Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

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Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Consultation Question 111

Representation ID: 10858

Received: 19/03/2021

Respondent: JO Steel Consulting

Representation Summary:

Site is located within flood zone1.

Development accepted - 91/04052/OUT, vets surgery.

Residential development to SE(a cul de sac Waverley Avenue) - footings in the site show an intention to extend cul de sac.

GB purpose 1 moderate score is not justified, should be Low.

GB Purpose 2 - will not result in neighbouring towns merging. All are part of Riddlesden settlement.

The analysis overlooks the fact that Riddlesden merges into Crossflatts .

Purpose 3 - within a well-established urban area, there is no development within the site, that applies to most of the sites allocated.

This submission respects the boundary between flood Zone 1&2. - very important it is not physical nor visible, a new one would need to be put in place.

The site fronts onto a 10min bus route

1.5 h proposed, one of most sustainable sites in District.

Site can be delivered now.

Development will reduce the shortfall in five year supply.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Consultation Question 137

Representation ID: 10936

Received: 19/03/2021

Respondent: JO Steel Consulting

Representation Summary:

Site adjoins QB1/H and QB2/H, both in the same ownership.

Site has an extant permission for housing.

It is a Brownfield site.

Located very close to bus routes.

QB1/H frontage lacks a footway which will of course be installed should this scheme be allowed.

The site was subject to a pre-application enquiry (16/08515/PMJ)

The School has no off-site parking .The submitted layout provides this. The combined site based on that layout will yield 124 dwellings.

Development will make a significant contribution to housing for Queensbury and the District.

The inclusion of a part of SHLAA QB33 will offer a critical mass that will be attractive in terms of scale to a wide range of house builders.

A Permanent, visually prominent new defensible boundary to the Green Belt exists – the tree lined Harp Lane.

Development can offer community benefits over and above what are routinely required of all housing schemes.

Development will reduce the shortfall in five year supply.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Consultation Question 139

Representation ID: 10956

Received: 19/03/2021

Respondent: JO Steel Consulting

Representation Summary:

A site specific Green Belt Assessment has not been carried out. (Relates to rejected site TH/023).

-Buildings comprising these former mills now demolished.
-Two applications approved, decision notices never issued because s106 agreement required.
-A pre-application enquiry reply indicated additional areas that might have potential for development pending a review of the Green Belt boundary.
-Boundary as described would encompass land that was most involved with the operations of the former Mills when they were operational.
-The pre-application letter stated:
unlikely to result in a level of ecological landscape or heritage harm which could not be overcome through sensitive design.” development would , in conservation terms, transform the site from its current negative contribution to making a positive contribution.

-Brownfield/PDL.
-Sustainable location, near to frequent bus routes.
-Would make positive contribution to Conservation Area.
-Development can be delivered now, a housing allocation is justified on the additional area proposed.
-Development will reduce shortfall of five year supply.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Consultation Question 121

Representation ID: 10979

Received: 19/03/2021

Respondent: JO Steel Consulting

Representation Summary:

Site formerly comprised a railway embankment.

No Green Belt Assessment.

Reasons for rejecting site are challenged.

Existing dwellings to west, attaching site to urban area. This is not an extension into open country. Dwellings to east - listed Hollin Hall and also site IL02/H. There is a Caravan Club site adjoining the northern boundary .

Site is visually contained, can be justified as a “rounding off “site.

Less impact on landscape than historical case when site was an embankment.

No impact on views into/out-of the ANOB.

Site not suitable for agriculture

Impact on listed building to east will be neutral.

Access to the A65 with good sight lines is available.

Site could yield 30 units.

Site ideal to accommodate SB&CB housing.

Available/deliverable now.

Adjoins highway that carries public transport and close to bus stops.

This is a brownfield site.

Site will assist in reducing the shortfall of five year supply.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

OX2/H - Cross Lane

Representation ID: 10984

Received: 20/03/2021

Respondent: JO Steel Consulting

Representation Summary:

OX2/H designated VGS, should be protected.

Development would, leave no green space left to enhance , some of the site needed to safeguarded part of boundary with Moorhouse Beck.

Land adjoins Flood Zone 2&3.

Development constrained by two existing houses, creating an irregular shape, effecting layout of any development.

Primary school close to this site and parking on Cross Lane at pick-up/drop of times will be lost due to development.

Little weight given to “preserve the setting, special character of historic towns”.

Site contributes to Bradford's Green Infrastructure (GI) Corridors.

Site provides important views to the Oxenhope Station CA to the South Pennine Moors SPA/SAC. Development would be detrimental to CA.

Negative impact on the Uppertown CA.

Only one site benefits from the protection of policy OS7, these areas are a valued/important part the village. Its loss would have a major impact. By comparison Green Belt protection covers the greater part of the District.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

OA1/H - Pasture Avenue

Representation ID: 10995

Received: 20/04/2021

Respondent: JO Steel Consulting

Representation Summary:

2015 SHLAA “Site rejected by an Inspector at last plan” not explained.

Draft Local Plan assessment under the four purposes not completely accepted. Sloping site prominent in the landscape with long distance views, the open area can be viewed from many aspects.

Problematic access - frontage to Pasture Avenue is basically no more than an agricultural field gate, appeared to be very little used, will need to be developed into a made road.
The assumption that “visibility splays should be possible is a very challengeable, because the major frontage to Pasture Avenue has not been put forward, otherwise it would be included the site’s red line. Visibility splays will have to involve third party land. Is this site deliverable? maybe this crucial uncertainty has put the delivery timescale 11 years out?

The allocation should be removed. Other sites which can guarantee access without any potential third party, visual issues are available.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

OA2/H - Keighley Road, Sykes Lane

Representation ID: 10996

Received: 21/05/2021

Respondent: JO Steel Consulting

Representation Summary:

2015 SHLAA reads: “OA/007 Sykes Lane - "sloping fields between Keighley urban edge and Oakworth. Important visual break between two settlements allowing open views out toward Haworth. Access Limited”.

Green Belt Assessment, purpose 4 states: “The site is connected to the historic core of the settlement along its northern boundary. The site plays a significant role in providing the rural setting for the settlement, helps to preserve the special character of the historic-core.

Impact on the views towards the historic centre of Haworth and the openness/visual amenity of Green Belt.

Visually prominent site.

Visual impact of significant engineering required to construct access to current highway standards.

Access difficulties, opposite an existing junction, engineering works could involve third party land.

Site in area which is always congested due to school/Coop.

Emergency access required.

Whole of site assessment is red flagged/having a major impact.

Other sites available which score more positively on Assessment.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Consultation Question 133

Representation ID: 10999

Received: 21/03/2021

Respondent: JO Steel Consulting

Representation Summary:

Objection to the rejection of site OA/016 Wide Lane.

The Heritage impact reason cannot be substantiated as the Assessment makes clear.

An approved access offers adequate visibility splays

Development can offer a significant public benefit a new length of footpath, something that the Highway Authority will never be able to deliver.

Majority of the site has been previously developed.

This is a discrete site in landscape terms.

Well established tree belts offer a new defensible boundary to the Green Belt.

“When defining Green Belt boundaries plans should:
f) define boundaries clearly , using physical features that are readily recognisable and
likely to be permanent .“

This site can be delivered now, the landowner has engaged in talks with a local builder.

The Council still cannot demonstrate five years supply of land with permission for housing as required by the NPPF 2019. ( 2.06 years was the latest figure published- Five year Housing Land Statement)

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Consultation Question 135

Representation ID: 11001

Received: 22/03/2021

Respondent: JO Steel Consulting

Representation Summary:

Surface water flood risk has been removed.

Site is poor quality grazing land.

Northern boundary to the new houses comprises a wooden post/rail fence, and gabions.

Green Belt Assessment does recognise that a combination of Marsh Lane/Moorhouse Lane will be more compliant with the NPPF than a wooden post/rail fence.

The boundary proposed, two public highways are permanent and obviously defensible.

Green Belt Assessment is contradictory purpose 4, on page 2 the contribution is assessed as “major" yet the summary, which in this respect is agreed concludes that it is Low.

Site would represent a reasonably logical rounding off the settlement.

The site is seen in the context of recent development to the south and a ribbon of development fronting Marsh Lane to the west.

Landscape impact, site has no greater impact than some other allocations.

Could be delivered now for self-build, parties have already approached the landowner expressing self-build interest.

Contribution to 5 year supply.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Consultation Question 111

Representation ID: 11002

Received: 22/03/2021

Respondent: JO Steel Consulting

Representation Summary:

Landowner is to restrict the original proposal submitted area as far north as PROW 18. Add to the area the new Call for Sites submission shown edged blue on the attached plan.

New proposal represents a coherent area related to/adjoins the existing built-up-area and access can be obtained from a number of points.

PROW 18 to the north, and Hoo Beck to the east, offer new clear and defensible boundaries.

Proposal is more visually contained in landscape terms.

Close to bus stop providing an hourly service, extra houses proposed could lead to the current bus services being improved.

The proposals offer an opportunity to improve the surface of PROW 18.

Proposal will strengthen the eastern boundary visually/physically.

Suggested the proposal should achieve at worst a moderate rating across Purposes 2,3 and 4.

Site can be delivered now and housing allocation is justified.

Interest shown by housebuilders.

Assist in reducing the shortfall of a five year supply.

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