LP0782 Land off, Cockhill Lane, Shelf

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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 Site Assessment acknowledges that this site performs strongly against the five purposes of Greenbelt, fulfilling four of the five purposes. However, due to its proximity to the listed buildings at 3-7 Cock Hill, it also fulfils Purpose IV– “To preserve the setting and special character of historic towns”. As a site that fulfils ALL FIVE purposes, this site should not be removed from the Greenbelt.

NPPF para 83 requires that ‘exceptional circumstances’ are demonstrated for land to be taken out of the Greenbelt but no such circumstances have been put forward. It is difficult to see how there may be exceptional circumstances in favour of development when there are dozens of small sites in urban areas that have been omitted simply on the grounds of their plot size.

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

Access to the site will be from Cock Hill Lane, either from the north via High Cross Lane or the south via West Street/Shelf Hall Lane. From either direction, but particularly from the south, Cock Hill Lane is a narrow country lane between dry stone walls, with NO FOOTWAY for its entire length except a short section on one side near the junction with West Street. The lane is narrow, steep in places with blind bends at the narrowest, steepest parts. On the steep, blind bends it is reduced to single track due to necessarily parked cars. It has a 60mph speed limit (reduced to 20mph only near West Street junction) and widely spaced street lighting consistent with non-urban lighting. It is totally unsuitable for increased volumes of traffic sharing space with pedestrians. Pedestrians accessing the nearest junior school or public bus stop would have to share Cock Hill Lane with the fast-moving traffic but without the benefit of a footway for their safe passage.

Linking this site to LP1543 (as seems necessary according to Highways DM’s site assessment) will give access to 495 additional houses onto Cock Hill Lane.

In their assessment of LP1543, Highways DM have stated – “Cock Hill Lane could provide a link through to the adjacent site [LP1543] but couldn’t accommodate traffic from the whole site – 330 dwellings. This is because of the impact on West Street and Cross Lane to the south.”

Strangely Highways DM have failed to raise similar comments against LP0782 which would also be accessed via Cockhill Lane and would increase the number of dwellings to 495.

Highways DM have stated (in separate assessments) that the access points on both sites would not be able to cope with the increased traffic, yet they seem unwilling or unable to admit that development of these sites is unsustainable.

There are some common features in the assessments of LP1543 and 0782 (either singly or linked together). Most notably that proposals for site access are very often unrealistic or very difficult, and then that the cumulative impact on the local highway network has either not been assessed, or where a judgement about the capacity of the LHN has been made it is unrealistic when considering such factors as the narrowness of individual roads, absence of pavements, difficult junctions etc.

Conservation (Heritage)

Listed Buildings at 3-7 Cockhill Lane are adjacent to the site and would be severely affected by development and the site access. Because the site is fairly flat next to Cock Hill Lane, a simple buffer strip as proposed is not enough to reduce the impact on the listed buildings. Demolition of existing dry-stone walls to create an access and ANY building on this site will have a severe impact on the setting of the listed buildings.

Conservation (Ecology)

The site is farmland, currently used for grazing and hay production. It supports a wide variety of wildlife but more importantly it supports a priority species listed in the Calderdale Biodiversity Action Plan (BAP) [2003-2010, awaiting update].

The site assessment calls for mitigation in the form of the creation of areas of unimproved, species rich grassland but the Plan does not say how and where this will be created in the local area. You cannot simply expect wildlife to accommodate development by moving to another field when their habitat is destroyed. Why try to re-create (perhaps unsuccessfully) habitat elsewhere when we have a perfectly acceptable one on this site that has existed for generations.

Accessibility

I agree with the ‘Distance to Bus Stop’ of between 400m and 2km. However, I disagree with several of the RAG scorings for journey times, notably ‘Journey time to Town Centre’ which is shown as “between 15 and 30mins”.

Referring to the WYMETRO ‘Journey Planner’ software, this gives a total journey time to town centre of 40-41mins at a.m. peak time, Mon to Fri. far greater than the ‘between 15 and 30mins’ stated in the Accessibility RAG scores. The total journey time increases to 42-46mins during a.m. off-peak when you might expect elderly or non-working people to travel.

Similarly, the ‘Distance to Primary School’ RAG scoring of ‘less than 15mins’ is incorrect. The nearest Primary School is Shelf J&I. There are no public bus services from the site to the school and the shortest route will be via Cockhill Lane/Shelf Hall Lane. Again, using the WYMETRO software the journey time is 25mins, not the “less than 15 mins” stated in the Accessibility RAG scoring.

However, what the Accessibility RAG scoring has also failed to take account of is that Cockhill Lane is a narrow country lane between dry stone walls, with NO FOOTWAY for its entire length except a short section on one side near the junction with West Street. The lane is narrow, steep in places with blind bends at the narrowest, steepest parts. On the steep, blind bends it is reduced to single track due to necessarily parked cars. It has a 60mph speed limit and widely spaced street lighting consistent with non-urban lighting. It is totally unsuitable for increased volumes of traffic sharing space with pedestrians, most notably elderly, disabled or school children.

Putting aside journey times for the moment, forcing pedestrians to use Cockhill Lane as an access route to school and bus stops is utterly irresponsible and will have disastrous consequences for their safety and is ultimately UNSUSTAINABLE.

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?

Open space

When considering the loss of open space, it is seriously flawed to consider that loss of the site will be felt only by residents adjacent to the site. Of course, there may be other open space within the catchment of this site to act as compensation. What the assessment fails to realise is that the site itself forms part of the catchment of other areas of Shelf, it is those areas that are losing access to open space. Can the council not see that, as the settlement boundary expands then open space grows ever more distant from existing housing. 

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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 LP0782 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.