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

Object

Representation ID: 29697

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Barton Wilmore

Persimmon objects to the exclusion of site CO/011 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 it is not adjacent to the urban area, however , in reality that clearly isn’t case.

The reference to the site being detached from the urban area is somewhat of a misleading statement as that is clearly not the reality on the ground, as it adjoins Cottingley Village Primary School. However, due to a quirk of the planning system, it falls on the wrong side of a line drawn on a plan (settlement boundary) and for the purposes of planning is deemed to be detached from the urban area. It would be entirely logical for the school to be incorporated into the settlement boundary and had this been the case, the only reason for rejecting the site would disappear.

Persimmon have provided technical documentation (assessments re highways, landscape, ecology and flood risk) which demonstrates that the site is available, achievable and suitable and represents a deliverable housing site.

The Sustainability Appraisal (SA) which has been undertaken for the site demonstrates it scores well and only has a negative (red) assessment on a single question – 3 (land & buildings) on the basis that the development would result in the loss of a greenfield site. This is exactly the same as the site which the Council
are proposing to allocate – CO/002. Interestingly, site CO/002 has 2 red assessments, and as such could be assumed to be the worse performing of the two sites.

Object

Representation ID: 29698

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Barton Wilmore

Objection to the rejection of CO/011

Whilst we consider that site CO/011 is more appropriate than site CO/002 and should replace it is the only allocation in the village, we note that it is identified as an ‘alternative’ site. If the Council progress the Local Plan as proposed, we advise that site CO/011, which is only rejected because it does not adjoin the settlement boundary, is allocated as safeguarded land. The Council will need reserve land over the plan period as inevitably, not all allocated sites will come forward and having
safeguarded sites will help maintain a 5YHLS over the plan period.

Given that the Council are planning for a shortfall of 9,000 homes across the plan period as they are not accounting for the 35% uplift as required by the standard method, we strongly suspect that the Council will need additional sites to meet this significant shortfall. As the site is identified as an ‘alternative’, we anticipate it will be allocated in this event.

Object

Representation ID: 29699

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Barton Wilmore

Housing Distribution - Cottingley

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.

In terms of Cottingley, it is closely linked to Bingley and is a short distance away from this Principal Town. We would question why it has been allocated fewer homes than Haworth as an example, which is an isolated settlement , which is poorly related to Keighley, the nearest Principal Town.

Cottingley is well served by local services in its own right an can accommodate additional growth over and above what is being proposed.

Object

Representation ID: 30068

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Housing Distribution - Silsden

The general inconsistencies of the approach to the District Wide Housing Requirement adopted by CBMDC are clearly apparent with reference to land at Bolton Road, considered in further detail below.

This has reduced from an apportionment to Silsden of 1,200 as set out within the adopted Core Strategy (2017), and also a reduction from 800 proposed in the Core Strategy Partial Review in 2019. It is important to note that the reduction from that in Core Strategy Partial Review to that in the draft Local Plan has occurred despite the overall district wide housing requirement not changing between the two documents. This reduction seems inexplicable when there is land (site SI/004) within the defined settlement boundary of Silsden that CBMDC has identified as being unconstrained and capable of accommodating in excess of a further 1141 dwellings, yet has not chosen to allocate.

Notwithstanding the need to increase the housing requirement overall, a reduction in the housing apportionment is not justified in respect of Silsden where there is non-Green Belt land which is suitable and available for development, and is clearly identified as such within the Council’s own evidence base.

Object

Representation ID: 30076

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Rejection of the full site SI/004

While the allocation of site SI2/H is supported it is important to recognise that this site forms part of a wider site in Persimmon’s control and it is inexplicable that the wider site that is located within the defined urban area of Silsden (and in particular the remainder of site SI/004 which has been identified within the Council’s own evidence based as being unconstrained) has not been also been identified as a preferred allocation.

As discussed throughout these representations, the most appropriate approach is the allocation of the full extent of the land within Persimmon’s control, as this would allow for the area to be comprehensively master planned for the long term reflecting the constraints and opportunities afforded by this site, for wider benefits to be delivered, and for a new eastern defensible eastern settlement boundary to this part of Silsden to be created.

In summary, Site SI2/H should be extended to accommodate the full extent of the 12.27 hectares of land within Persimmon’s control as shown on Figure 1.1 and Appendix 1 and allocated for 260 homes.

It is considered that development of the wider land holding (comprising the entirety of SLA site SI/004) would provide a suitable, available and deliverable extension of site SI2/H for allocation within the Local Plan.

The entirety of site SI/004 is located outside the Green Belt and within the settlement boundary for Silsden, it is identified by the Council’s own evidence base as being wholly unconstrained. The site should therefore be allocated in full within the next iteration of
the plan.

Object

Representation ID: 30216

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Rejected Site SI/003

Persimmon’s land holding also includes part of Site SI/003: Brownbank Lane.
We note that the more detailed proformas and analysis which sit behind the conclusions reached for rejected sites as set out within the Site Assessment Update Report have not been made available for comment as part of this consultation on the evidence and despite our requests these have not been made available. Persimmon reserve the right to view and comment on this more detailed information when this is made available.

In summary, it has been demonstrated with reference to the emerging site masterplan, and technical consideration of matters of access, landscape and heritage, that the Council’s conclusions regarding the unsuitability of parts of SI/003 for allocation are unfounded.

SEE FULL REP FOR ASSESSMENT OF HOW TECHNICAL ISSUES AND CONSTRAINTS TO BE ADDRESSED.
A comprehensive masterplan has been prepared which demonstrates how non-Green Belt land within the settlement limits of Silsden can be sensitively developed to deliver 260 new homes, alongside additional wider benefits including the ability to facilitate an eastern relief road should this be deemed necessary, and the creation of a permanent and defensible Green Belt boundary.

Comment

Representation ID: 30217

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Rejected Site SI/006

The only other non-Green Belt site (apart from site SI/003) to be rejected for allocation is site SI/006. This is a former safeguarded site. The reasons for non-allocation include access; protected hedges; landscape impacts; and flood risk (part).
We are aware that access to this site is severely constrained and that there is limited prospect of upgrading the access, which would require third party land. It is therefore not considered that this site comprises a comparable or more favourable site over SI003 and/or SI/004. This site has not been subject to assessment in the SA, suggesting that CBMDC do not consider this site as a potential allocation.