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

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Object

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

Sustainability Appraisal & Strategic Environmental Assessment - Appendix E - SUE Assessments

Representation ID: 29962

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

Representation Summary:

SUE Assessments - Holme Wood / Sites at Holme Wood

Chapter 6 of the Sustainability Appraisal (2021) is dedicated to assessing the SUE options. One of the sites assessed is that of the proposed Holme Wood SUE site (ref: SS/005). The Holme Wood SUE site encompasses the seven individual housing sites which make up the Holme Wood North and Holme Wood South sites, as depicted within Appendix F, focusing on the South Bradford Urban Area.

Clearly the overarching assessment for the Holme Wood SUE site contradicts the assessment of the smaller individual sites.

Object

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

Sustainability Appraisal & Strategic Environmental Assessment - Appendix E - SUE Assessments

Representation ID: 29963

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

Representation Summary:

SUE Assessments - Holme Wood / Sites at Holme Wood

Reasonable Alternatives

In line with NPPF and PPG guidance we note that BMDC have reviewed both the draft sites and reasonable alternatives for the SUEs, with a summary of assessments for reasonable alternatives shown at Appendix E.

Yet Raikes Hall Farm, Holme Wood (SE/163) had been omitted as part of the SUE reasonable alternatives with no rationale. By ignoring Raikes Hall farm from the assessment of reasonable alternatives BMDC are not in accordance with the requirements of the NPPF and a point of legal procedure, in ensuring all reasonable alternatives are assessed.

We have therefore provided a Savills Assessment for both sites incorporating all the SA objectives to enable a comparison between the two, in accordance with the NPP - it highlights that there is nothing to split the two sites apart. The assessment clearly highlights our client’s land under SE/163 is a sustainable option with the added benefit over SS/005 of significant regeneration credentials to Holme Wood. The SUE should therefore be reallocated and extended to include more growth at Holme Wood North and assessed on this basis.

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