Sustainability Appraisal & Strategic Environmental Assessment - Appendix F - Wharfedale

Showing comments and forms 1 to 10 of 10

Object

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

Representation ID: 16996

Received: 22/03/2021

Respondent: Lynn Sanders

Representation:

•The headline conclusion is “A major adverse effect is predicted on the land and buildings SA Objective due to the loss of greenfield land.” Surely, on this criterion alone, the site must be deemed unsustainable.
•A second major adverse effect is acknowledged on biodiversity and geodiversity
•There are no major positive effects noted.
•The cultural heritage objective assessment appears to totally ignore the historical significance of the site
•Even though the majority of the resources listed (eg shops, pubs, healthcare) are beyond walking distance from the site, all are deemed to have “minor positive” influence on sustainability.
•Schools are acknowledged as a “minor negative” presumably because of distance, yet apart from employment, schools generate more journeys than all other venues.
•The employment section suggests that “Residents at the site would have excellent access to the diverse range of employment opportunities in the centre of Ilkley”. In fact, most residents of the town would be likely to head straight for Leeds. Employment opportunities in Ilkley are few and far between.

Full text:

I wish to register my opposition to the proposed development in Ilkley Ref: IL1/H, IL2/H, IL3/H, and IL4/H

Listed below are the reasons why i wholly opposed the proposed development:

GREEN BELT ISSUES.
•Protection is provided by the Government’s National Policy Framework.
•The presumption remains that brownfield sites will be used before green belt and there is an abundance of brownfield sites within Bradford City area.
•Despite a proposal to defer development of the three Ilkley sites until years 6-11, developers will doubtless pressurise Bradford Council for much earlier access to the more ‘lucrative‘ sites – following the pandemic it is already clear there will be new ways of working and much more time needs to be allowed to understand the lasting effects such as the freeing up of shop and office space in cities and towns for conversion to housing. Thus, any earlier development needs to be strongly resisted.
•Further, if green belt were to be developed, where will the ‘compensation’ come from? Certainly not from within Ilkley’s boundaries.
•The Council’s “Site Specific Green Belt Assessment” of IL/009 (aka IL1/H) itself also raises significant questions over its suitability, for instance:
oDevelopment of the site is acknowledged to have a MAJOR negative impact on purpose 3 of the NPPF GB policy “To assist in safeguarding the countryside from encroachment”. This alone should be enough to rule the site out for development.
oPurpose 5 “To assist in urban regeneration, by encouraging the recycling of derelict and other urban land” is scored as MODERATE. Development of any GB site will discourage the reuse of such land so the score should be MAJOR negative.
oThe scores allocated are one MAJOR, two MODERATE and two LOW, with an overall result of MODERATE. So, the Council acknowledge a MODERATE effect on GB which, we feel, should rule the site out. If, however, an appropriate weighting is given to the individual scores, the overall result would surely be MAJOR, without changing any individual score.

SUSTAINABILITY APPRAISAL/STRATEGIC ENVIRONMENTAL ASSESSMENT
•The headline conclusion is “A major adverse effect is predicted on the land and buildings SA Objective due to the loss of greenfield land.” Surely, on this criterion alone, the site must be deemed unsustainable.
•A second major adverse effect is acknowledged on biodiversity and geodiversity
•There are no major positive effects noted.
•The cultural heritage objective assessment appears to totally ignore the historical significance of the site
•Even though the majority of the resources listed (eg shops, pubs, healthcare) are beyond walking distance from the site, all are deemed to have “minor positive” influence on sustainability.
•Schools are acknowledged as a “minor negative” presumably because of distance, yet apart from employment, schools generate more journeys than all other venues.
•The employment section suggests that “Residents at the site would have excellent access to the diverse range of employment opportunities in the centre of Ilkley”. In fact, most residents of the town would be likely to head straight for Leeds. Empoyment opportunities in Ilkley are few and far between.

FLORA AND FAUNA
•The entire site falls within the Habitat Regulation Assessment 2.5km zone both for Nidderdale AONB and Ilkley Moor where land is protected from development.
•The site borders a priority wildlife habitat which would be seriously impacted by pets from the proposed development.
•The copse and a number of other ancient trees are protected by TPOs, blue bell woods, a huge number of wildflower species and curlews use the field as a feeding area in Spring, all of this acting to demonstrate the need to fully comply with the legislation as above.

FLOODING
•The site regularly floods with water pouring from the moor, through the golf course and onto Ben Rhydding Drive and beyond. Clearly, development of the site can only worsen the situation.
•Such increases in speed of water flows from this site and also the Coutances Way site below will doubtless increase the risk of further stability and slippage issues along the railway lines.

It is for all of the reasons that i oppose the development.

Support

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

Representation ID: 18409

Received: 24/03/2021

Respondent: Mrs JM Ogilvie

Agent: Mrs Gen Kenington

Representation:

The site-specific text summarises the Sustainability Appraisal assessment, which refers to the predicted effects of development, summarising that the development of this site would be unlikely to result in a significant effect, either positive or negative on any SA objective. We do not disagree with this summary. Whilst the site scores minor adverse effects against SA
Objectives 12 and 17 in relation to accessibility to services and education, the distances of 1.4km to Addingham services and 1.4km to Addingham Primary School are still considered acceptable distances. The site is well located to the bus network, with bus stops located within 400m to the east of the site on Moor Park Drive. The site (as referenced in the AMA Highways
Report) is considered to be located in a sustainable and easily accessible location on foot or by bicycle, with the entirety of Addingham falling within an acceptable 2km walking catchment of the site

Full text:

On behalf of our client Mrs J M Ogilvie, we support the identification of Site AD1/H and confirm its deliverability within the Plan Period via this submission.

Our client has been promoting the suitability of this site for a number of years, which has in more recent years included communication with the Council via their pre-application service in 2015.

Given that the site is now identified as a preferred allocation our client has renewed confidence in the delivery of this site and has appointed a team of consultants to prepare relevant technical background documents to evidence the suitability of the site for residential development.

This representation is informed by a Highways Advocacy Document (Appendix 1) and a Preliminary Ecological Appraisal (Appendix 2).

Further, a topographical survey is being undertaken shortly, which will allow a full Tree Survey of the existing trees on the site to be undertaken. This will then inform future design proposals for the site.

As well as this site-specific representation in support of Site AD1/H (Consultation Question 117) a separate Johnson Mowat response has been prepared on behalf of a number of clients who we are representing with land interests in the Bradford District. The Johnson Mowat response should be read alongside this site-specific response.

Comments are made on access and highways issues.

Comments are made on the SA.

We disagree with the overall conclusion of this site in the Green Belt Assessment, which needs re-evaluating, particularly given that the adjoining parcel AD/020 (Preferred Housing Site AD7/H) is scored differently.

Reference is made to the results of a Preliminary Ecological Appraisal been undertaken by Futures Ecology, which comprises a Phase 1 habitat survey and preliminary protected species survey.

Object

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

Representation ID: 21062

Received: 23/03/2021

Respondent: Andy Greenall

Representation:

I’m an Ilkley resident and also a sustainability professional and a Practitioner with the Institute of Environmental Management & Assessment. I carry out Sustainability Appraisals as part of my job.

With regard to IL1/H - Ben Rhydding Drive, Wheatley Grove: the SA section itself appears not to have picked up that around 10% of the site is currently covered by protected trees, which would be destroyed as part of any development (this is mentioned in passing under Constraints and Opportunities;

Full text:

Dear Sir or Madam,
I’m writing in response to the BD Local Plan Consultation, specifically regarding Ilkley. I’m an Ilkley resident and also a sustainability professional and a Practitioner with the Institute of Environmental Management & Assessment. I carry out Sustainability Appraisals as part of my job. While I recognise the need for housing and have no argument with the two smaller proposed locations in Ilkley, my view is that large developments such as those discussed below are incompatible with retaining the open, village-like nature of the town (and of retaining any semblance of proper green belt).
With regard to IL1/H - Ben Rhydding Drive, Wheatley Grove: the SA section itself appears not to have picked up that around 10% of the site is currently covered by protected trees, which would be destroyed as part of any development (this is mentioned in passing under Constraints and Opportunities; Development Considerations talks about increasing tree cover while building 130 houses on the site, which is highly misleading). I am also surprised that the impact on Green Belt has been categorised as Moderate, and would be very interested to see the rationale behind this. The conclusion (“this is a sustainably located green belt site”) is at best meaningless and at worst a prejudiced contradiction in terms.

IL3/H - Coutances Way: developing this open field into housing is simply incompatible with the notion of retaining green belt on this side of Ilkley. The appraisal itself admits this: “the site has a major potential impact on the Green Belt… makes a major contribution to the purposes of including land in the Green Belt… would have a major impact on openness.” It’s also in a flood zone, which is addressed minimally with no sign of local knowledge of the extent to which flooding is becoming a serious problem in Ilkley. Again, the Summary prejudicially concludes that the site is “sustainably located” without having done anything to demonstrate that this is the case (rather the reverse). I cannot comment on the SA as I cannot find it - it's mentioned as an 'accompanying report', which I can't locate (doubtless my error) - but again, if it does conclude that developing this site would be viewed as sustainable I would be very interested in seeing the rationale behind it.

I appreciate that you're exceptionally busy but I do hope you'll take the time to consider these points.

Object

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

Representation ID: 29689

Received: 24/03/2021

Respondent: Redrow Homes

Agent: Mrs Gen Kenington

Representation:

Rejected Site IL/013

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

The site receives minor negative scores against 5 of the sustainability objectives and major negative scores against 2 objectives.

We disagree with some of these negative and neutral scores on the following objectives:

Land & Buildings
Water Resources
Biodiversity & Geodiversity
Landscape & Townscape
Cultural Heritage
Air Quality
Accessible Services
Social Cohesion

For detail see submission document.

Full text:

Dear Sir or Madam,

Please find attached a response to the Draft Local Plan Preferred Options in relation to rejected site IL/013 Wheatley Lane, Ilkley on behalf of our client Redrow Homes.

Please can you acknowledge receipt of the attached submission.

I look forward to hearing from you.

Object

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

Representation ID: 29696

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Barton Wilmore

Representation:

Site ME/005

The other reason the Council have dismissed the site is due to ‘landscape impacts’.

Regarding site ME/005, the SA concludes as follows under question 7 (landscape and townscape):

The site is 1.2km south of the Nidderdale AONB, but residential development here would not be expected to have a discernible impact on or alter views into or out of the AONB, due to the presence of existing and similar built form to the north of the site and its location adjacent to the village of Menston. However, residential development at this site could result in the loss of open greenfield and Green Belt land that contains GI elements of potentially high visual amenity, including trees, and it would therefore be likely to adversely alter the local town scape and landscape character, although the nearby existing built form could help to limit the magnitude of
potential effects.

However, Pegasus’ assessment of the site concludes very differently, see below:

It is not considered that the development of the site would result in the loss of any landscape features that hold an individual landscape or visual value or are of a specific importance to the wider landscape character. Existing landscape features worthy of retention such as the trees within and bounding the site, and the stone walling along Burley Road could be incorporated as part of a new development. Together with new planting, retained vegetation would contribute to the well wooded character of the locality and help to integrate new development into the landscape.

Full text:

We have been instructed by our Client, Persimmon Homes to make representations to the draft Local Plan in respect of their following land interests. These representations should be read in accordance with the overarching representations prepared on their behalf by Lichfields.

• 23489MENS/A5/CA – Land at Beech Close, Menston (ME/005)

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: 29779

Received: 25/03/2021

Respondent: Ilkley Town Council

Representation:

Site IL1/H (SLA ref IL/009) - Wheatley Grove

Inaccuracies and points to address in SA for the site:

7. The negative impact of housing development on the high visual amenity of this area for the local community and visitors has been underestimated and should be seen as a major negative.

8. Ben Rhydding Drive has listed buildings/ heritage assets.

9 - References ‘new employment premises’ (?) yet 130 residential dwellings proposed with associated air pollution within the SSSI Risk Zone (above)

10 –Ben Rhydding Drive is a private not an access road therefore access required via narrow/poor sight lines Wheatley Grove/Wheatley Lane junction increasing the hazards to this junction (which would need re-modelling). It would also direct more traffic up Wheatley Grove round to the narrow/poor sight lines junction with High Wheatleyand then on to the blind corner junction of High Wheatley/Ben Rhydding Road. This increase in car traffic would endanger walkers and cyclists and therefore not supporting national and local active travel policies. The Wheatley Grove access increases the distance from rail station and no frequent buses this is a major negative with a declining baseline.

11 –Building at 18dpha does not meet the Local Plan’s density requirements meaning this development, or one of any increased density does not represent a significant enough contribution to Bradford’s housing numbers and tenure mix to warrant the negative impact of destroying the functionality of this site within a SSSI Impact Risk Zone. This is a major negative.

Full text:

Please find attached the submission from Ilkley Town Council to the CBMDC Local Plan Consultation.

I apologise for its late arrival, but I understand from Councillor Brown that you will accept a late submission. Unfortunately, we had problems with the internet on Monday which caused delays.

Object

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

Representation ID: 29780

Received: 25/03/2021

Respondent: Ilkley Town Council

Representation:

Site IL1/H (SLA ref IL/009)

Inaccuracies and points to address in SA for the site:

12 – The distance from accessible services does not support the Local Plans ’15 Minute Neighbourhood approach’

13 – Ben Rhydding/Ilkley’s infrastructure and services are already overstretched and cannot support more (e.g. places at nearest primary schools for children in this area have not always been guaranteed) This is a major negative.

16 – The area is already of substantial regular use and benefit to local residents for the reasons stated and especially during the Covid pandemic. A development of the size proposed would have a major negative impact on the wellbeing of existing residents and PROW users due to destruction of natural habitats. Wharfedale Hospital, Otley is 10km west of the site.

17 – Ilkley Grammar School is the nearest state school. Both the local primary and secondary school are beyond the target distances.

19 – The history and scale of the proposed development show construction is likely to be by a larger developer not smaller local builders. The level of disruption and extra construction traffic could also be a negative for local businesses therefore suggesting a positive/negative effect.

Full text:

Please find attached the submission from Ilkley Town Council to the CBMDC Local Plan Consultation.

I apologise for its late arrival, but I understand from Councillor Brown that you will accept a late submission. Unfortunately, we had problems with the internet on Monday which caused delays.

Support

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

Representation ID: 29786

Received: 25/03/2021

Respondent: Ilkley Town Council

Representation:

Site IL2/H (SLA Ref IL/011b)

Agree with Sustainability Assessment and note 6 – Biodiversity and Geodiversity as only area with major negative effect due to triggering ikely significant effects on the South Pennine Moors SPA/SAC and the North Pennine Moors SPA/SAC.

Under 10 – Transport agree the need for a segregated cycle path linked between Ilkley and Addingham (suggest looking again at Wharfedale Greenway route) to alleviate pressure on A65 and work towards a net gain improvement in air and noise quality and social cohesion and enable any development on this site to be car free to support a mix of housing including affordable homes.

Recommend Neutral, as exceptional circumstances for release of Green Belt not demonstrated, but with positives.

Full text:

Please find attached the submission from Ilkley Town Council to the CBMDC Local Plan Consultation.

I apologise for its late arrival, but I understand from Councillor Brown that you will accept a late submission. Unfortunately, we had problems with the internet on Monday which caused delays.

Support

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

Representation ID: 29788

Received: 25/03/2021

Respondent: Ilkley Town Council

Representation:

Site IL3/H (SLA ref IL/014) Coutances Way

Agree in the main with the Sustainability Assessment for this site but emphasise NPPF Paras 157 and 160 demand a net improvement to flood risk as a result of new development. However due to the impact of climate change the increase in the number and severity of severe flooding incidents and risk of water pollution experienced in the area over recent years arguably shows the decline in the baseline trend to be accelerating. This results in the A65 area being impassable for all and places residents properties at risk of flooding as well as expensive insurance claims for the well-used (by Ilkley Grammar School, local residents and visitors) Ben Rhydding Sports complex on Coutances Way and probably in time too for the Moss and Moor Garden Centre nest to this.

Full text:

Please find attached the submission from Ilkley Town Council to the CBMDC Local Plan Consultation.

I apologise for its late arrival, but I understand from Councillor Brown that you will accept a late submission. Unfortunately, we had problems with the internet on Monday which caused delays.

Object

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

Representation ID: 29797

Received: 25/03/2021

Respondent: Ilkley Town Council

Representation:

Site IL4/H (SLA Ref IL/033)

Agree in the main with the Sustainability Assessment for this site however given the increase in the number and severity of severe flooding incidents and risk of water pollution over recent years consider 4 – Climate change resilience and 5 – Water resources need revising to become major negative effects. The baseline trend has been recognised as declining however due to the impact of climate change this trend has arguably become stronger.

Due to limited car parking facilities further caution is expressed about even sensitive development of this to prevent further adverse effects to 13 – Social cohesion.

Due to major adverse effects on the Ilkley Conservation Area, Old Bridge Scheduled Monument, major and minor adverse effects on natural themed indicators including recent flooding incidents and adverse effects on social cohesion due to limited parking and air quality.

Full text:

Please find attached the submission from Ilkley Town Council to the CBMDC Local Plan Consultation.

I apologise for its late arrival, but I understand from Councillor Brown that you will accept a late submission. Unfortunately, we had problems with the internet on Monday which caused delays.