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

Support

Representation ID: 2279

Received: 19/03/2021

Respondent: Clive Brook Planning

We support the existing policy content but consider that it should be slightly expanded to positively encourage joint working with landowners/developers to enable the enhancement and expansion of green infrastructure networks.

Support

Representation ID: 2284

Received: 19/03/2021

Respondent: Clive Brook Planning

POLICY SP11:- PROTECTING THE SOUTH PENNINE MOORS SPA/SAC AND THEIR ZONE OF INFLUENCE:- On behalf of my clients we support the policy content but would wish to see positive and proactive working with landowners and developers particularly where they are able to facilitate substantial improvements to supporting habitat provision and other recreation opportunities outside the SPA/SAC .
See also our more specific comments on the Supplementary Planning Document for the South Pennine Moors SPA/SAC

Support

Representation ID: 2288

Received: 19/03/2021

Respondent: Clive Brook Planning

POLICY SP14:- MAKING GREAT PLACES- On behalf of my clients we support this policy and particularly welcome the insertion of sub criterion 6 of the policy with regard to open and collaborative working which is seen as necessary in order to help achieve the best outcomes. This positive and proactive approach should be included in other strategic policies which are essential to achieving high quality places, beautiful housing and environments which are accessible to all. These major gains for climate change, health and wellbeing , habitat improvements and biodiversity net gains will only be achieved by such open and collaborative working.

Support

Representation ID: 2294

Received: 19/03/2021

Respondent: Clive Brook Planning

Support with commentary on improvements which need to be made to the strength and delivery of this policy in an integrated manner with other strategic policies.

Object

Representation ID: 11807

Received: 23/03/2021

Respondent: Clive Brook Planning

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.

The Council’s Green Belt review rejects the site on outline Green Belt grounds and does not progress this site to a full site specific review. I disagree with the conclusions reached. While the site is not currently attached to the urban area within the settlement boundary of Ilkley it is within the Growth study 500 m arc parcel which did not dismiss the potential of this and related sites and gave much greater and more realistic consideration to the housing need and demand for this Principal Town.

The Council further conclude that it could only be considered for release in association with sites IL/037 and IL/039. I totally disagree with this conclusion as it could come forward, without IL/037 and IL/039, in association with IL/009 and the already developed sites in the current residential cell to either side of Ben Rhydding Drive.

I also disagree with the assessment that this site would have “a major potential impact on the Green Belt. Given the site’s association with existing development and its high degree of containment by this it cannot be concluded that its release would contribute to urban sprawl (purpose 1 in the assessment). Similarly, the development of this site would make no contribution to purpose 2 -preventing neighbouring towns from merging into one another. The site would only have a limited negative impact on purpose 3 of the Green Belt- assisting in safeguarding the countryside from encroachment. Purpose 4- the preservation of the setting and special character of an historic town we have argued does not apply in the Ilkley or Bradford wide context.

Object

Representation ID: 11822

Received: 23/03/2021

Respondent: Clive Brook Planning

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.

Green belt review of site - The description of the site submitted is incorrect as it only included the large northern component of my client’s landholding and not the house and gardens to the south. We argue that purpose 4 should be entirely removed from the Green Belt Review process.

SA - 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.

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

Object

Representation ID: 11824

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.

Support

Representation ID: 11825

Received: 23/03/2021

Respondent: Clive Brook Planning

Support for sites AD3/H and AD4/H.

A unifying master plan approach proposed for totality of the landholding (inc. remainder of land between sites) and the enhanced quality of the environment, place and design which can be achieved via the proposals including:

• Provision of on site habitat improvements, particularly in 4 southern fields, Other habitat/biodiversity enhancements will be included subject to consultation with local groups, who hold valuable expertise and survey information having closely monitored species within the village locality. Natural England and the Yorkshire Wildlife Trust will be consulted. Approach is to form a mosaic of habitats with appropriate after management plans.

• A network of tree and hedge planting improvements along existing and new lines are proposed with appropriate after management.

• The northern three fields which make up the designated Village Greenspace area will primarily be improved as a parkland area to provide certain on-site recreation facilities.

Object

Representation ID: 11826

Received: 23/03/2021

Respondent: Clive Brook Planning

Rejected Site TH/013

Site specific submission for land at Spring Holes Lane, Thornton. 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. In particular:

PURPOSE 3:- I disagree that the site plays a major role in Safeguarding the countryside from encroachment given its size, disposition and associations with settlement and development to the south , north west and due to topographical changes to the east. The countryside in the wider tract of Green Belt is crossed by pylon lines and other infrastructure and is a somewhat degraded landscape.

PURPOSE 4:- I have argued in response to the selected Green Belt Methodology that this criterion relating to the preservation of the setting and special character of historic towns has been misapplied and is not relevant to the Bradford District context.

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: 30054

Received: 17/03/2021

Respondent: Clive Brook Planning

Housing Distribution

On behalf of my landowner and developer clients I object to policy SP8 :- These objections relate to :-
1.The considerable under-assessment of the District's housing need and the lack of any applied uplifts to the baseline minimum housing need figure of 1,704 dwellings/annum.
2. The determination of the housing requirement and its distribution throughout the settlements in the Bradford hierarchy.
3. Objections to the proportion of the housing requirement which will be required from the Green Belt to meet the objectively assessed needs of the District in the most sustainable way. less