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

Object

Representation ID: 28163

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

There are significant differences with the SLA estimated yield compared with the Draft Local Plan proposed yield. Further clarification relating to these yield discrepancies would be welcomed.

A number of detailed comments relating to yields and site boundaries are made in our detailed submission.

Support

Representation ID: 28165

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

We welcome the fact that analysis is given within the SA of the collective SUE as well as the individual site assessments.

Object

Representation ID: 28169

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

The Holmewood SUE receives a minor adverse effect against the Climate Change resilience objective (Objective 4), however individually, the Holme Wood South sites all score a minor positive effect against this objective.

We disagree with the overall minor adverse effect which relates to the overall long-term impacts of greenfield land being replaced with built form and the potential effects on the local extent of surface water flood risk. Holme Wood South lies in Flood Zone 1, and the site’s climate change resilience could be improved with the inclusion of Green Infrastructure, as illustrated on the Masterplan. The inclusion of SUDs and appropriate drainage strategies via comprehensive masterplanning will ensure that there is no increased surface water flood risk. The SUE score against this objective should be a minor positive.

Object

Representation ID: 28170

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

The SUE receives a major adverse effect against the Cultural Heritage Objective (Objective 8), however the individual sites of Holme Wood South score a neutral effect for sites SE19/H and SE49/H and a minor adverse effect for sites SE46/H and SE47/H against this objective. There are no listed buildings within Holme Wood South. Reference to there being six Grade II Listed Buildings, each being historic farm buildings, as well as the Grade II* listed Ryecroft Hall is incorrect and refers to a larger site SE/100 which is not proposed in full in the Draft Local Plan. There are no listed buildings within the Holme Wood South sites. The scoring needs reassessing and marked neutral.

Object

Representation ID: 28171

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

We disagree with the SA scoring against Objective 10: Transport which is predicted a minor adverse effect. This is unduly negative, considering the proximity of Holme Wood South to existing bus stops along Westgate Hill Street, the existing and proposed connections into the existing Holme Wood estate, and the proposed bus route, as indicated on the Masterplan. It is considered the score should be amended to a minor positive at least.

Object

Representation ID: 28172

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

We disagree with the major adverse effect against the Water Resources objective (Objective 5) for Site SE47/H.

The site is scored negatively due to the ‘presence of a waterbody’, which is the watercourse that traverses the site. This should not result in an adverse rating. The existing watercourse has been incorporated into the Masterplan, as part of the green infrastructure strategy, that provides a habitat rich environment. This should be seen as a positive effect or neutral.

Object

Representation ID: 28173

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

We agree with the major positive scores awarded to the Housing, Accessible Services, Social Cohesion, Education, Employment and Economy objectives for the SUE (Objectives 11, 12, 13, 17, 18 and 19). However, we there is an error in the scoring of the individual site scores against the Education Objective for sites SE46/H, SE47/H and SE48/H which all incorrectly state that the nearest secondary school is Tong Leadership Academy, when in fact the nearest Secondary School is Tong High School, located to the immediate west of Holme Wood South as indicated on the Opportunities and Constraints Plan at Appendix 1. These scores need revisiting.

Object

Representation ID: 28239

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

NW9/H

Site NW9/H has been individually assessed in the Sustainability Appraisal against the 17 sustainability appraisal objectives, with 9 of the scores being positive, relating in particular to most socio-economic themed objectives and the location of the site in relation to education, employment and health.

We disagree with the major adverse scoring of the site against the biodiversity and geodiversity criteria (SA Objective 6), which refers to a reduction in biodiversity value and local ecological connectivity. Design considerations including and appropriate green space, additional landscaping and habitat creation could improve and enhance biodiversity value and retain ecological connectivity. The scoring should be amended to a neutral effect.

Object

Representation ID: 28307

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

Sites NW10/H and Site NW/024

Both Site NW10/H and the whole extent of NW024 have been individually assessed in the Sustainability Appraisal against the 17 sustainability appraisal objectives.
The sites score almost identically against the criteria, with the exception of 3 criteria as explained below.

- Water Resources: The larger site NW/024 receives a major adverse effect against Criteria 5 – Water Resources, whereas Site NW10/H receives a minor positive score. We disagree with the major adverse score. The difference appears to relate to the presence of waterbodies within the site boundary of NW/024. This however should not result in an adverse rating. The existing pond located in the south west part of the site is not a constraint to development and provides an opportunity to retain and include as part of the green infrastructure strategy that provides a habitat rich environment. As identified on the Masterplan, this can be incorporated into SUDs and swale features within the site. It is considered the score should be amended to a minor positive in alignment with NW10/H.

- Biodiversity and geodiversity: Site NW10/H receives a major adverse score, whereas NW/024 receives a minor adverse score against this objective. We disagree with both scores. Both sites provide an opportunity to enhance biodiversity value, with the provision of open space, green infrastructure and additional landscaping. It is considered that the score should be amended to a neutral score for both sites.

- Housing: Given the size of NW/024 and the development scale, Site NW/024 receives a major positive score against this criteria compared with NW10/H minor positive score.

Comment

Representation ID: 30193

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

We agree with the major positive scores awarded to the Housing, Accessible Services, Social Cohesion, Education, Employment and Economy objectives for the SUE (Objectives 11, 12, 13, 17, 18 and 19). However, we there is an error in the scoring of the individual site scores against the Education Objective for sites SE46/H, SE47/H and SE48/H which all incorrectly state that the nearest secondary school is Tong Leadership Academy, when in fact the nearest Secondary School is Tong High School, located to the immediate west of Holme Wood South as indicated on the Opportunities and Constraints Plan at Appendix 1. These scores need revisiting.