50m to the north east.

However, a strong degree of physical and visual separation is provided between the listed building and development site by a belt of coniferous woodland that my Client intends to retain and enrich. Subject to this the listed building will continue to benefit from a high quality rural setting and there will be a neutral or negligible impact upon its setting and special interest, as confirmed by the Heritage Impact Assessment attached as appendix 3. The site should be assessed as O (neutral/ negligible).

Object

Representation ID: 29858

Received: 24/03/2021

Respondent: Mr & Mrs A Kemp

Agent: Heritage Planning Design Ltd

Site BI3/H (SLA ref - BI/011)

Objections are made to the following assessments:

Objective 12 - Accessible Services
The site is assessed as (minor negative) against this sustainability objective.

However, within the SA I have been unable to find the definition of “accessible services” or “key services,
amenities and or facilities”, which must be within 600m of the site to achieve a positive assessment. Nearby facilities include Lady Lane Park School that is within 300m of the site, and Oakwood Hall Hotel, which includes a publicly accessible bar and restaurant, is just over 300m from the site. It is suggested that these are key services, amenities and facilities that justify a – (minor positive) assessment.

Objection 17 - Education
The site is erroneously assessed as - (minor negative) against this sustainability objective. It is located within 300m of Lady Lane Park School, which provides infant and junior education, and just over 1km from Bingley Grammar School, which provides secondary education (Beckfoot School is not the nearest secondary school). It is believed that both schools have some capacity for new students and the site should therefore be assessed as ++ (major positive).

Support

Representation ID: 29869

Received: 24/03/2021

Respondent: Stuart Brook

Agent: Heritage Planning Design Ltd

Site KY36/H (SLA site KY/114)

Overall, the SA is positive, and this is welcomed

Object

Representation ID: 29870

Received: 24/03/2021

Respondent: Stuart Brook

Agent: Heritage Planning Design Ltd

Site KY36/H (SLA site KY/114)

Regarding surface water flooding, a deliberate gap has been left between two land drains to create a drinking pool for cows, which can be easily made good by reconnecting the pipes. My Clients, who have owned the land for decades, have never witnessed any surface water flooding attributable to run-off. It is anticipated that any surface water flood risk could be addressed by a competent Engineer and Architect. Measures might include avoiding the construction of buildings on the parts of the site at the highest theoretical risk of surface water flooding and raising floor and/or land levels.

Support

Representation ID: 29888

Received: 24/03/2021

Respondent: Kathleen Simpson

Agent: Heritage Planning Design Ltd

Site KY36/H (SLA site KY/114)

Overall, the SA is positive, and this is welcomed

Object

Representation ID: 29889

Received: 24/03/2021

Respondent: Kathleen Simpson

Agent: Heritage Planning Design Ltd

Site KY36/H (SLA site KY/114)

Regarding surface water flooding, a deliberate gap has been left between two land drains to create a drinking pool for cows, which can be easily made good by reconnecting the pipes. My Clients, who have owned the land for decades, have never witnessed any surface water flooding attributable to run-off. It is anticipated that any surface water flood risk could be addressed by a competent Engineer and Architect. Measures might include avoiding the construction of buildings on the parts of the site at the highest theoretical risk of surface water flooding and raising floor and/or land levels.

Object

Representation ID: 29916

Received: 24/03/2021

Respondent: The Laver Family

Number of people: 2

Agent: Johnson Mowat

Regarding sites BA2/H and BA6/H

The site-specific text summarises the Sustainability Appraisal assessment, which refers to the predicted effects of development. The scores against the objectives are identical for both sites.

Over half of the 17 objectives of these sites are given a positive score, these relate to climate change resilience, transport, housing, social cohesion, culture and leisure, health, education,
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Draft Bradford District Local Plan – Preferred Options Consultation March 2021
employment and economy. The minor adverse effects relate to the range of natural environment themed objectives as a result of the proposed development taking place on greenfield and Green Belt land. A minor adverse effect is predicted against cultural heritage, which is discussed in detail below.

A major adverse effect is predicted against the biodiversity and geodiversity objective, which we consider is negatively scored. There are significant opportunities to improve ecological connectivity at the site as well as provide new Green Infrastructure and significant new open space and landscape features. Existing trees are proposed to be retained. The opportunities here are not reflected in the negative SA scoring against objective 6, and should be revisited.

Object

Representation ID: 30147

Received: 23/03/2021

Respondent: Clive Brook Planning

THE SUSTAINABILITY APPRAISAL OF SITE EM/005

Given the description of the site and the summary assessment it appears that the larger site containing the southern residential curtilage and buildings has been included. This mistake needs to be rectified and a site sustainability re-assessment carried out.

Many documents have been provided and were covered in the formal pre-app assessment referred to in this response. It does not appear that these have been fully taken into account.

COMMENTS IN RELATION TO SPECIFIC SUSTAINABILITY CRITERIA USED

Criterion 3 Land and Buildings – the site has a better rating than the preferred allocation site- EM/007.

Criterion 4 -Climate Change resilience- It is not clear why this site is rated green pink- and the preferred site green+ when both are in FZ1 and there is only a very small area of differential which may be in the southern section of the site which should not have been included.

Criterion 6 Biodiversity and Geodiversity- Account needs to be taken of the proposals for the outline biodiversity, recreation and other environmental improvements which are proposed for this site and which are wholly capable of being accommodated on site. This does not apply to site EM/007.

Criterion 7 Landscape and Townscape- Landscape improvements have been discussed with officers at the pre-app meeting and are included in submissions. There is full potential to improve the current landscape as well as accommodating the proposed level of development, subject to detailed site planning and negotiations.

Criterion 10- Transport- Cliff Delph scores better than the preferred site.

Criterion 12- Accessible Services- the Cliff Delph site is marginally preferable to the preferred allocation.

Criterion 17 Education- Cliff Delph again scores better on access to schools.

Based on this rational comparison of performance the Cliff Delph site EM/005 is preferable to the much smaller selected allocation site EM/007.