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

Object

Representation ID: 27091

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

NW19/H

The site is currently designated as Green Belt within the Replacement Unitary Development Plan (RUDP).

The Proposed Site Allocation Map identifies the site as a preferred housing allocation and of course is supported.

However, the Site Allocations Map also indicates that the site as being washed over by Green Belt. It is also displayed the same way in the separate ‘Local Area Strategy and Plan’ for Heaton set out below paragraph 5.5.48 of the main part of the draft local plan. This is clearly a cartographical error, as Policy SP5 (and associated accompanying text) of the draft plan relating to Green Belt is clear insofar as it identifies exceptional circumstances as required by paragraph 137 of the NPPF to remove land from the Green Belt, with part B of Policy SP5 listing the specific sites that should be released. This list includes site NW19/H.

Accordingly, both the Site Allocation Map and the separate Local Area Strategy and Plan for Heaton should be amended, with it clearly depicting the site removed from the Green Belt consistent with Policy SP5 and to solely indicate its allocation for housing.

Object

Representation ID: 27093

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Green Belt Site Assessment:

While we fully support the allocation of the site for residential development we disagree with the Council's green belt assessment for the site.

The Council’s assessment concluded that, overall, the site is located in a moderate performing Green Belt parcel and development of the site would result in major impact on the fundamental aim and essential characteristics of Green Belt in this location.

However, for the reasons set out above, it is considered that the impact upon the Green Belt has been overstated.

Notwithstanding this it is noted and supported that Council has clearly deemed that, in the context of the acute housing need and the absence of alternative sites, the benefits of developing this site for housing outweigh any harm to the wider Green Belt in this area.

As described in our comments in Table 3, the site adjoins an existing built up area to the east and is close to a range of uses and, although the site largely lacks built form, the topography and tree cover mean it is not particularly visible or prominent. The land is contained by physical boundaries to the north and east and will be largely self-contained.

It is considered that strong new Green Belt boundaries can be formed to prevent further development or sprawl, and this would continue to be the case should the additional land identified in Annex 2 be included as part of a future allocation.

Support

Representation ID: 27094

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

The site is located within a sustainable location with easy access of a good range of local services and public transport services.

Draft Policy SP5 acknowledges that Green Belt releases are required in order to meet the future housing requirements within Bradford. It is considered that the proposed removal of the site from the Green Belt and allocation for housing is justified and appropriate and that this would not prejudice the five purposes of the Green Belt as set out in the NPPF.

The site assessment demonstrates that the site has no significant technical constraints which would prevent its delivery for housing development.

The site (if expanded - see below) could accommodate up to 470 dwellings, providing a substantial contribution to the identified housing need, whilst responding to the site constraints, retaining key existing landscape features as well as incorporating public open space and new landscaping.

The site is available and deliverable now and would make an important contribution towards meeting the housing requirements of the District.

In light of the above, the proposed allocation NW19/H is supported and should be taken forward in the Draft Local Plan. It is also considered appropriate to extend the allocation to the north east and south east of the site and west of Shay Lane.

Support

Representation ID: 27104

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Persimmon agree with the position reached by the Council in Policy SP5 that exceptional circumstances exist to amend the Green Belt within the District and the evidence base is clear that such circumstances exist to accommodate the level of housing identified for the north western part of the Regional City of Bradford.

Object

Representation ID: 27105

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Site NW13/H is currently designated as Green Belt within the Replacement Unitary Development Plan (RUDP).

The Proposed Site Allocation Map identifies the site as a preferred housing allocation and of course is supported. However, the Site Allocations Map also indicates that the site as being washed over by Green Belt. It is also displayed the same way in the separate ‘Local Area Strategy and Plan’ for Heaton set out below paragraph 5.5.48 of the main part of the draft local plan.

This is clearly a cartographical error, as Policy SP5 (and associated accompanying text) of the draft plan relating to Green Belt is clear insofar as it identifies exceptional circumstances as required by paragraph 137 of the NPPF to remove land from the Green Belt, with part B of Policy SP5 listing the specific sites that should be released. This list includes site NW13/H.

Accordingly, both the Site Allocation Map and the separate Local Area Strategy and Plan for Heaton should be amended, with it clearly depicting the site removed from the Green Belt consistent with Policy SP5 and to solely indicate its allocation for housing.

Object

Representation ID: 27107

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Green Belt Site Assessment:

Although we fully support the allocation of site NW13/H for residential development we disagree with the Council's green belt site assessment.

Overall, it is considered that the site makes a very limited contribution to the Green Belt purposes. The site adjoins the existing built up area and there is no strong defensible boundary between the existing built up area and the site. Therefore, the development of the site would not harm the role of the wider Green Belt and a new defensible Green Belt boundary can be formed along the western edge of the site. It is also considered that land to the south west of the site could also be released from the Green Belt and be brought forward for additional housing (rejected site NW/31A). The site can be accessed via site NW13/H and also adjoins the existing built up area of Bradford. The boundaries of this site both to the north and south are considered weak in the Council’s assessment and, therefore, there is an opportunity to provide stronger Green Belt boundaries as part of the future development of the site.

Comment

Representation ID: 27108

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Highways

The Council’s assessment identifies that access can be taken from Millmoor Close, however, the total number of dwellings served off Bootham Crescent will need to be 200 or less as this is a cul-de-sac.

A Highways Note has been prepared by Optima presented in Annex 3 which demonstrates that safe and satisfactory vehicular and pedestrian/cycle access can be provided to Site NW13/H.

In accordance with national policy and the Leeds Council’s Street Design Guidance which is utilised by Bradford Council, the assessment shows that it is not necessary to provide two points of access above 200 dwellings Bootham Park/Sowden Road corridor can safely and satisfactory accommodate at least up to the 300 dwelling threshold, which the Council suggest is the figure above which a second point of access “must” be required.

On this basis, and deducting the existing 128 properties, it is concluded that up to 172 additional dwellings could be accommodated off Millmoor Close. Deducting the 58 dwellings which are proposed to be allocated at site NW13/H and the 12 dwellings at site NW12/H therefore leaves sufficient capacity in the local highway network for 102 dwellings to be developed at rejected site NW/031A and served via Millmoor Close.

Support

Representation ID: 27109

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

The site is located within a sustainable location with easy access of a good range of local services and public transport services.

Draft Policy SP5 acknowledges that Green Belt releases are required in order to meet the future housing requirements within Bradford. It is considered that the proposed removal of the site from the Green Belt and allocation for housing is justified and appropriate and that this would not prejudice the five purposes of the Green Belt as set out in the NPPF.

The site assessment demonstrates that the site has no significant technical constraints which would prevent its delivery for housing development.

The indicative masterplan demonstrates how the site could accommodate up to 60 dwellings whilst retaining existing tree buffers as well as incorporating public open space and enhanced landscaping. The site is available and deliverable now and would make an important contribution towards meeting the housing requirements of the District.

In light of the above, the proposed allocation NW13/H Millmoor Close is supported and should be taken forward in the Draft Local Plan.

It is also considered appropriate to extend the allocation to include land south west of the site which is capable of accommodating a further 100 dwellings.

Object

Representation ID: 27110

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

The allocation of site NW13/H is supported - however it is also considered appropriate to extend the allocation to include land south west of the site NW/031A which is capable of accommodating a further 100 dwellings.

The site could be accessed through site NW13/H - i.e. via Milmoor Close. We disagree with the Council's assessment that only 200 dwellings can be taken from Milmoor Close and that a second access woulkd be required (see comments made on site NW13/H).

The site adjoins the existing built up area of Bradford. The boundaries of this site both to the north and south are considered weak in the Council’s assessment and, therefore, there is an opportunity to provide stronger Green Belt boundaries as part of the future development of the site.

Support

Representation ID: 27470

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Silsden’s designation as a Local Growth Centre, as set out in Policies SP2: Spatial Priorities and SP3: Hierarchy of Settlements, is fully supported. As acknowledged within the Draft Local Plan, Silsden comprises a highly sustainable and strategically located settlement with strong links to nearby larger towns and cities due to its transport links.

It is therefore entirely appropriate that the settlement makes a significant contribution to meeting the District’s needs for housing and supporting community facilities and local services in line with its designation as a Local Growth Centre. However, in its current form the draft local plan is not facilitating this. Silsden has the ability to accommodate a greater quantum of housing in a sustainable manner without incursion into the Green Belt.