Sustainability Appraisal & Strategic Environmental Assessment - Appendix F - Wharfedale

Showing comments and forms 1 to 13 of 13

Object

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

Representation ID: 1736

Received: 16/03/2021

Respondent: Mr Philip Davies

Representation Summary:

Having read the Apparel & Assessment with regards to Ilkley, I'm concerned that the the listed positive impacts (transport, education, accessibility) are deemed 'minor'; whereas the negative impacts are all 'significant', and all sites have been scored 'major negative' for geodiversity and biodiversity. This reads to me as very little positive effect for significant negative detriment. I have read and can appreciate the Council have tried to avoid the use of Green Belt in the main instance but would implore them to reconsider the sites if, by their own assessment, there is little to be achieved in using these sites, other than meeting a target number. As an Ilkley resident, it's extremely worrying to think we will be potentially worsening our climate change resilience, cultural heritage & land and buildings for this minor gain.

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 Summary:

•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.

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: Johnson Mowat

Representation Summary:

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

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 Summary:

As a local resident and with my knowledge and expertise in relation to sustainability appraisals I have the following comments.

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;

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: Johnson Mowat

Representation Summary:

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

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 Summary:

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.

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 Summary:

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.

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 Summary:

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.

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 Summary:

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.

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 Summary:

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.

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 Summary:

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.

Object

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

Representation ID: 30133

Received: 24/03/2021

Respondent: Clive Brook Planning

Representation Summary:

Site IL/016

Major error in assessment relating to flood risk. Will be addressed in masterplan. Assessment speculative.
Criterion 4 score should minor or neutral impact.

TPO woodland – only woodland is outside site boundary.

Soil quality will not be depleted.

Water bodies can be accommodated via good drainage/environment practice. Assessment has not looked at the masterplan proposals or recognised the wide protection/environmental corridor contained in them. Rating should be minor negative or neutral or positive (if masterplan is considered).

Criterion 6: description of proposals and environmental enhancements they contain not taken into account.

Criterion 8: setting/proximity of parts of Ilkley & Middleton Conservation Areas can be taken fully into account in detailed design stages. Building groups will set high standards to support new Government policy on beauty. Negative scoring based on supposition.

Criterion 11: 175 to 200 dwellings represents substantial contribution to housing need. More than minor positive contribution.

Criterion 16: development with major recreation, natural and landscape content brings substantial benefit towards health & wellbeing. Counterbalances distance to health facilities. Rating should be neutral.

Criterion 18: no proven loss of agricultural employment - transitional sheep grazing provides part of the employment for one/two people.

Comment

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

Representation ID: 30148

Received: 23/03/2021

Respondent: Clive Brook Planning

Representation Summary:

SA of Sites AD3/H & AD4/H

Given the proposals for the large area of retained and environmentally enhanced open land associated with the delivery of the two proposed allocations the local planning authority will need to significantly review their scoring system for what we propose will be a wider mixed use site bringing all the benefits summarized in the earlier sections of this submission.

The outline master plan proposals comprised in the Environmental Proposals Plan provide mitigation and enhancement proposals which should change the negative assessment against criteria 3, 6, 7, 8, 9 and increase some of the positive assessments including criteria 10, 11, 12, 16 and 19.