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

Comment

Representation ID: 29664

Received: 24/03/2021

Respondent: Leeds City Council

The proposed allocations around the Holmewood area, encroaching into the green belt to the south of Tyersal and to the west of Drighlington, raises concerns.

Firstly, concerning the general encroachment and reduction of the strategic green belt gap between Leeds and Bradford; secondly the significant amount of green belt land that is required for release for 5 proposed housing sites for 1,447 new homes. The sites are SE45, 31, 13, 18/H and SE46, 47, 48/H and non-green belt site SE19/H and thirdly the overall impact of these sites and significant housing numbers on infrastructure provision in Leeds.

In setting exceptional circumstances for the release of these sites Leeds City Council would wish to see justification that all other options have been exhausted for housing in other locations within the settlement hierarchy.

It is also understood that Bradford City Council’s position is that the highway improvements as shown on the interactive map for Wakefield and Tong Road are sufficient to support the number of houses proposed. We wish to reserve our position on this until further evidence / information is provided through further consultation and duty to cooperate discussions.

Comment

Representation ID: 29665

Received: 24/03/2021

Respondent: Leeds City Council

The proposed allocations around the Holmewood area, encroaching into the green belt to the south of Tyersal and to the west of Drighlington, raises concerns.

Firstly, concerning the general encroachment and reduction of the strategic green belt gap between Leeds and Bradford; secondly the significant amount of green belt land that is required for release for 5 proposed housing sites for 1,447 new homes. The sites are SE45, 31, 13, 18/H and SE46, 47, 48/H and non-green belt site SE19/H and thirdly the overall impact of these sites and significant housing numbers on infrastructure provision in Leeds.

In setting exceptional circumstances for the release of these sites Leeds City Council would wish to see justification that all other options have been exhausted for housing in other locations within the settlement hierarchy.

It is also understood that Bradford City Council’s position is that the highway improvements as shown on the interactive map for Wakefield and Tong Road are sufficient to support the number of houses proposed. We wish to reserve our position on this until further evidence / information is provided through further consultation and duty to cooperate discussions.

Comment

Representation ID: 29666

Received: 24/03/2021

Respondent: Leeds City Council

We note that there is further work to be carried out regarding detailed site requirements for the proposed allocations as issues are highlighted within the site assessments, SA appraisal and green belt assessments. With regard to the sites mentioned above, should the sites be allocated, site requirements should ensure that these sites are brought forward in a comprehensive, master planned manner. To achieve this it may be necessary to combine the sites into a single allocation. We wish to reserve our position on this until further evidence/information is provided through further consultation and duty to cooperate discussions.

The sites are SE45, 31, 13, 18/H and SE46, 47, 48/H and non-green belt site SE19/H

Comment

Representation ID: 29668

Received: 24/03/2021

Respondent: Leeds City Council

At this time we note that Bradford City Council are not proposing to identify a further set of safeguarded land as in its view there is not enough evidence at present to support further release. Within this consultation there is a further call for sites, however this decision will be reviewed following the consultation and further work on the extent of growth options which includes the land to the east of Holmewood through the potential investment in the form of the South East Bradford Access Road (SEBAR).

We wish to reserve our position on this as additional work until this evidence/information is provided through further consultation and duty to cooperate discussions.

However, significant concern is raised regarding the SEBAR and its impacts on the green belt, on Leeds City Council’s Site Allocations Plan (adopted September 2019) identified and allocated sites and the impact upon climate change. Both Leeds City Council and Bradford MDC have declared Climate Emergencies. The Council would not wish to see an incremental growth of the South East of Bradford (potentially invited through safeguarded land designations) which would raise future issues around infrastructure provision / burdens on development that are best dealt with at an early stage and in a comprehensive manner.

Comment

Representation ID: 29669

Received: 24/03/2021

Respondent: Leeds City Council

The plan proposes allocations for @70ha of employment land. 30ha are required through green belt release.

Specific reference is made to proposed employment allocation SE37/E North of Westgate Hill and West of Tong Road. In setting exceptional circumstances for the release of this site Leeds City Council would wish to see justification that all other options have been exhausted for employment in other locations.

It is also understood that the highway improvements as shown on the interactive map for Wakefield and Tong Road are sufficient to support the number of houses proposed. We wish to reserve our position on this until further evidence/information is provided through further consultation and duty to cooperate discussions.

Comment

Representation ID: 29671

Received: 24/03/2021

Respondent: Leeds City Council

Other key sites the plan proposes to allocate will result in encroaching into the green belt: NE22 and NE23/E – Apperley Bridge/Esholt.

These sites have an ongoing planning application on them which Leeds City Council are in dialogue on through the planning application consultation process, raising issues on impact on greenbelt, air quality, traffic impacts, etc) and we wish these discussions to continue through that process and also through the duty to cooperate, where appropriate.

Comment

Representation ID: 29673

Received: 24/03/2021

Respondent: Leeds City Council

Other key sites the plan proposes to allocate will result in encroaching into the green belt: NE22 and NE23/E – Apperley Bridge/Esholt.

These sites have an ongoing planning application on them which Leeds City Council are in dialogue on through the planning application consultation process, raising issues on impact on greenbelt, air quality, traffic impacts, etc) and we wish these discussions to continue through that process and also through the duty to cooperate, where appropriate.

Comment

Representation ID: 29677

Received: 24/03/2021

Respondent: Leeds City Council

Infrastructure

a. From discussions and stated in the plan there is more work to be carried out on the accumulative impacts of the plan and allocations, for example with regard to Leeds City Council’s services, highways, flooding, schools (new and extensions), freight park, wildlife, biodiversity, flooding and detailed site requirements, etc. We wish to, reserve our position on this until further evidence / information is provided through further consultation and duty to cooperate discussions.

Comment

Representation ID: 29678

Received: 24/03/2021

Respondent: Leeds City Council

4. Climate change

a. The plan states that it will achieve a target of net zero carbon emissions by 2038 and has a clean air zone. The plan has detailed polices relating to flooding, air quality, green infrastructure, environmental policies to achieve this target. Leeds City Council supports the intent of these policies.

Comment

Representation ID: 29679

Received: 24/03/2021

Respondent: Leeds City Council

5. Gypsy, Traveller and Travelling Show People

a. Since the CSPR (2019) consultation where Leeds City Council raised issues regarding the number of pitches proposed, Arc4 have carried out commissioned work and the Plan has increased the number of pitches required in discussion with GATE. This is welcomed. There is a call for sites as part of this consultation and therefore we wish to reserve our position on this until further evidence / information is provided through further consultation and duty to cooperate discussions.