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

Support

Representation ID: 27779

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

The aims of Policy EC3 in improving local skills delivery and opportunities for local employment is unreservedly supported. In order to best achieve these goals and to maximise the improvement of local employment and skills it is recommended that the requirement set out in Part A of the policy, requiring at least 10% of the workforce employed from 20% of the most deprived areas, to be applied flexibly and ‘wherever possible’ added to this part of the policy to ensure that projects are not delayed or undermined by unnecessary skills shortages.

Comment

Representation ID: 27781

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

It is assumed that those development requirements set out in sub-section D of Policy EN8: Air Quality, including the requirement for developments to be ‘air quality neutral’, refer only to developments proposed within the Clean Air Zone (CAZ) (as identified on the proposals map) as such requirements are unlikely to be justified outside the CAZ. It is therefore recommended that this is clarified within the policy.

Comment

Representation ID: 27782

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

It is noted that Policy CO1 contains reference at Point D to residential developments which contribute to recreational pressure upon the South Pennine Moors SPA and SAC being required to mitigate these effects in line with the requirements of Policy SP11 and the South Pennine Moors SPA/SAC Planning Framework SPD, which could include the provision of new recreational natural greenspaces or improvement to existing open spaces.

Suggested amendments to Policy SP11 set out above and in Appendix 2 will ensure that reference to the provision of new, or improved, open space as having the potential to mitigate recreational pressure on the SPA/SAC is consistent with the provision of Policy SP11 and the accompanying SPD.

Support

Representation ID: 27816

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Policy SP15 provides an overarching framework for the consideration, and encouragement, of the creation of healthy places, with Policy CO3 requiring all major developments to undertake a screening assessment and, where applicable, a subsequent Health Impact Assessment (HIA) for major developments, commensurate to the scale of the development, to accompany the planning application.

Whilst the intention of policy SP15 in encouraging development proposals to positively design for creating healthy places is supported, HIA, or HIA screening, as required by Policy CO3 is considered to be an unnecessary requirement. Compliance with the health related planning policies and themes set out in Policy SP15 can be addressed sufficiently within Planning Policy Statements and Design and Access Statements typically submitted with residential applications, and certainly for all major residential applications where such matters would be considered by officers without the need for further reports. It is therefore requested that Policy CO3 be removed from the draft Local Plan.

Object

Representation ID: 27817

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Policy SP15 provides an overarching framework for the consideration, and encouragement, of the creation of healthy places, with Policy CO3 requiring all major developments to undertake a screening assessment and, where applicable, a subsequent Health Impact Assessment (HIA) for major developments, commensurate to the scale of the development, to accompany the planning application.

Whilst the intention of policy SP15 in encouraging development proposals to positively design for creating healthy places is supported, HIA, or HIA screening, as required by Policy CO3 is considered to be an unnecessary requirement. Compliance with the health related planning policies and themes set out in Policy SP15 can be addressed sufficiently within Planning Policy Statements and Design and Access Statements typically submitted with residential applications, and certainly for all major residential applications where such matters would be considered by officers without the need for further reports. It is therefore requested that Policy CO3 be removed from the draft Local Plan.

Object

Representation ID: 28384

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Propose that 2 additional areas are added to preferred option NW19/H to provide an additional 6-7ha.

See submission document and appendices 2 and 3 for details.

Object

Representation ID: 29692

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Barton Wilmore

Persimmon objects to the exclusion of site ME/005 as a proposed housing allocation, as it is a deliverable site which is suitable, available and achievable.

The only reason the Council have rejected the site is because of perceived Green Belt impacts and landscape impacts.

However, the Council have not fully justified specifically what the issues through their evidence base.

Persimmon have provided technical documentation which demonstrates that contrary to the Council’s conclusions, the development of the site would have minimal impact upon the Green Belt and the local landscape.

We consider that site ME/005 should be allocated based on the current housing requirement proposed in the draft Local Plan as it is suitable, available and achievable. However, in the context that the Council have a shortfall of 9,000 units across the Plan period and will therefore need to apportion additional units to Menston, this site should be allocated once the numbers are increased to the standard method level.

Detailed technical assessment so the site are provided - see submission document - including relating to highways, landscape, green belt, ecology

Object

Representation ID: 29693

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Barton Wilmore

Green Belt Assessment of ME/005

In the ‘Site Assessment and Rejected Sites Background Paper’ the Council confirm that site ME/005 is rejected on the following grounds – Green Belt Impact and Landscape Impact.

However, having reviewed the Council’s evidence base we have been unable to locate the Green Belt Assessment, which the document implies has been undertaken.

For context, the Green Belt Appraisal conducted by Pegasus on behalf of Persimmon concludes as follows:
Whilst the removal of the site from the Green Belt would result in some harm to the Green Belt by virtue of the direct impact of its footprint, the actual perceivable extent of harm would be minimal and would not significantly affect any Green Belt purpose. The development of the site offers potential to discretely and neatly ‘round off’ the settlement edge and provide a strong defensible Green Belt boundary.

Pegasus, who undertook the appraisal made the following assessment:

Purpose 1 – to check the unrestricted sprawl of large built up areas – there would be no unrestricted sprawl

Purpose 2 – to prevent neighbouring towns from merging into one another – there would be no merging of neighbouring towns

Purpose 3 – to assist in safeguarding the countryside from encroachment – development of the site would result in minimal encroachment into the countryside

Purpose 4 – to preserve the setting and special character of historic towns – development of the site would have no impact on the setting and special character of historic towns

Purpose 5 – to assist in urban regeneration, by encouraging the recycling of derelict and other urban land – not assessed

Object

Representation ID: 29694

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Barton Wilmore

Landscape Assessment of ME/002

The other reason the Council have dismissed the site is due to ‘landscape impacts’. In order for the Council to have come to that conclusion we would expect there to have been a landscape document within the Council’s evidence base which had been prepared by qualified landscape architects and which assesses the site and its landscape impacts. We have been unable to locate any such document and it is therefore assumed that the Council are relying on the site appraisal comments
within the Sustainability Appraisal (SA), which has been prepared by Arcadis.

The SA states that development of the sit would potentially lead to the loss of green infrastructure elements such as trees that are high visual amenity, which would likely adversely impact upon town and local
character.

However, Pegasus’ assessment of the site concludes very differently, see below.

It is not considered that the development of the site would result in the loss of any landscape features that hold an individual landscape or visual value or are of a specific importance to the wider landscape character. Existing landscape features worthy of retention such as the trees within and bounding the site, and the stone walling along Burley Road could be incorporated as part of a new development. Together with new planting, retained vegetation would contribute to the well wooded character of the locality and help to integrate new development into the landscape.

Object

Representation ID: 29695

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Barton Wilmore

Housing Distribution - Bradford City Centre & Menston

The Council’s approach to distribution in the draft Local Plan is considered to be flawed for a number of reasons. Firstly, the decision to uplift the target from 3,500 (4,000 in the Core Strategy Review) to 7,000 is a mistake given Bradford’s historic deliverability issues in the City Centre.

Not only that, it is at odds with the likely shift in living expectations following the Covid-19 pandemic, which is likely to see an even greater desire for more rural living, in areas close to countryside and green space.

The extent of housing in the City Centre should be retained at 3,500 as per the adopted Core Strategy and the residual 3,500 spread out around the District.

In terms of Menston, which is one of six Local Growth Centres, it has been apportioned the 2nd lowest distribution. Menston is closely related to Guiseley, which the two settlements almost merging into one, and it is therefore more sustainable than settlements such as Burley-in-Wharfedale and should be apportioned a similar level of new homes.