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

Object

Representation ID: 2355

Received: 19/03/2021

Respondent: Clive Brook Planning

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.

Object

Representation ID: 30069

Received: 23/03/2021

Respondent: Clive Brook Planning

Rejected site TH/013
Site specific submission for land at Spring Holes Lane, Thornton. (TH/013) Considers that a residential allocation of this land for a development of circa 58 dwellings. Will contribute to towards an enhanced requirement in Thornton (800 to 825 dwellings).

Some of the proposed greenfield and brownfield sites are subject to a variety of constraints and/or environmental requirements to accommodate reducing their combined capacity by around 100 dwellings.

Disagree with the overall conclusion reached in this site specific Green Belt assessment that the site has a major potential impact on the Green Belt.

Relationship of the site with Thornton Recreation Ground to the south west and the sports fields to the west presents opportunities for environmental improvements and appropriate landscaping

Disagree with the SA assessment against criterion 3 -Land and Buildings as the loss of a relative small area of greenfield land does not justify a major adverse impact rating.

Object

Representation ID: 30071

Received: 23/03/2021

Respondent: Clive Brook Planning

Rejected site EM/005
Request that the Council’s officers re-consider this site (EM/005) as a preferable, or additional, allocation to EM/007 as it brings a much wider range of benefits given its potential and its superior sustainability performance. It is also capable of making a meaningful contribution to market and affordable housing and to meeting the higher component of the full objectively assessed housing need which should be distributed to this Local Service Centre. This in conclusion would help to resolve the two key settlement issues identified for the village.

Object

Representation ID: 30072

Received: 24/03/2021

Respondent: Clive Brook Planning

Rejected site IL/015
Site specific submission for land in my client’s ownership to the south of Slates Lane and west of Coppywood Drive.

Proposal involves five dwellings with remainder of the site being retained in the Green Belt with proposed environmental enhancements in the retained field areas.

Presents an ideal opportunity for a small housebuilder or self-build projects - will help provide the variety of site opportunities being sought in policies HO4, HO6 and the innovation sought in policy SP8.

Area closely attached to a residential outlier cell washed over by the Green Belt. Could be resolved by taking this part of Curly Hill out of the Green Belt along revised boundary lines which closely follow the urbanized curtilages of houses in this cell and along the west to east highways forming the District boundary (Slates Lane and the linked section of Carters Lane). Would provide a clear, logical and highly defensible boundary.

Object

Representation ID: 30075

Received: 23/03/2021

Respondent: Clive Brook Planning

Rejected site IL/020A
The exclusion (and subsequent allocation) of this site (IL/020A) from the Green Belt is justified in relation to the exceptional circumstances which apply to the housing need, requirement and supply at this Principal Town and the need for a range of sites including small deletions from the Green Belt where this can logically be achieved in association with adjacent nearby changes, as is the case in these particular location and site circumstances.

Object

Representation ID: 30132

Received: 24/03/2021

Respondent: Clive Brook Planning

Rejected site IL/016. Object to reasons for rejection in the SLA.

Sensitive landscape – statement appears to be derived from the SA. Landscape/visual appraisal was produced in 2016, providing initial but comprehensive assessment. Not clear whether this has been taken into account. Masterplan contains substantial and positive landscape proposals. Description of landscape and other environmental enhancement potential appears not to have been considered.

Limited access – no specific analysis provided to support this position. 2 proposed accesses in the masterplan have been surveyed. Separate access identified to preferred site IL/011B. Would be highly desirable to have comprehensive master plan for all land to north of the A65 with the two accesses proposed. Eastern access (at existing Victoria Road traffic lights) is the preferable main access point with potential to increase capacity of currently installed system.

Object

Representation ID: 30133

Received: 24/03/2021

Respondent: Clive Brook Planning

Site IL/016

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

TPO woodland – only woodland is outside site boundary.

Soil quality will not be depleted.

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

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

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

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

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

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

Object

Representation ID: 30147

Received: 23/03/2021

Respondent: Clive Brook Planning

THE SUSTAINABILITY APPRAISAL OF SITE EM/005

Given the description of the site and the summary assessment it appears that the larger site containing the southern residential curtilage and buildings has been included. This mistake needs to be rectified and a site sustainability re-assessment carried out.

Many documents have been provided and were covered in the formal pre-app assessment referred to in this response. It does not appear that these have been fully taken into account.

COMMENTS IN RELATION TO SPECIFIC SUSTAINABILITY CRITERIA USED

Criterion 3 Land and Buildings – the site has a better rating than the preferred allocation site- EM/007.

Criterion 4 -Climate Change resilience- It is not clear why this site is rated green pink- and the preferred site green+ when both are in FZ1 and there is only a very small area of differential which may be in the southern section of the site which should not have been included.

Criterion 6 Biodiversity and Geodiversity- Account needs to be taken of the proposals for the outline biodiversity, recreation and other environmental improvements which are proposed for this site and which are wholly capable of being accommodated on site. This does not apply to site EM/007.

Criterion 7 Landscape and Townscape- Landscape improvements have been discussed with officers at the pre-app meeting and are included in submissions. There is full potential to improve the current landscape as well as accommodating the proposed level of development, subject to detailed site planning and negotiations.

Criterion 10- Transport- Cliff Delph scores better than the preferred site.

Criterion 12- Accessible Services- the Cliff Delph site is marginally preferable to the preferred allocation.

Criterion 17 Education- Cliff Delph again scores better on access to schools.

Based on this rational comparison of performance the Cliff Delph site EM/005 is preferable to the much smaller selected allocation site EM/007.

Comment

Representation ID: 30148

Received: 23/03/2021

Respondent: Clive Brook Planning

SA of Sites AD3/H & AD4/H

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

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

Object

Representation ID: 30149

Received: 23/03/2021

Respondent: Clive Brook Planning

SA of Site Site TH/013

The site specific SA concludes that “development at this site would be unlikely to result in a significant effect, either positive or negative, on any SA objective. I disagree with the assessment against criterion 3 -Land and Buildings as the loss of a relative small area of greenfield land does not justify a major adverse impact rating.

We propose off-site environmental improvement contributions in the form of landscaping and other positive environmental changes towards the enhancement of Thornton Recreation Ground as a small improved parkland. This would make a contribution to the current deficit of parks and gardens space in the village of -5.24 hectares. These will require local consultation and discussion with the Council.