Site Assessment Update Report (Feb 2021)

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: 2355

Received: 19/03/2021

Respondent: Clive Brook Planning

Representation:

We object to this evidence base document with regard to the way in which Green Belt Review criterion are introduced into the process at various stages and on certain other more limited issues which cumulatively lead to a need to review parts of the proposed seven stage process.

Full text:

SITE ASSESSMENT UPDATE REPORT (FEBRUARY 2021) & THE REVISED SITE ASSESSMENT METHODOLOGY JULY 2019 (AS REFERRED TO IN THE UPDATE REPORT)
The objection submitted on behalf of my clients is in relation to specific aspects of the methodology which depart from the normally used and accepted methodologies used by planning authorities when preparing a composite Local Plan.
1. Throughout a number of the stages of site selection Green Belt assessment has been introduced within environmental and technical criteria listings. The consideration of Green Belt at a large parcel and site specific level needs to be considered in a parallel but separate process. Green Belt is often wrongly considered as an environmental policy whereas it is solely a development control policy seeking to prevent urban sprawl and the coalescence of settlements as its prime functions. The Green Belt Review as a separate process has rightly sieved out parcels of land which are isolated or significantly detached from the nearest urban settlement identified in the settlement hierarchy. It has also sieved out such parcels where the land is predominantly within an area covered by a primary environmental or technical constraint ( e.g protected floodplain FZ3b; AONB, SPA/SAC ). At paragraph 1.19 of the more detailed methodology statement (July 2019) the following statement is made :- "The site assessment methodology (in particular stages 2 and 5) has been designed to ensure that the requirement in in both national policy and within the adopted Core Strategy to maximise the potential of non Green Belt sites and locations is reflected. It brings in the need to establish on a settlement by settlement basis whether there are exceptional circumstances for Green Belt change." The national policy approach to Green Belt reviews is a combination of the advice in paragraphs 137 to 139 inclusive. In paragraph 138 prominence is given to the need to take account of promoting sustainable patterns of development. The Council's approach to site selection and the allocation of land gives undue prominence and weight to the continued protection of the Green Belt and fails to appropriately assess how the most sustainable patterns of development can be achieved in each settlement in the hierarchy.

2. Stage 1 of the assessment seeks to reject Green Belt sites which are "not adjacent and contiguous to the built up area and/ or could not reasonably form an acceptable urban extension." The basis for rejecting parcels at stage 1 of the GB Review is whether or not they "touch" the settlement to which they are most related. The subsequent rejection of sites includes the lead criterion of not being "attached" to the urban area. The Green Belt Review, the Site Selection Methodology and the earlier 2013 Growth Study produced by Broadway Malyan use different means of defining and assessing parcels. We consider that the Growth Study's use of 500metre arc distances from the urban boundary provide a more considered and consistent set of results in relation to the assessment of retained parcels and sites. The need for physical attachment to the urban area is not quantified and in itself is not an adequate assessment of a site' relationship to the existing urban morphology. It is important that the chosen approach is fair and objective. We consider the Growth Study to be the best approach on this matter.

3. At paragraph 4.5 of the 2019 Revised Site Assessment Methodology relating to the initial screening out of sites and in subsequent assessment stages reference is made to the evidence which will be relied on. At no stage is there any reference with regard to master plans and technical and environmental reports/ information submitted by promoters of sites being taken into account in the process. Information submitted with this consultation and in earlier consultations ( including July 2016 submissions in relation to Issues and Options consultation on the Allocations DPD and the 2019 consultation on the Core Strategy Partial Review should be taken into account where this establishes clear mitigation which reduces an impact or positive impacts are established against specific criteria.

4. The use of Green Belt as an environmental criterion in table 6.1 is not appropriate or justified.

5. There is no obvious stage at which the clear and significant results of master planned schemes producing cumulative positive environmental impacts can be introduced.

Object

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

Representation ID: 4838

Received: 24/03/2021

Respondent: Eric Breare Design

Representation:

Land at Mytholmes Lane Haworth HA/006

Objection on behalf of and with his approval, the land owner. Not all the land should be rejected as a preferred site.
The bottom section of the site can be retained as Green Belt to reinforce the landscape setting
of the River Worth, which forms the boundary between Oakworth and Haworth.
This would form a roughly equal area of land to both sides of the river worth to separate the settlement areas.
The Green Belt is drawn too tight to the existing houses with no space for future expansion.
The land has two access points one down Mytholmes Lane and one from Hebble Row where the land has a road frontage.
The site is within 400M of a bus stop.
Plan by email blue land to be Green Belt with additional landscaping to form a stronger Green Belt boundary. Red development.

Full text:

Land at Mytholmes Lane Haworth HA/006

Objection on behalf of and with his approval, the land owner Mr Todd Buchanan.
Not all the land should be rejected as a preferred site.
The bottom section of the site can be retained as Green Belt to reinforce the landscape setting
of the River Worth, which forms the boundary between Oakworth and Haworth.
This would form a roughly equal area of land to both sides of the river worth to separate the settlement areas.
The Green Belt is drawn too tight to the existing houses with no space for future expansion.
The land has two access points one down Mytholmes Lane and one from Hebble Row where the land has a road frontage.
The site is within 400M of a bus stop.
Plan by email blue land to be Green Belt with additional landscaping to form a stronger Green Belt boundary. Red development.

Object

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

Representation ID: 4889

Received: 22/02/2021

Respondent: Mr Robert Allan

Representation:

I am unaware of any good reason why my client’s land should not enjoy residential development opportunity, given its location, virtually surrounded by residential and indeed scheduled to be developed as a single opportunity with adjacent land already in the draft for residential?

Full text:

I am unaware of any good reason why my client’s land should not enjoy residential development opportunity, given its location, virtually surrounded by residential and indeed scheduled to be developed as a single opportunity with adjacent land already in the draft for residential?

Further email sent 26/02/2021, see attachments.

Attachments:

Object

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

Representation ID: 4908

Received: 11/03/2021

Respondent: Mr Robert Allan

Representation:

All I seek is this 8-acre site to be considered as a future potential residential or mixed residential/commercial opportunity. Although currently, various mill buildings, all tenanted, these buildings are elderly and the basis of occupation short-term. Furthermore, the land is now really a non-conforming user being surrounded predominately by either residential or woodland. All nearby land recently developed has been for residential purposes.

As I say, on behalf of the owners of this land, all I seek is your re-consideration of this superb potential residential opportunity as it is not included in the draft local plan - Preferred Options (Regulation 18) which was issued in February of this year. That seemed most surprising.

Full text:

For reasons which I don't quite understand, Leah Midgely suggests in her recent email to me that I should write to your department as I'm not in a position to respond using a link into an existing website.

Please, therefore, find attached a copy of my email to Leah, dated 12th February coupled with her response of 17th February.

All I seek is this 8-acre site to be considered as a future potential residential or mixed residential/commercial opportunity. Although currently, various mill buildings, all tenanted, these buildings are elderly and the basis of occupation short-term. Furthermore, the land is now really a non-conforming user being surrounded predominately by either residential or woodland. All nearby land recently developed has been for residential purposes.

As I say, on behalf of the owners of this land, all I seek is your re-consideration of this superb potential residential opportunity as it is not included in the draft local plan - Preferred Options (Regulation 18) which was issued in February of this year. That seemed most surprising.

Should you need any further information, please get in touch otherwise I trust re-consideration of this opportunity will take place.

Object

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

Representation ID: 5103

Received: 19/03/2021

Respondent: Mr Robert Allan

Representation:

The land is about 3 acres and would be very suitable for residential development, given its frontage to a road and its south-facing orientation and the fact that it is abutting residential development on 3 sides.

I notice with some concern that this land was not allocated in your recent Draft Allocations Plan Document, issued in early February, for residential development and the purpose of this email is to ask if reconsideration to that could be undertaken so that in the next issue documentation, this land is proposed for residential development purposes for which it is ideally suited.

Full text:

I have communicated regarding this parcel of land, as shown edged on the plan herewith, with Leah Midgley in your Planning Dept.

Many, many months ago I suggested the land should be considered for residential development and I know The Home Group have also contacted you confirming that is their view also.

The land is about 3 acres and would be very suitable for residential development, given its frontage to a road and its south-facing orientation and the fact that it is abutting residential development on 3 sides.

I notice with some concern that this land was not allocated in your recent Draft Allocations Plan Document, issued in early February, for residential development and the purpose of this email is to ask if reconsideration to that could be undertaken so that in the next issue documentation, this land is proposed for residential development purposes for which it is ideally suited.

I'm sure you will get a similar letter from The Home Group supporting the content herein.

Object

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

Representation ID: 6030

Received: 01/03/2021

Respondent: Deborah Holmes

Agent: Rose Consulting

Representation:

Rejection of site OA/001

1. The site provides an opportunity for the creation of a strong, defensible Green Belt boundary.

2. In isolation, site OA1/H constitutes an irregular protrusion into the Green Belt.

3. The reasons for rejecting the site are not substantiated and appear contrived.

4. As cited, my client is aware of no SWF issues. SuDS would remedy any problems.

5. The site could deliver a major positive effect on the health SA Objective. Minor positive effects were predicted for nearly all other socio-economic SA Objectives.

6. A HRA would be undertaken to ensure there are no significant effects on these protected sites.

7. Development would cause only very minimal landscape impact.

8. Heritage has been cited as a reason for rejection but it appears no HIA was carried out.

9. Its sustainable located adjacent to the settlement boundary within a reasonable proximity to services and facilities.

Full text:

1. Development of the site, when assessed in conjunction with the adjoining site (OA1/H) would form a logical settlement extension and provide an opportunity for the creation of a strong, defensible Green Belt boundary, of greater strength than that exists presently.
2. In isolation site OA1/H constitutes an irregular protrusion into the Green Belt and would form an abnormal built form, increasing the possibility of future encroachment into the Green Belt. It is disputed that development of the site would create a new Green Belt boundary of similar strength to that of the existing one as assessed by the Council.
3. The reasons for rejecting the site are not substantiated and appear contrived.
4. The site is situated in flood zone 1, as is the adjoining site. Although cited as a reason for rejection by the Council, my client is aware of no surface water flooding issues, despite the extreme weather conditions of the last 5 years. Nevertheless, the application of SuDS would remedy and in fact improve any existing surface water flooding problems.
5. In terms of the Sustainability Appraisal, the site could deliver a major positive effect for residents on the health SA Objective as a result of being within the target distances for all necessary health facilities. Furthermore, minor positive effects were predicted for nearly all other socio-economic themed SA Objectives due to the benefits of new residential development for the local economy as well as the location of the site in relation to transport links, local services and amenities, education facilities and employment areas.
6. In terms of a requirement for a Habitats Regulations Assessment, as this site falls within 7km of the South Pennine Moors SPA/SAC, a Habitat Regulations Assessment would be undertaken to ensure there are no significant effects on these protected sites.
7. As with the adjoining site, development would cause only very minimal landscape impact. The policy framework contained within the Local Plan will ensure this. Site specific mitigation measures would also be provided such as the provision of mature boundary planting along a strong, defensible Green Belt boundary and some additional on-site Open Space.
8. There would appear to be no Heritage Impact Assessment carried out for the site. In accordance with the approved Site Assessment Methodology, this indicates that a decision was made that there would be no impacts to be assessed. As such, it is somewhat confusing that heritage has been cited as a reason for rejection, and given no reference whatsoever in the site report for site OA1/H. The site is some distance from the Conservation Area and would not affect the setting of any listed buildings.
9. This is a sustainable site located adjacent to the settlement boundary and within a reasonable proximity of a number of services and facilities. The site would make a positive

Object

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

Representation ID: 7247

Received: 10/03/2021

Respondent: David Hill LLP

Representation:

•The landowners are keen to develop the site (HR/001) and confirm that it is available.
•Under the revised methodology for calculating the housing requirement Bradford will need to provide more housing than shown in the draft plan. This site could contribute to this.
•Previous scheme submitted to show access is feasible and an illustrative layout to show how the open space to the south of the site could be linked to the park to the west. The site would be deliverable if allocated.

Full text:

HR/001 - Harden Road

We are disappointed to see that the site has not been allocated in the Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021. However, the landowners are keen to progress with developing the site and we would like to confirm that it is still available.

The landowner notes that under the revised methodology for calculating housing requirement, that Bradford Council will need to provide more housing than is shown in the current draft. This site could help make up the numbers. We have previously submitted a scheme that shows access into the site is feasible and provided an illustrative layout to demonstrate how housing could be developed on the site and how open space to the south of the site could potentially link to the park to the west. We therefore believe the site would be deliverable if the site were to be allocated.

I have attached the previously submitted documents for your further consideration.

I note that other sites in Harden refer to the Green Belt assessment, stating that they only have a moderate impact. I’ve been unable to find the Green Belt Assessment for site HR/001 on the Bradford Council website and wondered if you could provide me with it so that the landowner can better understand your decision not to include their site?

Attachments:

Object

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

Representation ID: 7410

Received: 10/03/2021

Respondent: David Hill LLP

Representation:

KY/151 - Long Lee Lane
•The landowners are keen to progress with developing the site and confirm that it is available.
•Under the revised methodology for calculating the housing requirement Bradford will need to provide more housing than shown in the draft plan. This site could contribute to this and it is noted it is identified as an ‘Alternative’. The site will not require Green Belt land to be released.
•It is noted that the site is described as not being achievable due to topography and landscape impact. Previous scheme submitted to show access is feasible and an illustrative layout to show how housing could be developed. It shows that topography will not prevent development. A Landscape and Visual Impact Assessment for the site has assessed the landscape impact of the site. The site would be deliverable if allocated.

Full text:

KY/151 - Long Lee Lane

We are disappointed to see that the above site has not been allocated in the Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021. However, the landowners are keen to progress with developing the site and we would like to confirm that it is still available.

The landowners note that under the revised methodology for calculating housing requirement, that Bradford Council will need to provide more housing than is shown in the current draft. This site could help make up the numbers and we note that in the Site Assessments for Airedale the site is given the status as ‘Alternative’. The site will not require any Green Belt Land to be released and we believe it is a very strong candidate for inclusion in the new Local Plan as a housing site.

We note that the site is described as not being achievable due to its topography and landscape impact. However, we have previously submitted a scheme that shows access into the site is feasible and provided an illustrative layout to demonstrate how housing could be developed on the site. These documents show that the topography of the site will not prevent development. We also submitted a Landscape and Visual Impact Assessment for the site, which assessed the landscape impact of the site. We therefore believe the site would be deliverable if the site were to be allocated.

I have attached the previously submitted documents for your further consideration.

Object

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

Representation ID: 7483

Received: 10/03/2021

Respondent: David Hill LLP

Representation:

•The landowners are keen to progress with developing the site and confirm that it is available.
•Under the revised methodology for calculating the housing requirement Bradford will need to provide more housing than shown in the draft plan. This site could contribute to this and it is noted it is identified as an ‘Alternative’.
•It is noted in the SHLAA that the site is not suitable due to access and impact on conservation area. However, a design has been submitted which shows that access to the site is achievable and would not prevent delivery of the site. We would confirm that any proposed development would be designed with the setting of the conservation area as a primary consideration.

Full text:

EM/004 - Street Lane, East Morton

We are disappointed to see that the site has not been allocated in the Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021. However, the landowner is keen to progress with developing the site and we would like to confirm that it is still available.

The landowner notes that under the revised methodology for calculating housing requirement, that Bradford Council will need to provide more housing than is shown in the current draft. This site could help make up the numbers and we note that in the Site Assessments for Airedale the site is given the status as ‘Alternative’.

In the SHLAA the site is said to not be suitable due to two reasons.

1. The access isn’t suitable - However, an access design has been submitted previously that demonstrates that access into the site is achievable and that this would not prevent delivery of the site.
2. Impact on the conservation Area - We note that the site appraisal mentions the site could potentially have an adverse impact on the adjoining East Morton Conservation Area. We would like to confirm that any proposed development would be designed with the setting of the conservation area as a primary consideration.

I have attached the previously submitted documents for your further consideration.

Attachments:

Object

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

Representation ID: 7518

Received: 08/03/2021

Respondent: Mr W Willan

Agent: Townsend Planning Consultants

Representation:

Objection to the omission of land at Raikes Lane, Holme Wood from the Plan as a preferred option housing site. (SLA ref SE/062)
The site forms a logical extension into the green belt and does not conflict with green belt purposes defined by the NPPF
The Council in preparing their new Local Plan are required to examine the current allocations
as contained on the current proposals map, this is an appropriate time to examine the Green
Belt. It is considered that the Council should reassess their approach to the site. The
representation site forms a coherent extension to the settlement and is available and
deliverable for housing (subject to its reallocation as part of the Local Plan). The 5
Bradford District Local Plan
representation site was previously identified as part of previous development proposals and
identified as an area to potentially be removed from the Green Belt. The allocation of the site
will deliver necessary housing, whilst also strengthening the Green Belt in the area. The site is
deliverable in the short term and, therefore, should be brought forward for development.

Full text:

Submission relates principally to the omission of land at Raikes Lane as a preferred option housing site
See attachments

Attachments: