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

Support

Representation ID: 27471

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Support the conclusions reached in the site allocation pro-forma.

Persimmon has undertaken technical work to inform development of a masterplan for its development as part of the wider site SI/004. This work confirms the conclusion set out within the Site Assessment Update Report (February 2021) that site SI/004A is suitable and deliverable for housing development.

However note our objection to the failure to allocate the wider site area (see separate representation).

Comment

Representation ID: 27474

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

This site was removed from the Green Belt and identified as safeguarded land in the 2005 UDPR. The site now remains outside the Green Belt and within the settlement boundary. Despite this, and the present need for additional housing within the district, the site has not yet come forward for development and we are not aware of any active discussions or planning applications regarding the site’s development. We note that the site is owned by CBMDC.
It is unclear whether acceptable access to the site can be achieved given the nature of the narrow
streets and on street parking on the approach to the site. Site levels could also present a potential barrier to the site’s delivery.
This site scores less favourably than sites SI/004A, SI/004 and SI/003 in respect of flood risk (SA Objective 4) and access to public transport (SA Objective 10).

Comment

Representation ID: 27475

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

This site was removed from the Green Belt and Identified as Safeguarded Land suitable to meet long term housing needs in 2005 in the UDPR. Despite this, and the present need for additional housing within the district, there have been no planning applications progressed at the site and we are not aware of any pre-application discussions regarding its development. Indeed, we are aware that there are existing disputes over title which calls into question its availability and at very least is likely to prevent the site coming forward for residential development within the plan period. Given this position it is unclear what evidence CBMDC has to justify identifying the site as a draft housing allocation at this stage.

Comment

Representation ID: 27476

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

As the proforma for this site within the Draft Local Plan confirms, there is no direct access to site SI4/H, with access proposed to be taken from the adjacent site (SI/020 or SI5/HC: Keighley Road). Whilst the detailed plans approved in respect of site SI5/HC indicates two potential points of access into the site, site access is ransomed by at least one third party, and both access points are required to cross Sykes Lane as an unregistered and un-adopted road. It is therefore important for the plan to acknowledge that delivery of site SI5/HC does not necessarily guarantee the delivery of site SI4/H, and significant concerns regarding the achievement of site access are likely to undermine the site’s deliverability.
Even if the access could be resolved, the site is in multiple ownerships and cannot reasonably be considered to be available and deliverable now. There are also other key site constraints which would need to be overcome in advance of, or mitigation incorporated within the development, including the loss of allotments and potential impacts on Sykes Lane (identified in the emerging Neighbourhood Plan as a key feature/protected lane).
The Sustainability Appraisal identifies potential major adverse effects on climate change (SA Objective 4) on account of parts of the site being within flood zones 2 and 3, and the site’s location within a green infrastructure corridor (SA Objective 6). These scores are worse than those predicted for sites SI/003 and SI/004.
It is therefore not considered that there is sufficient certainty for this to be a preferred allocation, particularly when there are other comparable, and more sustainable, non-allocated sites which can demonstrate immediate deliverability

Comment

Representation ID: 27477

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

This site has detailed planning permission for 156 dwellings and is therefore expected to come forward within the plan period in accordance with this permission.
It is of note that this site attracts more negative scores in respect of SA Objectives 6 (Biodiversity and Geodiversity) and 4 (Climate Change Resilience) than sites SI/003 and SI/004.

Comment

Representation ID: 27478

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Whilst these two sites are currently in use, a new 3 form entry primary school is under construction such that sites SI6/H and SI7/H are likely to become available for development in the short-medium term.
At 42-43 dwellings per hectare, the estimated yields at these sites appear high, particularly if the existing buildings are of historic interest, as suggested by the pro-forma for site SI6/H, and the existing buildings are to be considered for retention. Any reduction in yield would potentially require additional sites being identified for allocation even before any uplift in the apportionment of housing to Silsden is considered (as advocated elsewhere in the representations).
If the level of housing identified for Silsden remains as proposed then the allocation of sites SI/004 and SI/003 would be preferable to a number of the currently identified preferred allocations.

Comment

Representation ID: 27479

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

This site is subject to a live planning application for six semi-detached dwellings. At the time of writing there appear to be several significant unresolved planning issues, including loss of amenity space, impacts on protected trees, drainage and highways matters. Silsden Town Council objects to the application on similar grounds, and strongly objects to the loss of more green urban space.
Whilst it is recognised that the granting of planning permission would demonstrate the suitability of the site for housing development, site SI8/H and the Development of urban greenspace, does not appear to be an appropriate housing allocation, particularly in light of other deemed suitable for development by the Council’s own evidence case.
SI8/H should not comprise preferred allocatiions.

Object

Representation ID: 27595

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

ZONE A - The policy does not state whether the partial inclusion of the site in Zone A excludes development across the whole site or whether it is only that part of the site within the 400m zone that is excluded. The policy must be made clear that only areas within 400m of the Habitats site are affected and not the entirety of potential development sites that may straddle the 400m zone.
The Zone A exclusion is based on the recommendations within the HRA for the draft Local Plan. All of the cited evidence for excluding residential development from the zone within 400m of the SPA originates from studies of lowland habitats, particularly heathland. In the case of lowland heaths the scientific evidence is very poor and a causal relationship between residential development within 400m and birds numbers or habitat degradation has never been established. There is no evidence that residential development within 400m of moorland and other upland habitats has any detrimental impact upon either SPA birds or the habitats which are the interest features of the SAC. There is no empirical evidence provided in the HRA for the draft Local Plan to suggest the assertion that ‘urban edge effects’ impact on upland habitats. Studies specific to lowland cannot be simply transposed to upland habitats which have very different characteristics and are not accessed in the same way or subjected to the same pressures as lowland heaths. The relevance to the qualifying species of the SPA has not been established. The HRA cites the impact pathway of cat predation however there is no evidence that cats have any adverse effects on bird populations a view which is not supported by the RSPB (see link).
This policy zonation is entirely unjustified by any scientific evidence and should be removed from the policy.

Object

Representation ID: 27641

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

ZONE B relates to such evidence that may be reasonably required, as to whether land proposed for development affects foraging habitat for qualifying species of the SPA. The guidance in the HRA for the draft Local Plan (see below) and the South Pennine Moors SPA/SAC SPD does not adequately describe what evidence will be required (for example, survey effort and methods) to establish whether land is or is not functionally linked to the South Pennine Moors SPA/SAC. The HRA of the draft Local Plan and SPD should be based on field survey evidence of the presence of SPA birds rather than just desk-based study and the modelling of habitat types. It is essential to first establish whether or not a potential development site supports SPA birds (i.e. birds which are actually associated with CBMDC Draft Local Plan Review Persimmon Homes West Yorkshire 4 the SPA and are regularly moving between the SPA and the development site).
If this policy is to remain then it must be reworded to reflect that fact that it is only land that is used by SPA birds which may be regarded as functionally linked land not simply habitat that may be used theoretically.
“In Zone B it will be considered, based on such evidence as may be reasonably required, whether land proposed for development affects foraging habitat DEL<for> INS<used by> DEL<the qualifying species of the> SPA INS<birds>. Further guidance can be found in the South Pennine Moors SPD.”

Comment

Representation ID: 27644

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

ZONE C - Section D referenced the ‘roof tax’ approach to mitigation of recreational effects that the Council is proposing to introduce through the SPD as such the policy should be clearly linked to policy SP11, C 3 b which it addresses. We suggest the following update to the wording of the text.
The South Pennine Moors SPD sets out a strategic mitigation scheme and a mechanism for the calculation of the financial contributions "< under policy SP11, C, 3b>" to mitigate recreational impacts on the SPA and SAC as a consequence of housing growth and subsequent population increases.