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

Support

Representation ID: 27472

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

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.

Support

Representation ID: 27480

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Rejected Site SI/006

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.

Object

Representation ID: 27679

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Impacts from urban edge effects have been overstated in the HRA and no evidence is presented to demonstrate how these effects may be manifest on a large moorland site such as the South Pennine Moors. Our specific comments on this aspect of the HRA of the
draft Local Plan are set out below:
• Paragraph 4.3: It is incorrect to state that all allocated sites within 400m can cause fragmentation effects. It is the SPA/SAC which is protected not the surrounding land. Given that no development is proposed within the SPA/SAC it is impossible to see how fragmentation could be a potential impact pathway.
• Paragraph 4.12-13: The evidence provided for ‘urban edge effects’ is entirely related to lowland heathland sites. No evidence relevant to large moorland and other upland habitats is presented.
• Paragraph 4.14: The evidence regarding the impacts of domestic cats is entirely unproven, there is no evidence whatsoever to show that domestic cats affect birds at the population level.

The draft Local Plan HRA impact assessment of the loss of functionally linked land is therefore fundamentally flawed as it is not the presence of a certain type of habitat that is important, but the presence of SPA birds. This basic principle (tested in the case of Sun Lane) must be acknowledged in future iterations of the HRA. Given the various surveys that have now been carried out it is questionable whether the policy protecting land outside the SPA is necessary at all as there is no evidence of even sporadic (never mind regular) movement of birds from the SPA to surrounding land.

Object

Representation ID: 29696

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Barton Wilmore

Site ME/005

The other reason the Council have dismissed the site is due to ‘landscape impacts’.

Regarding site ME/005, the SA concludes as follows under question 7 (landscape and townscape):

The site is 1.2km south of the Nidderdale AONB, but residential development here would not be expected to have a discernible impact on or alter views into or out of the AONB, due to the presence of existing and similar built form to the north of the site and its location adjacent to the village of Menston. However, residential development at this site could result in the loss of open greenfield and Green Belt land that contains GI elements of potentially high visual amenity, including trees, and it would therefore be likely to adversely alter the local town scape and landscape character, although the nearby existing built form could help to limit the magnitude of
potential effects.

However, Pegasus’ assessment of the site concludes very differently, see below:

It is not considered that the development of the site would result in the loss of any landscape features that hold an individual landscape or visual value or are of a specific importance to the wider landscape character. Existing landscape features worthy of retention such as the trees within and bounding the site, and the stone walling along Burley Road could be incorporated as part of a new development. Together with new planting, retained vegetation would contribute to the well wooded character of the locality and help to integrate new development into the landscape.

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.