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

Object

Representation ID: 18018

Received: 24/03/2021

Respondent: Harworth Group & Nufarm UK Ltd

Agent: Johnson Mowat

The requirement of NPPF para 137 to fully examine all reasonable options to meeting identified need before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries is recognised.

However, the draft Policy should also reflect that certain development types require sites of a particular scale, type or location that is extremely unlikely to be able to be accommodated in a non-Green Belt location given the extent of the Green Belt across the district and the location of key infrastructure, in particular motorway junctions.

Plan paragraph 3.5.8 sates ‘the main demand for employment land is unlikely to have moved from the Bradford Urban Area (strongly within South East Bradford and M606 corridor) and surrounds’.

Policy SP4 should be amended to read:

‘Third priority to the release of Green Belt land where the locational requirements of particular development necessitate this, to meet identified development need in full and as set out under Policy SP5’.

Object

Representation ID: 18031

Received: 24/03/2021

Respondent: Harworth Group & Nufarm UK Ltd

Agent: Johnson Mowat

Please also refer to our comments on Policy EC1

Harworth and Nufarm object to the inclusion of sites NE22/E and NE23/E within the list at part C of draft Policy SP5 as these sites should not be allocated as employment sites.

Site NE22/E (see Section 5), this should be removed outright.

Site NE23/E should be developed for employment use only if planning permission is granted on the basis of ‘very special circumstances’ being demonstrated. Given a planning application is currently being considered by the Council, it is not necessary to remove this site from the Green Belt and allocate it as an employment site.

Alternative wording for Part D of draft Policy SP5 relating to NE23/E is given (see submission document). The proposals map should also be amended.

A further change to the Green Belt is justified in the location south and east of the Nufarm UK Ltd factory at Wyke to accommodate a strategically located allocation for employment development and to safeguard additional land.

Object

Representation ID: 18034

Received: 24/03/2021

Respondent: Harworth Group & Nufarm UK Ltd

Agent: Johnson Mowat

Safeguarded Land:

A safeguarded land designation may be appropriately used in the location broadly south and southeast of the Nufarm UK Ltd factory and north of the land we propose for employment allocation at Whitehall Road, Wyke

This will serve to allow a single, rational change to be made to be made to the Green Belt boundary in this location, whilst limiting the extent of the suggested employment allocation area to that which is currently deliverable in a manner compatible with the existing Nufarm UK Ltd business. It then allows flexibility for allocation of further employment land in this location at a future plan review stage without change to the Green Belt and on the basis of satisfactory relationship with the Nufarm UK Ltd business.

Object

Representation ID: 18067

Received: 24/03/2021

Respondent: Harworth Group & Nufarm UK Ltd

Agent: Johnson Mowat

Harworth and Nufarm support the aim stated at part A/1 of draft Policy SP6 for Bradford to be ‘the UK’s fastest growing economy getting more people into work and improving skills’. However, they have concerns that this aim is not matched / achieved, by the strategy of land allocation for employment development.

Part A/1d of draft Policy SP6 should be revised as follows:
‘Our globally connected district – making best use of and improving our transport infrastructure and digital connectivity to strengthen our global trading links and access new markets’.

Re B/2 of the policy - 72ha of land is inadequate provision to meet the stated aims to support business expansion, retain local jobs and attract new investment.

In order to ensure a correct range of sites / locations the following words should be added ti the policy:
‘For modern manufacturing and distribution, sites able to deliver large format development will be allocated in locations close to the motorway network, primarily in Bradford South’.

Object

Representation ID: 18069

Received: 24/03/2021

Respondent: Harworth Group & Nufarm UK Ltd

Agent: Johnson Mowat

Harworth and Nufarm object to draft Policy EC1 on the basis that the policy does not allocate sufficient land to meet employment land need and deliver economic growth as set out in our response to draft policy SP6 (above); and that the policy does not allocate land of appropriate site size, type or location to meet employment land need and deliver economic growth.

The policy depends too greatly upon large sites in locations not well suited to the core industrial/warehouse market. In particular, the ‘Esholt Strategic Employment Area (SEA)’ sites (NE22/E and NE23/E) total 31.55 ha representing 45% of the total supply in a location c.10km from the motorway network.

Draft proposed allocations NE22/E, NE23/E and NE24/E should be omitted.

Additional alternative sites are required to be identified. This should include, as a minimum, the allocation of ‘Land north of Whitehall Road, Wyke’ (our ref. EM114/A) for c.21 ha of employment land for B2/B8 use.

Suggestions are made regarding amendment to strategic sites, medium and large sites and smaller sites (see attached document).

Object

Representation ID: 18073

Received: 24/03/2021

Respondent: Harworth Group & Nufarm UK Ltd

Agent: Johnson Mowat

Harworth and Nufarm are generally supports the principles set out in draft Policy TR6, however consider elements of this to be overly generic, reflecting principles that may not be applicable to Bradford district(for instance part B - we are not aware of any significant intermodal freight facilities (i.e. road/rail, road/waterway) existing in Bradford district.

We are not aware that any substantial freight is handled at Leeds Bradford Airport such that this would justify the location of major storage/distribution development on the basis of its proximity to the airport.

This policy wording is therefore at risk of encouraging storage/distribution development to be inappropriately located.

Accordingly, the draft Policy wording should be revised as follows:
‘Encourage the location of storage/distribution development with high levels of freight and commercial traffic close to intermodal freight facilities, airports, or roads designed and managed as traffic distributors and close to intermodal facilities where this is demonstrated to be appropriate to the use proposed.’

Object

Representation ID: 18074

Received: 24/03/2021

Respondent: Harworth Group & Nufarm UK Ltd

Agent: Johnson Mowat

At 31.55 ha representing 45% of the total employment land supply, the ‘Esholt Strategic Employment Area (SEA)’ is disproportionate to the overall distribution of employment land, the nature/sector of the uses indicated, and the suitability of the location for large numbers of HGV movements.

The SEA is located approximately 10km from the motorway network (M606)

Site NE23/E currently subject to a planning application does not therefore require an allocation to deliver employment development of an appropriate nature.

There is no justification for the allocation of site NE22/E (4.94 ha) other than its location between site NE23/E and the A658 Harrogate Road.

Sites NE22/E and NE23/E do not serve to meet the demand from occupier businesses and inward investors for employment development sites that are located close to the motorway network.

Draft Policy EC1 part D should be omitted (i.e. to omit sites NE22/E and NE23/E as employment allocations) and the proposals map amended accordingly.

Object

Representation ID: 18078

Received: 24/03/2021

Respondent: Harworth Group & Nufarm UK Ltd

Agent: Johnson Mowat

At 31.55 ha representing 45% of the total employment land supply, the ‘Esholt Strategic Employment Area (SEA)’ is disproportionate to the overall distribution of employment land, the nature/sector of the uses indicated, and the suitability of the location for large numbers of HGV movements.

The SEA is located approximately 10km from the motorway network (M606)

Site NE23/E currently subject to a planning application does not therefore require an allocation to deliver employment development of an appropriate nature.

There is no justification for the allocation of site NE22/E (4.94 ha) other than its location between site NE23/E and the A658 Harrogate Road.

Sites NE22/E and NE23/E do not serve to meet the demand from occupier businesses and inward investors for employment development sites that are located close to the motorway network.

Draft Policy EC1 part D should be omitted (i.e. to omit sites NE22/E and NE23/E as employment allocations) and the proposals map amended accordingly.

Object

Representation ID: 18079

Received: 24/03/2021

Respondent: Harworth Group & Nufarm UK Ltd

Agent: Johnson Mowat

At 31.55 ha representing 45% of the total employment land supply, the ‘Esholt Strategic Employment Area (SEA)’ is disproportionate to the overall distribution of employment land, the nature/sector of the uses indicated, and the suitability of the location for large numbers of HGV movements.

The SEA is located approximately 10km from the motorway network (M606)

Site NE23/E currently subject to a planning application does not therefore require an allocation to deliver employment development of an appropriate nature.

There is no justification for the allocation of site NE22/E (4.94 ha) other than its location between site NE23/E and the A658 Harrogate Road.

Sites NE22/E and NE23/E do not serve to meet the demand from occupier businesses and inward investors for employment development sites that are located close to the motorway network.

Draft Policy EC1 part D should be omitted (i.e. to omit sites NE22/E and NE23/E as employment allocations) and the proposals map amended accordingly.

Object

Representation ID: 18080

Received: 24/03/2021

Respondent: Harworth Group & Nufarm UK Ltd

Agent: Johnson Mowat

At 31.55 ha representing 45% of the total employment land supply, the ‘Esholt Strategic Employment Area (SEA)’ is disproportionate to the overall distribution of employment land, the nature/sector of the uses indicated, and the suitability of the location for large numbers of HGV movements.

The SEA is located approximately 10km from the motorway network (M606)

Site NE23/E currently subject to a planning application does not therefore require an allocation to deliver employment development of an appropriate nature.

There is no justification for the allocation of site NE22/E (4.94 ha) other than its location between site NE23/E and the A658 Harrogate Road.

Sites NE22/E and NE23/E do not serve to meet the demand from occupier businesses and inward investors for employment development sites that are located close to the motorway network.

Draft Policy EC1 part D should be omitted (i.e. to omit sites NE22/E and NE23/E as employment allocations) and the proposals map amended accordingly.