Site Assessment Update Report (Feb 2021)

Showing comments and forms 1 to 21 of 21

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: Mr Todd Buchanan

Agent: 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:

Object

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

Representation ID: 16865

Received: 23/03/2021

Respondent: Avant Homes

Agent: ID Planning

Representation:

(Page 24/25)
-Object to the proposed rejection of site IL/044.
-We support the proposed allocation of site IL/044 and adjacent site IL/012 to provide a mix of new housing in a sustainable location.
-IL/044 not assessed as part of a Green Belt Parcel.
-An assessment of both sites IL/012 and IL/044 against Green Belt purposes should be undertaken.
-Distribution of new homes to Ilkley is not sufficient to support its growth and focus as a principal town over the Plan period.
-The release of three sites (two on the eastern site) from the Green Belt is insufficient to ensure the protection of the Green Belt boundary beyond the plan period.
-The distribution to housing to Ilkley should be increased and additional sites should be identified to provide sustainable housing.
-Additional safeguarded land sites should be identified to protect the Green Belt boundary beyond the plan period.
-No known constraints to the physical delivery the site.
-Sites are in flood zone 1 and access could be gained from Skipton Road.
-Development would result in encroachment into the countryside but the Council has recognised there are exceptional circumstances through the release of three sites around the town to meet housing need.

Full text:

SEE ATTACHMENTS FOR SUBMISSION IN RELATION TO SITES WI3/H (WILSDEN) & IL/044 (ILKLEY)

Object

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

Representation ID: 17670

Received: 23/03/2021

Respondent: Bannister Investments Limited

Agent: ID Planning

Representation:

These representations are made in relation to two sites, Land to the north of Banner Grange (BU/005) and Bradford Road (BU/014) in Burley in Wharfedale. We object to sites BU/005 and BU/014 being rejected as preferred housing allocations.
We consider the sites should be allocated as Preferred Housing Allocations to support the delivery of sustainable housing in the Local Growth Centre of Burley in Wharfedale. The sites are available and deliverable for development in the short term.
There are no known physical constraints that would prevent the development of these sites for residential use and we support the allocation of revised site BU/005 and BU/014 in the Local Plan to provide additional housing to meet identified local needs.

Full text:

SEE ATTACHMENTS FOR FULL SUBMISSION

Object

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

Representation ID: 18412

Received: 22/03/2021

Respondent: Charles Ratcliffe

Representation:

Object to the rejection of site OX/001.
•Site has a history of being allocated for development in the past but was reallocated as Village Green Space in the last plan (RUDP).
•The site should not be Local Green Space. The SHLAA indicated that the site has no public access, does not contribute to the setting of the area and does not fulfil the village greenspace designation.
•The site does not meet the Local Green Space criteria.
•There are no special features which make it beautiful, no public access for recreation, it is not of historic value, is not rich in wildlife and is too large a parcel of land to be allocated for LGS.
•The site at Cross Lane has more beauty and significant as a LGS site. It has a number of special features: hedgerows, trees, nesting birds, watercourse etc.
•The site at Crossfield Road should not be identified for development as it undermines the Green Belt designation and sets a precedence for Green Belt erosion.
•Development of this site with a sensitive design provides an opportunity to enhance the conservation area. Any flood risk and ecological impact could be mitigated.
•Site would be accessed from Denholme Road and there is a bus stop adjacent to the site. The site would have positive effects on the socio-economic SA Objectives.

Full text:

Response to Land Allocation and rejection as a housing development site.

Site at Denholme Road Leeming Oxenhope Reference OX/001

As a former resident and current property owner, I object to the rejection of this site for Development and the allocation of the site as Local Green Space.

The site has a history of being allocated for development in the past. It was allocated for housing development following an appeal to the Local Development plan (UALP).
The planning inspector stated that its development should be guided by a Design Brief to be produced by Bradford Council. Unfortunately this could not be produced in time before the Governments release of PPG3, where brownfield site took president and greenfield site were allocated a release date. This site was given a release date of 2014.

However again before that date the government instructed authorities to scrap their development plans and start work on their Replacement Unitary Development Plans.
Following consultation with the Parish Council this land was re-allocated as Village Green Space.

In the S.H.L.A.A search for sites the land was put forward again for development. Following the development teams assessment the land was described as :- “Village green-space notation does not represent the site as it has no public access and does not contribute in any way to the setting of the area. Slightly sloping grubby field between houses”.

When the site is judged by the development team on its own merit, the site should not be Local Green Space. It is only following consultation with the Parish Council that this designation is allocated.

This site does not meet the criteria for Local Green Space as set out in the Oxenhope Neighborhood Plan. Local Green Space designation should only be used where the site is demonstrably special and holds local significance because of its beauty, historic significance, recreational value and richness of its wildlife.

There are no special features to the field that gives it any beauty. The land has no public access for recreation. The historic value in the area is the Reservoir and Valve Tower themselves and not just a field opposite, that does not contribute to the setting of the area. The wildlife partially identified could not be regarded as richness of wildlife. The two nesting birds are not identified and there are no habitats and nesting sites identified because non exist on the site. The site is also too large a parcel of
land to be allocated for Local Green Space in it location.

On the other hand the land at Cross Lane has more beauty and significance as a site of Local Green Space. With it landscape and topography, protected hedgerows, Woodland with TPO and significant watercourse running round one boundary. These are special features that warrant Local Green Space allocation. This land is also much richer in wildlife, with nesting birds in the hedgerows and trees. Wildlife habitat of badgers in the woodland and wildlife associated watercourse. Dear can be regularly seen on the land that come down from the surrounding Moorland to graze.
It is also wrong to identify land within the Green Belt at Crossfield Road for development over land this site, because it undermines the very existence of the Green Belt and sets a president for further Green Belt erosion.

To develop the land on Denholme Road presents a real opportunity with a sensitive design to mitigate any impact on and enhance the conservation area. There is a small area of flood risk on the site, a flood risk assessment would identify the mitigation measures necessary and would present another opportunity to provide some high quality open space on the site. An ecological survey would be carried
out to identify and mitigate accordingly.

The site is on a bus route with a bus stop right outside the site, access would be directly from Denholme Road where a wide road frontage would provide a safe access. Some positive effects are predicted for a range of 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 and employment areas.

Object

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

Representation ID: 24282

Received: 24/03/2021

Respondent: Bradford Council

Representation:

Rejected sites:
The Willows site on Hainsworth Road has just been approved for a further 44 homes. This is despite the site failing to match the criteria set by a different part of the Planning Department and the site been placed on the Rejected Sites document within the Proposed Local Plan. This is wholly conflicting and clearly different Planning officers hold quite different views on what is an appropriate site for development. This does not give confidence to the planning process nor the content of the Proposed Local Plan.

Full text:

Please find attached my submission to the consultation on the Proposed Local Plan.

Object

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

Representation ID: 24601

Received: 24/03/2021

Respondent: Andrew Coates

Agent: Rural Solutions

Representation:

REJECTED SITE AD/013 (SEE ATTACHMENTS)
Despite the clear beneficial location of the Bolton Road (Site AD/013) outside the 2.5 km SPA/SAC and in close proximity to the primary school and within close walking proximity to services and facilities within the Local centre, it has been rejected due to ‘landscaping constraints’. However, other sites which have been suggested for allocation make reference to ‘sensitive site design to mitigate any impact on landscape character’. Site AD013 is not in any sensitive landscape designation (over and above any other of the preferred allocations) and as such, there is no reason as to allocate site over and above this well-located site.
Site AD/013 is located within two existing pockets of housing and across the road from the caravan park. All these existing built forms are what is immediately visible when travelling along Bolton Road from the north.
-Request that AD/013 is allocated within the Publication draft as it represents sustainable development.
-Site will continue to be promoted through all the various stages of the Local Plan process and be heard by the Inspector.

Full text:

SEE ATTACHMENT
Despite the clear beneficial location of the Bolton Road (Site AD/013) outside the 2.5 km SPA/SAC and in close proximity to the primary school and within close walking
proximity to services and facilities within the Local centre, it has been rejected due to ‘landscaping constraints’. However, other sites which have been suggested for allocation make reference to ‘sensitive site design to mitigate any impact on landscape
character’. Site AD013 is not in any sensitive landscape de signation (over and above any other of the preferred allocations) and as such, there is no reason as to allocate site over and above this well-located site.
Site AD/013 is located within two existing pockets of housing and across the road from the caravan park. All these existing built forms are what is immediately visible
when travelling along Bolton Road from the north.

An overarching google map of this fact is attached as part of this representation.

We respectfully request that our client’s sustainable site is allocated within the Publication draft as it represents sustainable development for the community of Addingham. It is proposed to continue to promote housing site AD/013 through all the various stages of the Local Plan process and to be heard by the Inspector.

Object

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

Representation ID: 24893

Received: 24/03/2021

Respondent: CEG Land Promotions Ltd

Agent: Lichfields

Representation:

REFERENCE TO BU2/H
We note the process by which the Council is required to assess and compare reasonable alternative sites, and the screening criteria for initially rejecting any sites which are not reasonable or realistic options – i.e. where it is unlikely that development on that site is achievable (paragraph 4.2). It is considered that the fundamental issues associated with delivery of this site referenced above suggest that it should have been initially screened out as not being a reasonable or realistic site in accordance with the methodology adopted within the Site Assessment Update Report (February 2021).

In particular, the table at paragraph 4.3 presents a number of ‘Screening Criteria’ which are to be applied and which are considered to render sites unsuitable for allocation. This includes ‘Green Belt sites which are not adjacent and contiguous to the built up area and or could not reasonably form an acceptable urban extension’.

Full text:

See attachments of CEG’s representation to the Draft Bradford District Local Plan Preferred Options (Regulation 18) Consultation. This includes:
-Appendix 1 Assessment of the Housing Requirement proposed within Policy SP8
-Appendix 2 Commentary on Evidence Base Documents
-Appendix 3 The Secretary of State’s decision and Inspector’s Report regarding application
16/07870/MAO (reference APP/W4705/V/18/3208020)
-Appendix 4 Burley-in-Wharfedale Alternative Site Assessment (2016)
-Appendix 5 Burley-in-Wharfedale Updated Alternative Site Assessment (April 2019)
-Appendix 6 Scalebor Park Land Registry Extract
-Appendix 7 Response to the HRA, associated policies and the South Pennine Moors
SPA/SAC Planning Framework SPD (prepared by Baker Consultants

Object

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

Representation ID: 24894

Received: 24/03/2021

Respondent: CEG Land Promotions Ltd

Agent: Lichfields

Representation:

PLEASE REFER TO SUBMISSION FOR THE FULL RESPONSE & TABLE DETAILING REJECTED SITES.

We note that the more detailed proformas and analysis which sit behind the conclusions reached for rejected sites as set out within (this report) have not been made available for comment as part of this consultation on the evidence. CEG reserve the right to view and comment on this information, which is pertinent to the strategy of
site selection to meet the local housing apportionment, when these are made available.

Based on the above conclusions, none of these sites should be considered for allocation in future iterations of the emerging plan.

Full text:

See attachments of CEG’s representation to the Draft Bradford District Local Plan Preferred Options (Regulation 18) Consultation. This includes:
-Appendix 1 Assessment of the Housing Requirement proposed within Policy SP8
-Appendix 2 Commentary on Evidence Base Documents
-Appendix 3 The Secretary of State’s decision and Inspector’s Report regarding application
16/07870/MAO (reference APP/W4705/V/18/3208020)
-Appendix 4 Burley-in-Wharfedale Alternative Site Assessment (2016)
-Appendix 5 Burley-in-Wharfedale Updated Alternative Site Assessment (April 2019)
-Appendix 6 Scalebor Park Land Registry Extract
-Appendix 7 Response to the HRA, associated policies and the South Pennine Moors
SPA/SAC Planning Framework SPD (prepared by Baker Consultants

Support

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

Representation ID: 27472

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Representation:

Site SI/003 - Persimmon’s land holding also includes part of Site SI/003: Brownbank Lane.
We note that the more detailed proformas and analysis which sit behind the conclusions reached for rejected sites as set out within the Site Assessment Update Report have not been made available for comment as part of this consultation on the evidence and despite our requests these have not been made available. Persimmon reserve the right to view and comment on this more detailed information when this is made available.

In summary, it has been demonstrated with reference to the emerging site masterplan, and technical consideration of matters of access, landscape and heritage, that the Council’s conclusions regarding the unsuitability of parts of SI/003 for allocation are unfounded.

SEE FULL REP FOR ASSESSMENT OF HOW TECHNICAL ISSUES AND CONSTRAINTS TO BE ADDRESSED.
A comprehensive masterplan has been prepared which demonstrates how non-Green Belt land within the settlement limits of Silsden can be sensitively developed to deliver 260 new homes, alongside additional wider benefits including the ability to facilitate an eastern relief road should this be deemed necessary, and the creation of a permanent and defensible Green Belt boundary.

Full text:

These representations have been prepared by Lichfields on behalf of Persimmon Homes (West Yorkshire) (“Persimmon”) to the public consultation on the Draft Bradford District Local Plan – Preferred Options (regulation 18) consultation draft (February 2021).

The representation is made specifically in relation to land at Bolton Road, Silsden where Persimmon have an option agreement to purchase land for development, and where preapplication discussions are ongoing regarding the site’s development for housing.

PLEASE REFER TO THE SUBMISISON FILES IN THE ATTACHMENTS

Support

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

Representation ID: 27480

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Representation:

The only other non-Green Belt site (apart from site SI/003) to be rejected for allocation is site SI/006. This is a former safeguarded site. The reasons for non-allocation include access; protected hedges; landscape impacts; and flood risk (part).
We are aware that access to this site is severely constrained and that there is limited prospect of upgrading the access, which would require third party land. It is therefore not considered that this site comprises a comparable or more favourable site over SI003 and/or SI/004. This site has not been subject to assessment in the SA, suggesting that CBMDC do not consider this site as a potential allocation.

Full text:

These representations have been prepared by Lichfields on behalf of Persimmon Homes (West Yorkshire) (“Persimmon”) to the public consultation on the Draft Bradford District Local Plan – Preferred Options (regulation 18) consultation draft (February 2021).

The representation is made specifically in relation to land at Bolton Road, Silsden where Persimmon have an option agreement to purchase land for development, and where preapplication discussions are ongoing regarding the site’s development for housing.

PLEASE REFER TO THE SUBMISISON FILES IN THE ATTACHMENTS

Support

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

Representation ID: 28485

Received: 24/03/2021

Respondent: Mr Colm McCann

Representation:

COMMENT
In relation to possible alternative sites for housing I would like to suggest the land between 162 Skipton road and the proposed site at IL2H. This land is above the flood plain and already considered within the town boundaries. Therefore would have a lesser impact on Ilkley's rural character and traffic flows than either of the Ben Rhydding proposals.

Another option within town boundaries could be development of flood resistant housing on the field between the river Wharfe and Langbar Road.

Full text:

I would like to make a number of points about the proposed housing allocation for Ilkley and Ben Rhydding in the proposed Bradford local plan.

Firstly what is the justification for the proposed 314 houses in this area? Is there analysis of local demographic trends to demonstrate need for this number and type of housing?

I note the housing allocation for Bradford city centre is only 7000 or approximately 2% growth. Surely this plan is a great opportunity to help stimulate city centre regeneration by creating quality spaces and housing to make city centre living attractive. This in turn will support the evening economy and aid recovery following the economic impacts of the pandemic. How much of the housing target within the plan is being met by utilising brown field sites or repurposing mill sites in the city?

The plan states that Ilkley is a tourism and leisure destination however I would like to question Bradford councils long term strategy for the town particularly key council services. Whilst i do not support any plans are to to expand Ilkley and Ben Rhydding as commuter towns which seems to the goal of Bradford then a long term infrastructure plan is required. The town swimming pool is badly in need of replacement with a modern leisure facility. I believe the future of Ilkley library is under threat as a council run facility as part of a strategy to shrink council services while this plan is suggesting a population increase. The local campaign to improve water quality in the river Wharfe is well publicised however is analysis been completed to understand capacity in the sewage treatment system for additional housing without further deterioration in water quality? Ilkley grammar school is heavily oversubscribed and has outgrown its historic site, again how can this school accomdate additional growth without a new school or significant changes to the district education provision.

I would like to comment on the proposed housing sites.

Regards the Countances Way proposal sacrificing green belt at this location will erode the boundaries between Ben Rhydding and Burley. Combined with the Ben Rhydding Drive proposal will lead to overdevelopment in this part of town. The proposed volume of new housing here will significantly add to to local traffic volumes particularly under Ben Rhydding railway bridge. I would like to see analysis to understand this would have on air quality and aesthetics of the village centre. This is a substantial release of green belt land and would like to see evidence for this compared to using historic mkll sites or empty offices within the district to provide housing units.

Further to my point above concerning overcrowding at IGS. A new school was proceed for some or all of the Countances Way site a number of years ago. In principle I do not support building on the green belt but this site is the only option for a replacement school outside the flood plain. Therefore if there is justification for building on green belt this site should be reserved for a replacement school and current IGS site used for housing.

I support the proposed site on Skipton road as this is an area of wasteland however I would hope that an access along the former railway line could be retained to allow future provision for an Ilkley to Addingham Greenway.

In relation to possible alternative sites for housing I would like to suggest the land between 162 Skipton road and the proposed site at IL2H. This land is above the flood plain and already considered within the town boundaries. Therefore would have a lesser impact on Ilkley's rural character and traffic flows than either of the Ben Rhydding proposals.

Another option within town boundaries could be development of flood resistant housing on the field between the river Wharfe and Langbar Road.

Object

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

Representation ID: 29036

Received: 23/03/2021

Respondent: Mr John Waddington

Agent: Eric Breare Design

Representation:

•Object to the rejection of OX/001 for development and its allocation as Local Green Space.
•Site was previously allocated for housing following an appeal to the Local Development plan.
•The Inspector stated the development should be guided by a Design Brief but this was not produced before PPG3 was released requiring brownfield sites to be developed first. Greenfield sites were given a release date but the government then required the Council to work on a RUDP. This land was allocated Village Green Space.
•Site put forward in the SHLAA and described as: “Village green-space notation does not represent the site as it has no public access and does not contribute in any way to the setting of the area. Slightly sloping grubby field between houses”
•Site is only designated Local Green Space following consultation with the Parish Council.
•The site does not meet the criteria for LGS as set out in the Oxenhope Neighbourhood Plan.
•There are no special features that give it beauty, no public access for recreation. Historic value is provided by the reservoir tower not from the adjacent field that does not contribute to the setting. The wildlife is not rich, the nesting bird are not identified. Site is too large to be designated LGS.
•The site at Cross Lane has more beauty and significance as a LGS. That site has more special features and is richer in wildlife.
•Also wrong to identify Green Belt site at Crossfield Road over this site as it undermines the Green Belt and sets a president for further Green Belt erosion.
•The site presents an opportunity for development with a sensitive design to mitigate any impact on the Conservation Area. A flood risk assessment and ecology survey would be carried out and mitigation measures provided. Open Space would be provided.
•The site is on a bus route with a stop adjacent to the site. Safe access could be provided from the wide frontage on Denholme Road. Some positive effects are predicted for a range of SA Objectives.

Full text:

Submitted on Mr Waddingtons behalf (Property owner in the area) and with his knowledge because he has no internet access.
Response to Land Allocation and rejection as a housing development site.
Site at Denholme Road Leeming Oxenhope Reference OX/001
As a former resident and current property owner, I object to the rejection of this site for Development and the allocation of the site as Local Green Space.
The site has a history of being allocated for development in the past. It was allocated for housing development following an appeal to the Local Development plan (UALP).
The planning inspector stated that its development should be guided by a Design Brief to be produced by Bradford Council. Unfortunately this could not be produced in time before the Governments release of PPG3, where brownfield site took president and greenfield site were allocated a release date. This site was given a release date of 2014. However again before that date the government instructed authorities to scrap their development plans and start work on their Replacement Unitary Development Plans. Following consultation with the Parish Council this land was re-allocated as Village Green Space.
In the S.H.L.A.A search for sites the land was put forward again for development. Following the development teams assessment the land was described as :- “Village green-space notation does not represent the site as it has no public access and does not contribute in any way to the setting of the area. Slightly sloping grubby field between houses”.
When the site is judged by the development team on its own merit, the site should not be Local Green Space. It is only following consultation with the Parish Council that this designation is allocated.
This site does not meet the criteria for Local Green Space as set out in the Oxenhope Neighborhood Plan. Local Green Space designation should only be used where the site is demonstrably special and holds local significance because of its beauty, historic significance, recreational value and richness of its wildlife.
There are no special features to the field that gives it any beauty. The land has no public access for recreation. The historic value in the area is the Reservoir and Valve Tower themselves and not just a field opposite, that does not contribute to the setting of the area. The wildlife partially identified could not be regarded as richness of wildlife. The two nesting birds are not identified and there are no habitats and nesting sites identified because non exist on the site. The site is also too large a parcel of land to be allocated for Local Green Space in it location.

On the other hand the land at Cross Lane has more beauty and significance as a site of Local Green Space. With it landscape and topography, protected hedgerows, Woodland with TPO and significant watercourse running round one boundary. These are special features that warrant Local Green Space allocation.
This land is also much richer in wildlife, with nesting birds in the hedgerows and trees. Wildlife habitat of badgers in the woodland and wildlife associated watercourse. Dear can be regularly seen on the land that come down from the surrounding Moorland to graze.
It is also wrong to identify land within the Green Belt at Crossfield Road for development over land
this site, because it undermines the very existence of the Green Belt and sets a president for further Green Belt erosion.
To develop the land on Denholme Road presents a real opportunity with a sensitive design to mitigate any impact on and enhance the conservation area. There is a small area of flood risk on the site, a flood risk assessment would identify the mitigation measures necessary and would present another opportunity to provide some high quality open space on the site. An ecological survey would be carried out to identify and mitigate accordingly.
The site is on a bus route with a bus stop right outside the site, access would be directly from Denholme Road where a wide road frontage would provide a safe access. Some positive effects are predicted for a range of 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 and employment areas.