Site Assessment Update Report (Feb 2021)

Object

Representation ID: 30222

Received: 24/03/2021

Respondent: John Cordingley Consultancy

Site NE/072
I assumed that the land in question would have been allocated for housing. It is an obvious candidate for exclusion from the green belt. It is visually unobtrusive and suitable for housing, as opposed to limited agricultural use.

Please treat this letter as formal objection / representation.

The land is available for housing development. There are no issues on access to the full site.
These have been discussed previously

Object

Representation ID: 30223

Received: 24/03/2021

Respondent: Gleeson Homes and Regeneration

Agent: Peacock and Smith

The site is available (in the control of a housebuilder) and suitable for development; there are no constraints that cannot be addressed or mitigated for.

Although the Site Assessment Update Report 2021 asserts that the site should not be allocated due to
having “limited access”, we do not consider this a reason that can be sustained to justify the non allocation of the site.

Our client has control over part of the garden to 33 Kenstone Crescent, which allows for a suitable access to be achieved.

Furthermore, Idle is a settlement which hosts a wide range of services and facilities, including supermarkets, retail outlets, schools, medical facilities and public transport links. All of these are within close proximity of our client’s site

We conclude that site ref: NE/128 – Kenstone Crescent should be allocated for residential development.

Object

Representation ID: 30224

Received: 24/03/2021

Respondent: Keyland Developments Ltd

Agent: Barton Wilmore

As noted under our comments relating to Policy SP5, our Client objects to the Council’s decision not to allocate the residential element of the Esholt site / application for residential purposes (NE/053). It has been established that the Council can allocate land detached from the boundary of the Bradford North East sub-area i.e. sites NE22/E and NE23/E, so there is no procedural reason why they can not allocate the housing site.

The NPPF provides clear guidance on the approach Council’s should take when releasing land from the Green Belt, paragraph 138 states “where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport”. The guidance does not state that such sites have to be adjacent to existing settlement boundaries and it is presumed that this is intentional so not as to preclude suitable sites which are not adjacent to a settlement boundary.

Site NE/053 is a case in point. It does adjoin a settlement, but one which is not defined in the settlement hierarchy; however, it is previously developed and it well-served by public transport, being near to Apperley Bridge railway station. As such, the site is sequentially preferable to most Green Belt release sites which the Council are proposing.

In addition to this, the Council are fully aware of the exceptional level of design and sustainability that the development is proposing, and it is considered that this helps to further justify the sites release from the Green Belt as a proposed housing allocation. Ultimately, by allocating this site, it means that should the housing target remain as proposed by the Council, a small reduction in the amount of greenfield, Green Belt release could be achieved.

Object

Representation ID: 30225

Received: 23/03/2021

Respondent: Mr Peter Martin

Agent: Athena Planning and Development

SE/077
The landowners of Royds Hall Farm are seeking the allocation of Site SE/077 and the potential development land at Summer Hall Ing, Delf Hill for housing. The further development land is located directly adjacent to Site SE/077, is contiguous to the built up area and would form an acceptable and sustainable urban extension which could significantly contribute to the provision of affordable housing, resolution of anti-social behaviour and the regeneration of Delf Hill Estate. The landowners are working with BMDC Estates on the establishment of a Collaboration Agreement for the future marketing and sale of SE/077 and are committed to bringing these sites forward.

In conclusion, site SE/077 has been identified as a preferred site for housing development, since the 1990s, is currently allocated for development and has had a previous planning permission tested on appeal with no issues regarding proximity to a hazardous installation raised previously. It is considered that the reasons for allocating the site for housing development have not significantly changed to warrant not being included in the BDLP. Further it is considered discounting the site in isolation solely on the basis of the hazardous installation with no consideration to the previous planning history or other regeneration and anti-social issues prevalent at this location is not in accordance with the settlement hierarchy and vision of the BDLP or the objectives of BMDC.

Development at SE/077 will result in a capital receipt to BMDC, greatly assist in the resolution of current issues around anti-social behaviour and fly tipping, overall regeneration of the Delf Hill estate and contribute significantly to affordable housing in South East Bradford.

As above, any planning application and environmental assessment for housing development on site SE/077 would have regard to the appropriate HSE guidance and undertake an assessment of risk and develop a sensitive design layout as considered appropriate.

In summary, the landowners are hereby seeking the allocation of SE/077 for housing development within the BDLP since:
▪ being located within a consultation zone for a hazardous installation does not immediately preclude development or the allocation of land for development;
▪ the reasons for supporting the grant of planning permission and the previous housing land allocation have not significantly changed;
▪ development in this location would support and enable regeneration of the Delf Hill estate and wider area; and
▪ development in this location would assist with the cessation of ongoing nuisance caused by anti-social behaviour.

Object

Representation ID: 30249

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

Objection to the failure to allocate sites SH/044 and SH/048 for housing development.

It is requested that the Council consider sites SH/044 and SH/048 as one combined site for the purposes of the emerging plan.

It is considered that this combined site represents a logical rounding off of the settlement given its location between an existing school and residential development, would not lead to encroachment into the countryside, urban sprawl or the coalescence of settlements. As such, the land no longer serves a Green Belt purpose and should no longer be protected.

The site represents a far more logical housing site than site SH4/H, which does not relate as well to the settlement and would lead to encroachment into the countryside. Furthermore, the topography of the site is prohibitive with significant access issues.

The combined site SH/044 and SH/048 is not considered to be constrained and matters such as ecological impacts could be mitigated through future design proposals and the site represents a suitable and logical housing allocation.

The site is suitable, available and achievable and also includes previously developed land and is being promoted by a well respected local housebuilder and Bradford Council.

It is noted in the Council’s ‘Site Assessment and Rejected Background Paper’ that site SH/044 has been rejected on a single basis – access. This is incorrect as the Council have previously considered a pre-application enquiry (14/04390/PMJ) for this site for a development of 67 units. The Council’s highways officer stated, “it is considered that the proposal is generally acceptable and it is not anticipated that there will be any major highway issues arising from your proposals”. The indicative layout demonstrates that a suitable access can be achieved to serve SH/044 if it is brought forward in isolation and the Council have incorrectly dismissed the site.

Object

Representation ID: 30250

Received: 24/03/2021

Respondent: Avant Homes

Agent: Tetra Tech (Leeds)

Advocates the allocations of site ME/013 for residential development.

Consider that the site is the Site to be suitable, available, deliverable and achievable and performs favorably when compared against preferred options. For example the preferred green belt option site ME1/H has no direct access, and is reliant on access from the development site to the east, which has a well-documented history and issues with delivery. ME1/H is outside the Core Strategy Accessibility Standards. However, site ME/013 can be safely accessed direct from Otley Road, and complies with the Core Strategy Accessibility Standards.

Site ME0/13, does not appear to be covered in the SA and Strategic Environmental Assessment which forms part of the Local Plan Evidence base.

We disagree with the green belt assessment of site ME/013. Our proposed re-scoring would suggest the overall rating is downgraded from Major to Moderate.

In the context of the comments above and our view that housing targets for Menston should be higher we continue to promote site ME/013 for allocation.

Object

Representation ID: 30251

Received: 19/03/2021

Respondent: Harworth Estates Property Group Ltd

- Support allocation of rejected site 007 Burley Road Menston- (see attached documents for details)

Object

Representation ID: 30252

Received: 19/03/2021

Respondent: Harworth Estates Property Group Ltd

Support for rejected site HA/013 to be included in the plan (See attached documents for detail)

Object

Representation ID: 30253

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Barton Wilmore

Persimmon objects to the exclusion of site ME/005 as a proposed housing allocation, as it is a deliverable site which is suitable, available and achievable.

The only reason the Council have rejected the site is because of perceived Green Belt impacts and landscape impacts.

However, the Council have not fully justified specifically what the issues through their evidence base.

Persimmon have provided technical documentation which demonstrates that contrary to the Council’s conclusions, the development of the site would have minimal impact upon the Green Belt and the local landscape.

We consider that site ME/005 should be allocated based on the current housing requirement proposed in the draft Local Plan as it is suitable, available and achievable. However, in the context that the Council have a shortfall of 9,000 units across the Plan period and will therefore need to apportion additional units to Menston, this site should be allocated once the numbers are increased to the standard method level.

Detailed technical assessment so the site are provided - see submission document - including relating to highways, landscape, green belt, ecology

Object

Representation ID: 30254

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Barton Wilmore

Objection to the rejection of CO/011

Whilst we consider that site CO/011 is more appropriate than site CO/002 and should replace it is the only allocation in the village, we note that it is identified as an ‘alternative’ site. If the Council progress the Local Plan as proposed, we advise that site CO/011, which is only rejected because it does not adjoin the settlement boundary, is allocated as safeguarded land. The Council will need reserve land over the plan period as inevitably, not all allocated sites will come forward and having
safeguarded sites will help maintain a 5YHLS over the plan period.

Given that the Council are planning for a shortfall of 9,000 homes across the plan period as they are not accounting for the 35% uplift as required by the standard method, we strongly suspect that the Council will need additional sites to meet this significant shortfall. As the site is identified as an ‘alternative’, we anticipate it will be allocated in this event.

Object

Representation ID: 30255

Received: 12/03/2021

Respondent: Justin Whitehorn & Richard Robinson-Horley

Agent: WBW Surveyors Limited

Rejected Site – BI/050
The land should be added to the Preferred Housing Site Allocations for Bingley and identified as a housing site by the new Local Plan.
The land should also be released from the Green Belt to allow its development for housing under Policy SP5.
The site assessment indicates that the site was not allocated due to ‘Landscape Impact’ and ‘Heritage Impact’.

Landscape Impact
- Site is enclosed by other built development. In particular, the allotments to the north. Landscape impacts on the wider open countryside would be very minimal.

Heritage Impact
Laythorpe Farm is the nearest Listed Building and is located the south east. The building is located within the Sty Lane housing development site that permits the erection of 420-440 houses. Development on this current proposed site, to the west of Micklethwaite Lane, will therefore have no impact on the setting of the listed building given that it will be enclosed and directly adjacent to other permitted housing development.
The site is within the Leeds to Liverpool Canal Conservation Area and land to the north of the site, also forms part of the Micklethwaite Conservation Area.
The Leeds to Liverpool Canal Conservation Area is a long linear designation that comprises a variety of different land uses adjacent to the historic canal. This part of the conservation area is characterised by residential development located adjacent to the canal. Some is very modern (the recently constructed residential development to the south), some approximately 50-70 years old (The Drive to the south west of the site), and some formed from the conversion of traditional mill buildings (Airedale Mills to the south). In summary, there is a variety of different buildings, ages, and approaches to development undertaken. There is absolutely no reason why development cannot be undertaken on this site without unacceptably impacting on the character and appearance of the Leeds to Liverpool Canal Conservation Area.
With respect to the Micklethwaite Conservation Area, due to the distance from the site, and the existence of the allotment site between the Conservation Area and this site, the impact on the heritage asset is very minimal.

Object

Representation ID: 30256

Received: 24/03/2021

Respondent: J A Whitwham

Agent: WBW Surveyors Limited

Rejected site - CU/008
-Land should be added to the Preferred Housing Site Allocations for Cullingworth and identified as a housing site by the new Local Plan.
-The land should also be released from the Green Belt to allow its development for housing under Policy SP5. (detailed assessment provided).
Site CU/008 is a preferable site for housing allocation than proposed allocation CU/3H.
1. Site enclosed by other housing developments. Given the characteristics of the surrounding land uses, it would be logical to release this site from the constraints of Green Belt policy. CU/008 would be a sensible rounding off of the Green Belt boundary, whereas this would not be the case with CU/3H which would project out into the open countryside. The impact on the rural character and appearance of the open countryside would be minimal as previous development has already altered it.
2. ‘topography’. It is accepted that the site slopes downhill to the south east and careful consideration will therefore need to be given to finished floor levels of the new dwellings and vehicular parking / manoeuvring areas. However, there is no reason why an appropriately designed scheme cannot be produced and this is not a reason of substance that justifies discounting the site. The topography has advantages. Most public views of the site will be from Bingley Road to the north west which is set at a higher level. New built development on the site will therefore be set at a lower level and will not be prominent in the local landscape. Development will simply infill the gap between existing built development.
3. ‘flood risk’. Only the south-eastern tips of the site, adjacent to Ellar Carr Beck, are within an identified area of Flood Risk. The final design of any scheme would need to ensure that this constraint was allowed for, but there is no reason why the development would be at an unacceptable risk from flooding, or could not provide surface water attenuation measures to ensure that flood risk is not exacerbated elsewhere.
4. The site is located close to the centre of the village and would therefore be a sustainable location for new development. The site has good access to local shops, services, and public transport. Development would help to further sustain the continued provision of those facilities within the settlement.
5. access could be achieved onto Bingley Road.
6. The landowner is willing to see the site developed and would be supportive of the allocation. There are no known obstacles or exceptional costs that would prevent development taking place on the site.

Object

Representation ID: 30261

Received: 23/03/2021

Respondent: Mr Andrew Hodgson

The council should revisit reassessing AD005 as a suitable alternative (to AD7/H) which has far less impact on the green belt in an accessible location.

Object

Representation ID: 30292

Received: 24/03/2021

Respondent: Mrs JM Ogilvie

Agent: Johnson Mowat

This response supports the allocation of AD1/H which is a preferred allocation with an identified capacity of 20 dwellings.

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

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

Comment

Representation ID: 30325

Received: 23/03/2021

Respondent: Addingham Environment Group

We support the Council’s reasons for rejecting all these sites except one, a site which forms a small part of AD008.
This is the site known as the “former garage site”. We consider that this site could be developed without having a major impact on the purposes of the Green Belt in this location. It is adjacent to the settlement boundary, within walking distance of village centre services and facilities, and close to a bus stop. Planning applications have been put forward recently for this Brownfield site and turned down. However, subject to a full ecological assessment of its potential impacts we would support building on this site.

Object

Representation ID: 30347

Received: 23/03/2021

Respondent: Mr Richard Hindle

Suggested alternative site so far rejected by the Council :

I also support the Environment Group with regard to the partial development of part of the rejected site AD008 (former garage). In line with my comments above, I suggest that this should be safeguarded for a type of mixed development which would secure additional employment in the village as well as a housing contribution. This might perhaps be in the form of live/work accommodation, and/or with a few small workshops and shared work/meeting space.

Object

Representation ID: 30348

Received: 24/03/2021

Respondent: Andrew Coates

Agent: Rural Solutions

REJECTED SITE AD/013
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.

Object

Representation ID: 30350

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

AD/005 should be included in the Plan, it is in the control of Chartford Homes, is suitable and deliverable and can deliver approximately 50-80 homes. These representations demonstrate the following,
- The need for significantly more homes in the plan;
- The need for more homes to be allocated in Addingham;
- The unsuitability of the proposed sites;
- The suitability of Our Clients site.
Addngham is tightly bounded by the Green Belt or designated Local Space, resulting in limited
opportunities for new housing to be developed.

The Council will need to allocate more homes, Addingham should receive a proportion of these and
this site is a suitable location for them. Should the Council not consider more homes are needed, it
is clear that at least one of AD3 or AD4 should be deleted in line with the evidence and as such a further site for 40 homes needed, which Our Clients site can provide.
However it is considered that once a methodology is published to be able to assess the sites our Clients site will be shown as more suitable and preferable and it should replace sites for approximately 80 homes

Support

Representation ID: 30352

Received: 23/03/2021

Respondent: Mr Andrew Hodgson

I would also be favour of including AD/011B and the larger site would accommodate more dwellings in an accessible and sustainable location thus removing the need to build on more valuable green belt sites to the west of the village.

Object

Representation ID: 30353

Received: 11/03/2021

Respondent: Neal Cowan

Rejected site: AD/005
Field between the cricket club and the Memorial hall have been rejected when they are closer to all amenities.

Object

Representation ID: 30356

Received: 18/03/2021

Respondent: Mrs Julie Cowan

The site AD/005 that was rejected in the centre of the village is a far better site for development even though it is on greenbelt.
It is close to all amenities in the village.
It would reduce to almost zero traffic entering and passing through the village
This site alone would provide most of the housing numbers for the whole village.
Residents can walk into the village and support local business a requirement of policy SP7
Entrance to the site is safe and easy.

The points re AD/005 are not present at site AD6/H.

Object

Representation ID: 30360

Received: 24/03/2021

Respondent: Mr Alastair Sim

Agent: Clive Brook Planning

The Council’s site specific Green Belt Review for the SHLAA referenced site IL/020B rejects the consideration of this site as a potential residential allocation on the grounds that the site is not attached to the urban area as defined by the land inside the settlement boundary of the main Ilkley urban area. I disagree with the conclusions reached.

While the site is not currently attached to the main urban area it was included within the 500m arc distance from the urban edge in the 2013 Growth Study produced by Broadway Malyan and which is still part of the evidence base for this emerging composite Local Plan. The Growth Study appraisal for this specific strategic parcel IL /SP/ 002 did not dismiss the potential of this site for a future residential allocation and gave much greater and more realistic consideration to the true scale of the housing need and demand for the Principal Town.

The only reason for the dismissal of this site is on the basis of non-attachment to the urban area whereas many sites are dismissed for a combination of two or three reasons. The Council argue in their dismissal of this site that it “could only come forward as part of a larger change to the Green Belt boundary including the release of the adjacent site IL/037 in association with IL/039 which lies to the west of IL/037. I totally disagree with this conclusion as there is a further linkage available involving the future development allocation of the preferred site IL/009 in association with the current residential cell to either side of Ben Rhydding Drive. Removing the current development cell from the Green Belt along with part of IL/020B and IL/009 this would achieve a logical association and an attachment with the urban are at the north western end of site IL/009.

This changed association and linked sites removal would be more logical and have less adverse impact on the five purposes of the Green Belt.

We have established specific exceptional circumstances for greater provision of housing on those sites which have strong sustainable development credentials. In association with the extensive environmental proposals for the total landholding these proposals form a truly sustainable development by meeting all three interlocking objectives (Environmental, Social and Economic -as contained in the NPPF) with enhancements in each case.