Sustainability Appraisal & Strategic Environmental Assessment - Appendix F - North Bradford, City Centre, Canal Road

Showing comments and forms 1 to 9 of 9

Object

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 28239

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Mrs Gen Kenington

Representation:

NW9/H

Site NW9/H has been individually assessed in the Sustainability Appraisal against the 17 sustainability appraisal objectives, with 9 of the scores being positive, relating in particular to most socio-economic themed objectives and the location of the site in relation to education, employment and health.

We disagree with the major adverse scoring of the site against the biodiversity and geodiversity criteria (SA Objective 6), which refers to a reduction in biodiversity value and local ecological connectivity. Design considerations including and appropriate green space, additional landscaping and habitat creation could improve and enhance biodiversity value and retain ecological connectivity. The scoring should be amended to a neutral effect.

Full text:

Dear Sir or Madam,

Please find the attached representation to the Preferred Options Draft Local Plan in relation to Preferred Site NW9/H off Wilsden Road, Sandy Lane, Allerton that has been prepared on behalf of our client Hallam Land Management.

Please could you acknowledge receipt of the attachment.

I look forward to hearing from you,

Object

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 28307

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Mrs Gen Kenington

Representation:

Sites NW10/H and Site NW/024

Both Site NW10/H and the whole extent of NW024 have been individually assessed in the Sustainability Appraisal against the 17 sustainability appraisal objectives.
The sites score almost identically against the criteria, with the exception of 3 criteria as explained below.

- Water Resources: The larger site NW/024 receives a major adverse effect against Criteria 5 – Water Resources, whereas Site NW10/H receives a minor positive score. We disagree with the major adverse score. The difference appears to relate to the presence of waterbodies within the site boundary of NW/024. This however should not result in an adverse rating. The existing pond located in the south west part of the site is not a constraint to development and provides an opportunity to retain and include as part of the green infrastructure strategy that provides a habitat rich environment. As identified on the Masterplan, this can be incorporated into SUDs and swale features within the site. It is considered the score should be amended to a minor positive in alignment with NW10/H.

- Biodiversity and geodiversity: Site NW10/H receives a major adverse score, whereas NW/024 receives a minor adverse score against this objective. We disagree with both scores. Both sites provide an opportunity to enhance biodiversity value, with the provision of open space, green infrastructure and additional landscaping. It is considered that the score should be amended to a neutral score for both sites.

- Housing: Given the size of NW/024 and the development scale, Site NW/024 receives a major positive score against this criteria compared with NW10/H minor positive score.

Full text:

Dear Sir or Madam,

Please find the attached representation to the Preferred Options Draft Local Plan in relation to Preferred Site NW10/H and the excluded remaining part of NW/024 on the western edge of Allerton, that has been prepared on behalf of our client Hallam Land Management who have a continued interest in the land.

Please could you acknowledge receipt of the attachment.

I look forward to hearing from you,

Object

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 28514

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

Representation:

Of concern is the Council’s Sustainability Appraisal , which has been prepared by Arcadis, which undertakes an assessment of all sites which have been put forward through the SHLAA process whether they are proposed allocations or rejected sites. However, no assessment of our Clients site in Nab Wood (SH/044) has been undertaken and as such, the Council have not fully assessed all potential alternatives.

Full text:

Dear Sir/Madam,

We have been instructed by our Client, Chartford Homes to make representations to the draft Local Plan in respect of their following land interests. These representations comment on the overarching strategic and thematic policies as well as providing site specific comments regarding their land interests in Nab Wood. It should be noted that a further set of site specific representations regarding their land interests in Addingham will follow shortly under separate cover.

I would be grateful if you could acknowledge receipt of the submissions.

Object

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29503

Received: 23/08/2021

Respondent: Laura Gorman

Representation:

In Bradford Council’s Sustainability Appraisal element of the Core Strategy Partial Review Scoping Report (January 2019) it states that ‘Physcial [sic] activity rates are below the national average, contributing problems with ill health. Therefore, it will be important for policies should seek to ensure that opportunities are provided for local people to participate in physical activity in order to improve the health and well being of the area.’ [pg 13]
As this site is situated mid-way down a sloping hill, the houses directly above it (to the south) will have their view significantly impacted as will those whose houses are directly adjacent to the site. This is aesthetically damaging and might also impact on mental wellbeing as a relatively quiet area becomes significantly busier and noisier.
Again, in Bradford Council’s Sustainability Appraisal element of the Core Strategy Partial Review Scoping Report (January 2019) there is a statement, ‘Landscape - The landscape is an important feature of the area, forming a key part of its identity. There is a need to ensure that these landscapes are protected and enhanced, particularly those elements that contribute to their distinctive character. Emerging policies and proposals should seek to maximise the benefits from the landscape character assessment to make decisions about the location and design of new development.’ [pg14] One neighbour referred to this development as taking the ‘Wood’ out of Nab ‘Wood’.
The same document makes this commitment, ‘Local Plan policy framework should ensure the protection, conservation and enhancement of biodiversity in line with the UK Biodiversity Action Plan.’ [pg 55] It can be argued that the proposed plans for Green Belt Land are not aligned to this commitment.

Full text:

I am writing to express my objections to the planning called SH4/H. I have the following concerns:

Traffic
With 164 houses and a conservative estimate of 1.3 cars per household, the proposed development would lead to approximately 200+ more cars in the area. The proposed access point for both entry and exit, Glenview Drive, is a small, narrow cul de sac ill-suited for such an increase in traffic. It feeds onto Glenview Road and, from there, onto other roads which are relatively narrow, with cars parked on the roads allowing space for only one car at a time. These roads are already incredibly busy with, for example, Bankfield Road being used as a rat run from Cottingley Cliffe Road down to the A650. This makes these roads dangerous currently, despite speed calming measures, and additional traffic from the SH4 plot would not only exacerbate this danger but also lead to traffic jams in the area at peak times. The proposal states that ‘Direct access from Cottingley Road (sic) is unlikely to be suitable’. Whilst that is the case, the increase in traffic would impact on that road as well, heading both into Bradford and towards Bingley, Haworth etc..

The roads heading towards Bingley from the Glenview end of Nab Wood, the A650 and Cottingley Cliffe Road, are already extremely busy roads with daily traffic jams at certain times, particularly at school times around Cottingley Village Primary School, and peak times for commuters trying to get onto the A650 (Bingley Road) from New Close Road. [Photographic evidence] Similarly, for those travelling on the A650 to Leeds, the M62 and Bradford City Centre etc., there will be increased bottlenecks at the Saltaire traffic lights, along Saltaire Road and beyond. These roads are not designed effectively for current traffic levels and the planned development will exacerbate this situation. [Photographs]

Whilst the proposed development at SH4 is just outside the World Heritage Site Buffer zone for Saltaire, increased traffic will have a significant impact on the heritage site, on Saltaire residents and on tourism in general. [https://www.bradford.gov.uk/media/2781/saltaireworldheritagesitebufferzone.pdf]

If you add to this the proposed developments at SH5 and SH6, then the road system would be under so much pressure that traffic jams would be continual, pedestrians would be under greater threat, and there would need to be significant improvements to infrastructure to alleviate the impact of the proposed plan. The proposed building and housing would also impact on the development and enhancement of the green corridor, a key priority for the Council.
Public Transport and Local Shops & Services
The plan indicates that the ‘Site [is] within 400m of a bus stop (Bingley Road/Saltaire Road) and beyond 800m of nearest rail station (Saltaire).’ It also states that ‘The plan for SH4 indicates an awareness that ‘residents would likely be required to travel beyond the target distance to access services and amenities.’ This recognises the poor access to public transport and amenities in this area proposed for development. People will travel by car to Saltaire, Shipley, Bingley and beyond in order to source anything from shopping to libraries to GP practices etc.
Air Pollution
The significant increase in cars for this development (and SH5/6) would lead to significant rise in air pollution, which is already a significant issue particularly around the A650. [https://naei.beis.gov.uk/emissionsapp/]. The proposal identifies this as an issue given that the land is within a Clean Air Zone , ‘A significant adverse effect has been predicted for the air quality SA Objective as a result of the site being situated entirely within the CAZ. Development here could potentially make achieving air quality improvement targets within the CAZ more difficult.’ Pollution from traffic is already high as a simple wall along the Bingley Road from Saltaire to the Bankfield site demonstrates and this is exacerbated during peak times (rush hour and school times) with standing cars adding to the pollution. The need to keep pollution levels within legal limits has become more important since the landmark case last December that air pollution was a factor in the death of a child in London. [https://www.theguardian.com/environment/2020/dec/16/girls-death-contributed-to-by-air-pollution-coroner-rules-in-landmark-case] We should be seeking ways of reducing traffic pollution rather than adding to it.
Schools
The plan states that it is ‘within the target distance for both primary and secondary education facilities.’ This is true, however it fails to take into account that the local primary school is already full. In a September 2019 letter from the Council in response to a query about proposed development in Cottingley, it is stated that three out of four Primary Schools in the area are full and two out of four Secondary Schools are full. This situation will not have improved since then. Action would need to be taken to improve and increase access to schools if the SH4/5/6 developments were to go ahead – as it stands now there is not the local educational infrastructure to support the proposed number of new houses.
Habitat and Bio-Diversity
This is a habitat that contributes to local and regional bio-diversity. The timing of the consultation means that it is not possible in winter/spring to undertake an ecological survey but local knowledge identifies that this space is not only an established woodland with mature trees (part of which extends further beyond the boundary of the proposed site
all the way to nearby Bankfield Road) but also home to: orchids, deer, badgers, foxes, tawny owls, barn owls and other raptors, and bats. This area is identified in the Friends of the Earth commissioned opportunity map for areas in England that could be suitable for creating woodlands. [https://takeclimateaction.uk/woodland-opportunity-mapping-england] This mapping identifies SH4 as a place suitable for increasing the woodland. This would not only increase the bio-diversity but also impact on water control.
Bradford’s 2020-2021 Sustainable Development Action Plan, responding to the climate emergency, talks of the importance of environmental stewardship, it states, ‘Living within environmental limits. The Council, with the powers, resources and influence at its disposal, will seek to ensure effective climate action and a safe and high quality local environment, actively working to have a positive impact on the rest of the world. Respecting the limits of our environment, resources and biodiversity and ensuring that the natural resources needed for life are unimpaired and remain so for future generations.’ [pg 7] [https://www.bradford.gov.uk/media/5841/sd-action-plan.pdf]

Flooding and Mining
The plan for SH 4 recognises that ‘the site consist of a large undulating open field which is steeply sloping in parts, with areas of mature trees and woodland within the site.’There are also water courses coming down through the field and through the residential area. The woodland and associated habitat provides some protection from flooding, but even that is insufficient. As recently as 2015, areas down the valley (including those around SH5/6) experienced serious flooding. [Photographs] The proposed plan would increase the likelihood of flooding as there would be little effectively done to mitigate the impact of 164 houses built on land currently acting to a certain degree as a flooding barrier.

Bradford’s Local Flood Risk Management Strategy (December 2016) which states, ‘The importance of sustainable development is both central to and influences flood risk, spatial planning policy and development management. Planning can influence flood risk measures though strategic policy allocations, policy measures and requirements of sustainable
drainage systems (SuDS), master planning, design and enforcement.’[pg 15] [https://www.bradford.gov.uk/media/4008/bradford-lfrms-final.pdf]
The Environment Agency Initial Assessment Report of Branksome Drive (November 2016) identified ‘Surface water flooding from run-off from the surrounding hills flowing towards the study area’ and as a possible cause. [Pg 7] [https://www.bradford.gov.uk/media/3730/branksome-drive-initial-assessment.pdf]
The plan for SH4 acknowledges that there are a number of small waterbodies (and mention is made of a possible risk to water quality by the development) and this plus surface water already contributes to flooding further down the valley. This risk to Branksome (including SH5 & 6) will be significantly increased through these developments at SH4.

It should also be noted that this area is an old mining area with evidence of shafts in most housing surveys – with some houseowners being advised of the need to have safety surveys done if they wished to have, for example, an extension built.
Mental and Physical Wellbeing
This piece of land is well visited by local residents and there are two Public Right of Way paths adjacent to the proposed site -Shipley 37 and Shipley 38. [https://cbmdc.maps.arcgis.com/apps/webappviewer/index.html?id=96f405cabeff443f820ac0c7df8fd658] If a local plan is designed to determine the future wellbeing of an area (in a broad sense) where people can thrive, then account has to be taken of wellbeing and mental health. A research article in 2009 indicated that ‘There is now a growing consensus that while personal factors are critical in determining health, the urban environment exacerbates or mitigates health and well-being outcomes. The level of active travel (walking and cycling) and outdoor recreational activity is strongly affected by accessibility to local facilities. Access to green, natural environments, and to local social networks, are factors in mental well-being.‘ [ https://www.researchgate.net/publication/222671013_Land_use_planning_and_health_and_well-being] The recent pandemic has highlighted this even more so with renewed engagement with local green spaces as people seek to alleviate the impact of covid and lockdowns on their physical and mental wellbeing. To remove well used green spaces is to remove opportunities for people to exercise and to engage with spaces and nature and will impact negatively on the health of local residents – which will then impact on the local health infrastructure.

Public Health England’s 2020 report ‘Improving Access to Greenspace’, states: ‘Local authorities play a vital role in…improving, maintaining and protecting existing greenspace’ (pg 12] and that local authorities like Bradford should ‘consider local greenspace to be a critical asset for maintaining and supporting health and wellbeing in local communities. The evidence base linking health and green space is compelling and encourages fresh thinking about the way these spaces can help meet local priorities’[pg 12][https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/904439/Improving_access_to_greenspace_2020_review.pdf]

Outcomes 2 and 4 of Bradford’s Joint Health and Wellbeing Strategy talk about access to green spaces and also about good mental wellbeing [pg 12]. It states that ‘Our ambitions for a healthy place are:
• Our homes and neighbourhoods, schools and workplaces are healthy places that support our wellbeing
• Improvements to our built environment make it easier to walk and cycle. New urban green space makes it easier to meet, play, connect to nature and be active…’ [pg 9]
[https://bdp.bradford.gov.uk/media/1331/connecting-people-and-place-for-better-health-and-wellbeing-a-joint-health-and-wellbeing-strategy-for-bradford-and-airedale-2018-23.pdf]
This plan is contrary to the ambitions identified in this locally owned strategy.

In Bradford Council’s Sustainability Appraisal element of the Core Strategy Partial Review Scoping Report (January 2019) it states that ‘Physcial [sic] activity rates are below the national average, contributing problems with ill health. Therefore, it will be important for policies should seek to ensure that opportunities are provided for local people to participate in physical activity in order to improve the health and well being of the area.’ [pg 13]
As this site is situated mid-way down a sloping hill, the houses directly above it (to the south) will have their view significantly impacted as will those whose houses are directly adjacent to the site. This is aesthetically damaging and might also impact on mental wellbeing as a relatively quiet area becomes significantly busier and noisier.
Historical Importance
This land is adjacent to two of, probably, the oldest buildings in and around Saltaire with two grade II listed buildings. The current residents have ensured that these are effectively maintained and they welcome the use of the land by visitors and the interest shown in their buildings. The building of a 164 housing estate adjacent to these buildings will significantly impact on the maintenance and access to these buildings both during the construction phase and beyond.
Green Belt and Green Land
This is one of three greenbelt sites identified in the plan for possible development in the Shipley area (SH4/5/6). The February 2019 National Planning Policy Framework states (section 13) that ‘The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.’ [para 133] The proposals for SH4/5/6 is fundamentally contrary to this nationally agreed aim. It further indicated the Green Belt boundaries can only be changed in exceptional circumstances and that’ Before concluding that exceptional circumstances exist…the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. This will be assessed through the examination of its strategic policies…and whether the strategy:
a. Makes as much use as possible of suitable brownfield sites and underutilised land.’ [para 137]
The Council has identified a range of alternative sites, many of which are closer to amenities and public transport. In addition, changing work practices and other impacts of the pandemic mean that there is more space available within town and city centres that could be effectively utilised as residential spaces. In addition, there are a number of empty residences within the Bradford region – 8765 according to a Government briefing from October 2020 [https://commonslibrary.parliament.uk/research-briefings/sn03012/]. Effective utilisation of some of these might reduce the need for additional housing to be built. The local Green Party have identified a range of sites include the Valley Road road-widening site as alternatives.
Again, in Bradford Council’s Sustainability Appraisal element of the Core Strategy Partial Review Scoping Report (January 2019) there is a statement, ‘Landscape - The landscape is an important feature of the area, forming a key part of its identity. There is a need to ensure that these landscapes are protected and enhanced, particularly those elements that contribute to their distinctive character. Emerging policies and proposals should seek to maximise the benefits from the landscape character assessment to make decisions about the location and design of new development.’ [pg14] One neighbour referred to this development as taking the ‘Wood’ out of Nab ‘Wood’.
The same document makes this commitment, ‘Local Plan policy framework
should ensure the protection, conservation and enhancement of biodiversity in line with the UK Biodiversity Action Plan.’ [pg 55] It can be argued that the proposed plans for Green Belt Land are not aligned to this commitment.
Timing
The timing of this consultation during a pandemic and a lockdown disenfranchises anyone who does not have access to technological means of communication. Their voices are not heard and many will be unaware of these plans. There has been no opportunity to meet publicly because of coronavirus restrictions and this is anti-democratic especially considering the significant impact of these plans if approved.

In conclusion
SH4 (and 5/6) are Green Belt Land, that in itself should be sufficient for these plans to be rejected as the proposals are contrary to National Planning Policy as other sites are available. However, the additional concerns about traffic, air pollution, schools, public transport, health & wellbeing, habitat & bio-diversity are clear indicators of a need to rethink these plans and consider alternative sites.

Object

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29590

Received: 23/03/2021

Respondent: Mrs D Coleman

Representation:

•The Sustainability Appraisal for SH3 is vague, unbalanced, incomplete and is not substantiated with any reference to the Council's extensive documentation on the importance and protection of Open Space.

Full text:

To all it may concern,

Please register my objection to the above plans to build houses - ref: SH3/H.

My family and I have lived in our home for 14 years and the green space was an enormous influence on purchasing our home in the first place.
Both my daughter and I unfortunately have crohns, and this illness impacts our lives enormously. At times we are basically house bound for weeks (even months) . This is due to debilitating fatigue and access to toilets. The green space is extremely important to us, enabling us a place to walk and get some crucial exercise and freedom. It's so important to be able to enjoy the fresh air within metres of our home. I feel safe being in a green space which is overlooked on 4 sides. I am frightened and feel too vulnerable to walk alone in parks, along rivers, canals and woods etc. due to the risk of people with ill intent.
We enjoy the beautiful views of Salts Mill, Saltaire village and Baildon Moor. The cherry trees are beautiful and attract birds and squirrels. We also have an abundance of bats .
In summer, loads of people have picnics on the fields, and gatherings of friends (pre covid). Locals erect gazebos and have family and childrens parties. Families play in the snow and sledge and build snowmen. Young people spend time together, chatting and seeing their friends safely and within site of many of their homes. Hundreds of children use this space to play, run around and just enjoy themselves freely.
It is also used by myself and hundreds of others as a pathway to various destinations in and around Shipley and Saltaire in order to avoid the heavily congested roads above and below us. (Bradford and Saltaire roads).


This is valued open space used by the whole community. Government and local policies show that recreation open space like this is supposed to be protected. This land is designated as Recreation Open Space in the previous plan.
I object to the space having this important designation removed. The land should remain as Open Space, with the typology of ‘Amenity Greenspace’ as defined in the Open Space Audit Feb 2021 The Draft Local Plan claims to protect open spaces when in fact it has removed our 1.3 hectares of open space from the map.
We are already an area that has been shown to be deprived of green space.
The Draft Local Plan worsens an already dire situation, decreasing the amount of green space while the policy states a need to increase it.
The Core Strategy Development Plan (DPD) Adopted by Bradford Council July 2017 Policy EN1 (Page 211) states: ‘A. Land identified as recreation open space, or which is currently or was formerly used for recreation open space will be protected from development’.
The Bradford Council Strategic Land Assessment (2021) (page 61) describes this land as exactly that: ‘Greenfield-Recreation open space’.
Local Plan Policy CO1 provides protection against the development of those existing open spaces as identified on the Policies Map Replacement Unitary Development Plan (2005) Until the publication of the Draft Local Plan the land was zoned as ‘OS2 Recreation Open Space’, which affords it similar protection as described above in A. In other words, land which we believed was protected from development has been moved out of such protection in this Draft Local Plan.
The Bradford District Local Plan (2021) states: ‘Paragraph 3.1.9 The Council places considerable importance on promoting and improving health and well-being and this is reflected in the policies of the Local Plan which seek to protect and enhance green spaces.’
Bradford Council Open Space Audit Report 2021 (page 44) states: Shipley has a deficit of Amenity Greenspace of 5.72 hectares and the priority for increasing provision is rated as ‘Moderate’. In percentage terms Shipley only has 36% of the Amenity Greenspace that the Council thinks the area needs.
Friends of The Earth used and A to E rating system to identify areas that are most deprived of green space in their research document ‘England’s Green Space Gap’ document (2020) Shipley was identified as being very low on green space, as category ‘D’ ( the second to lowest category).
Proposal SH3 fails to mention that the land falls under OS2 Recreation Open Space in the current plan - a designation that is being removed in this draft plan. This is evasive and clearly intended to draw the reader's attention away from what is being lost.
The Sustainability Appraisal for SH3 is vague, unbalanced, incomplete and is not substantiated with any reference to the Council's extensive documentation on the importance and protection of Open Space.
In what way does the plan for SH3 comply with policy CO1? In what way does this proposal address the 63% deficit of Open Space in Shipley that requires 'moderate' action according to the Open Space Audit 2021?
This is valued open space used by the whole community. Government and local policies show that recreation open space like this is supposed to be protected.We will lose the benefits of our community’s local green space.Children play regularly here and would have nowhere else to play. Many dwellings in the neighbourhood have no gardens and the local parks are a long way away involving main road crossings.It's used for sport/exercise.It's used for dog walking.Green space helps protect us against local air pollution problems.People travel via the green to work, or to the local nurseries and schools.We are already an area that has been shown to be deprived of green space.It was landscaped for recreation in the 1960s and is needed now just the same.- there are now thousands more vehicles on the roads - therefore our need for green space is actually far greater than it was in 1960Generations of families have used this space and we need to protect it for future generations.
Why destroy the play/recreation space of this and future generations for the sake of meeting only 3.5% of the Shipley ‘quota’ of new housing?
It is extremely short sighted and unacceptable to destroy much needed green space and the public's well being and access to recreational space when there are numerous local brown sites available to build upon which are at present unsightly and also open to vandalism and fly tipping).

Support

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29862

Received: 24/03/2021

Respondent: Batty Developments Ltd

Agent: Heritage Planning Design Ltd

Representation:

Site SH4/H (SLA Ref SH/026)

Recognition of the site’s sustainable location, in proximity to educational and other facilities is welcomed, as are the minor positive impacts predicted for climate change resilience, housing, social cohesion, culture and leisure, health, employment and economy.

Full text:

Dear Local Plan Team,

Please find attached representation on behalf of my Client Batty Developments Ltd. Please acknowledge receipt.

Identification of SH4/H - Glenview Drive, Bankfield Road as a preferred housing allocation is strongly welcomed.

Nevertheless, comments and in some cases concerns are raised below with respect to the following matters identified by the
DLP:
• Site Boundary
• Potential Site Access
• Sustainability Appraisal
• Habitats Regulations Assessment
• Green Belt
• Constraints and Opportunities
• Development Considerations
• Conclusion/ Summary

Comments are made on the proposed site.boundary.

Object

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29863

Received: 24/03/2021

Respondent: Batty Developments Ltd

Agent: Heritage Planning Design Ltd

Representation:

Site SH4/H (SLA Ref SH/026)

Climate change resilience
The site is assessed as + (minor positive) against this Sustainability Appraisal (SA) objective, but it should be assessed as ++ (major positive) as there will be low surface water run-off, plus the incorporation of green infrastructure within the development, potentially including a SUDS basin.

Water resources
The site is assessed as - (minor negative) against this SA objective as it could pose a risk to nearby water bodies and will result in a minor increase in water consumption. The latter is unavoidable and agreed but the former is clearly a risk that can be managed. Furthermore, the presence of nearby water courses provides opportunities for the creation of SUDS basins and the sustainable disposal of surface water, without placing additional demands on public sewers.

As the developer is investigating the feasibility of a SUDS basin (in-line with the submitted pre-application
enquiry), thus providing a new semi-natural waterbody, the site should be assessed as + (minor positive) or at least +/- (neutral) on the whole.

Full text:

Dear Local Plan Team,

Please find attached representation on behalf of my Client Batty Developments Ltd. Please acknowledge receipt.

Identification of SH4/H - Glenview Drive, Bankfield Road as a preferred housing allocation is strongly welcomed.

Nevertheless, comments and in some cases concerns are raised below with respect to the following matters identified by the
DLP:
• Site Boundary
• Potential Site Access
• Sustainability Appraisal
• Habitats Regulations Assessment
• Green Belt
• Constraints and Opportunities
• Development Considerations
• Conclusion/ Summary

Comments are made on the proposed site.boundary.

Object

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29864

Received: 24/03/2021

Respondent: Batty Developments Ltd

Agent: Heritage Planning Design Ltd

Representation:

Site SH4/H (SLA Ref SH/026)

Biodiversity & geodiversity
The site is assessed as - - (major negative) against this sustainability objective. However, the assessment is presumptuous and overly pessimistic, without good reason. In-line with the pre-application inquiry submitted, protected trees and woodland on-site will be protected and retained, and the Developer will be working with BI Ecology (letter attached as appendix 2) with the aim of achieving net gains for biodiversity and green infrastructure, in-line with the NPPF.

As the site is within 7km of the South Pennine Moors SPA/SCA, it is acknowledged that Habitat Regulations Assessment must be undertaken but the potential for significant effects is very low. At worst, the site should be assessed as +/- (neutral) on the whole.

Landscape & townscape
The site is assessed as - (minor negative) against this sustainability objective. The development would inevitably result in the loss of open land. However, development of the site would not result in the loss of any protected trees or woodland. It is agreed that the relationship of the site with existing built form, limits magnitude of potential effects on the landscape. The Design Team have not identified any long views upon which there will be significant negative effects and will
be working with PWP Design (Landscape Architects) (letter attached as appendix 3) to ensure good design and appropriate mitigation.

Full text:

Dear Local Plan Team,

Please find attached representation on behalf of my Client Batty Developments Ltd. Please acknowledge receipt.

Identification of SH4/H - Glenview Drive, Bankfield Road as a preferred housing allocation is strongly welcomed.

Nevertheless, comments and in some cases concerns are raised below with respect to the following matters identified by the
DLP:
• Site Boundary
• Potential Site Access
• Sustainability Appraisal
• Habitats Regulations Assessment
• Green Belt
• Constraints and Opportunities
• Development Considerations
• Conclusion/ Summary

Comments are made on the proposed site.boundary.

Object

Supporting Documents of the Draft Bradford District Local Plan - Preferred Options (Feb 2021)

Representation ID: 29865

Received: 24/03/2021

Respondent: Batty Developments Ltd

Agent: Heritage Planning Design Ltd

Representation:

Site SH4/H (SLA Ref SH/026)

Cultural heritage
The site is assessed as - (minor negative) against this sustainability objective due to its proximity to New Close Farm (grade II listed) and a barn to the east (grade II* listed) and a likely adverse impact upon their settings. It is agreed that there is potential for an adverse impact
upon the settings of these buildings, however, such an impact is not inevitable and can be avoided by good design and mitigation, including planting and a green buffer. It is suggested that the site should be assessed as +/- (neutral), subject to mitigation.

Air quality
The site is assessed as - - (major negative) against this sustainability objective. It is accepted that new development will inevitably result in some additional vehicle movements and emissions. However, impacts can and will be mitigated by electric vehicle charging points and measures such as a Travel Plan that encourage the uptake of sustainable transport options. It
is suggested the site should be assessed as - (minor negative).

Full text:

Dear Local Plan Team,

Please find attached representation on behalf of my Client Batty Developments Ltd. Please acknowledge receipt.

Identification of SH4/H - Glenview Drive, Bankfield Road as a preferred housing allocation is strongly welcomed.

Nevertheless, comments and in some cases concerns are raised below with respect to the following matters identified by the
DLP:
• Site Boundary
• Potential Site Access
• Sustainability Appraisal
• Habitats Regulations Assessment
• Green Belt
• Constraints and Opportunities
• Development Considerations
• Conclusion/ Summary

Comments are made on the proposed site.boundary.