LP0221, Land at Spring Head, Northowram

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Below you will find our suggested comments to help you through the commenting process.  Please remember that these are our suggested comments and we would advise adding your own thoughts and suggestions too.  

The Local Plan is divided into sections. We hope that you find the information below helpful 

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In this first section Calderdale Council asks if you believe the Local Plan is Legally Compliant. 

Legal compliance

Do you consider the plan to be Legally Compliant?

Our suggested comment is YES

But if you believe that the Local Plan is not legally compliant you should give details in the box provided

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In this second section Calderdale Council asks if you believe the Local Plan is Sound

Soundness

Do you consider the plan to be Sound? 

Our suggested comment is NO

The comments below will provide details why SNLPF believe the plan is not sound - you can if you wish use these comments

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Below are my comments as to why I consider the Local Plan is unsound

GREENBELT

The Greenbelt assessment is incorrect because it states that the site does not fulfil Purpose III of the five purposes of greenbelt (“To assist in safeguarding the countryside from encroachment).

The land is tranquil and the Site Assessment correctly identifies that it has both a Wildlife and Ecological Designation therefore I submit that it clearly fulfils Purpose III.

The Greenbelt assessment is incorrect because it states that the site does not fulfil Purpose IV of the five purposes of greenbelt [“To preserve the setting and Character of Historic Towns].

If the site is removed from Greenbelt the inevitable development traffic passing through the narrow streets of the nearby Conservation Area, would have a negative impact on the significance and setting of the Conservation Area and listed buildings within it. (See also my comments below under Highways Development Management and Conservation/Heritage).

NPPF para 83 requires that “exceptional circumstances” must be demonstrated before land is taken out of the Greenbelt. No such circumstances have been stated therefore the proposal is non-compliant.

NPPF para 84 requires a review of Greenbelt boundaries to take account of the need to promote sustainable development. Distant as it is from access to normal services this site is NOT sustainable and therefore the proposal is non-compliant.

Highways Development Management

Highways DM have stated that Development traffic would use either Hough or Towngate to access the A58 or A6036.

I disagree with the view of Highways DM that the Hough/A58 junction is in any way suitable to allow HGV access/egress to this site.

Hough is a very steep, narrow, cobbled street with a sharp, blind bend. Cars parked near the A58 junction make it especially narrow.

Towngate is a narrow street with resident’s cars necessarily parked on both sides, frequently leading to traffic congestion. It also has a pinch point and speed bumps to restrict traffic flow.

Hough and Towngate are signed as being “unsuitable for HGV’s and both streets pass through the Northowram Conservation Area which would inevitably suffer through increased volumes of development and residential traffic.

Highways DM have only considered the increased amount of residential traffic on Windmill Drive, they have failed to give any consideration to its suitability to accommodate development traffic, for which it is totally unsuitable.

Conservation/Ecology

The site contains two types of UK BAP Priority Habitats i.e. Deciduous Woodland and Lowland Meadow. The woodland is primarily Oak, but other deciduous species exist. The habitats are spread consistently across the entire site so it is erroneous and misleading to suggest that they are restricted to discreet pockets within the site or at the site margins. The assessment calls for a 10m buffer zone around the site boundary and, importantly, around the woodland within the site. However, this has not been reflected in the proposed developable area shown on the site allocation, which only allows for a buffer zone around the site boundary and ignores large areas of deciduous woodland within the site.

The site assessment calls for a Protected Species Report but, given that the site is Greenbelt, the site should not be allocated until such a report has been produced and a full understanding is reached on the impact of development on any species present.

The site is locally important as a tranquil area used for walking and gentle recreation. It is criss-crossed by several informal footpaths and there is a Public Right of Way across the northern end of the site. Because the site is tranquil, contains the two BAP Priority Habitats and is easily accessible, it is an important Green Infrastructure Asset for Northowram, something that the Local Plan claims to promote and preserve through its various GI policies but does nothing to support with this proposed allocation.

Conservation/Heritage

Conservation (Heritage) comments have failed to consider the full impact of the proposed allocation in the context of Highways DM proposals. Highways DM propose that development traffic will use Towngate and Hough to access/egress the site. Both streets pass through the Northowram Conservation Area. Towngate is a narrow village street, already suffering congestion from cars and along which are several listed buildings fronting the street. Hough is a very steep, in places narrow, cobbled street. Both Towngate and Hough are signed as being unsuitable for HGV’s which would be ignored if development traffic has to pass along it, to the possible detriment to Heritage Assets.

Accessibility

The journey times given in the Site Assessment are significantly underestimated and ignore the less mobile members of society.

For example, the journey time to town centre is shown as “less than 15mins”. Using the WY Metro ‘Journey Planner’ and for the elderly, disabled or young families walking slowly the time is 40mins and involves a walking journey of 800m to the nearest frequent bus stop.

Similarly, the Journey time to GP is shown as “less than 15mins”. As there is no suitable bus route to the nearest GP surgery this journey must be made on foot. For the elderly, disabled or young families walking slowly this will take 24mins and involve a walking distance of 1.2km. Clearly these accessibility times ignore the less mobile members of society and, rather than promoting the use of Sustainable transport, will force more people to use car journeys to and from these increasingly inaccessible sites. 

Sustainability

The Sustainability Assessment only scores 4 ‘positive’ outcomes out of 17 but two of these positive results are based on the seriously flawed Accessibility scores so must be disregarded (see my Accessibility comments above).

How can the site be regarded as sustainable when it has only 2 positive scores out of a possible 17?

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In this third section Calderdale Council asks if the Local Plan complies with the Duty to Co-operate

Duty to Co-operate

Do you consider that the plan complies with the Duty to Co-operate?

Our suggested comment is YES

But if you feel that the Local Plan does not comply with the Duty to Co-operate, you should give details in the box provided

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Modifications

In this section, Calderdale Council asks you to suggest the modifications you believe necessary to make the Local Plan sound. 

You may use the suggested comment below but you can also add your own comments

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This site should be removed from the Local Plan

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Examination

In this final section, Calderdale Council asks if you would like to take part in the Oral part of the Examination.  If you have provided suggested modifications to make the Local Plan sound, you may wish to take part. 

If you do wish to take part, you should answer YES to the Oral Examination question.  You should also give your reasons for attending

Please note that the examination is open to the public and you can attend as a spectator only. 

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Commenting on site LP0221 is now complete

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If you wish to comment on another site please return to our Proposed Sites Page and select that site to see our suggested comments.