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

Object

Representation ID: 28239

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

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.

Object

Representation ID: 28307

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

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.

Object

Representation ID: 28514

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

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.

Object

Representation ID: 29503

Received: 23/08/2021

Respondent: Laura Gorman

Re SA / Site SH4/H

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.

Object

Representation ID: 29590

Received: 23/03/2021

Respondent: Mrs D Coleman

•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.

Support

Representation ID: 29862

Received: 24/03/2021

Respondent: Batty Developments Ltd

Agent: Heritage Planning Design Ltd

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.

Object

Representation ID: 29863

Received: 24/03/2021

Respondent: Batty Developments Ltd

Agent: Heritage Planning Design Ltd

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 thus providing a new semi-natural waterbody, the site should be assessed as + (minor positive) or at least +/- (neutral) on the whole.

Object

Representation ID: 29864

Received: 24/03/2021

Respondent: Batty Developments Ltd

Agent: Heritage Planning Design Ltd

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.

Object

Representation ID: 29865

Received: 24/03/2021

Respondent: Batty Developments Ltd

Agent: Heritage Planning Design Ltd

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).