LP1543 Land North and North West of, Wade House Road
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
In this first section Calderdale Council asks if you believe the Local Plan is Legally Compliant.
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
In this second section Calderdale Council asks if you believe the Local Plan is Sound
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
Below are my comments as to why I consider the Local Plan is unsound
The Site Assessment acknowledges that this site performs strongly against the five purposes of Greenbelt, fulfilling three of the five purposes. I agree that it does not fulfil Purpose IV but a sense check for Purpose 1 shows that the site is identical in nature and boundary treatment to LP0782, to which it is linked. As LP0782 fulfils Purpose I then this site must also fulfil Purpose I. As a site that fulfils FOUR OF THE 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
Highways DM acknowledge that there is only one possible point of access to the site i.e. on Wade House Rd (A6036) and this has restricted visibility, this statement greatly understates the situation. In fact, the access is a narrow gap between terraced houses that is little more than two field gates wide as a simple site visit will show.
Highways DM allude to a possible access point in the North but there are no details given so it is not possible to make a reasoned comment on it. It seems that this access would be onto South lane which again Highways DM have said is not capable of taking the volume of traffic generated by 330 houses. Notwithstanding the fact that proposed site LP0782 (165 houses) would also be linked, adding further traffic volume.
Linking LP1543 and LP0782 has the potential for 495 houses and 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.
Accessing the site through LP0782 will put increased traffic onto Cockhill Lane. This 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 the various classes of pedestrians. Pedestrians accessing the nearest junior school or public bus stop would have to use Cockhill Lane as well as the fast-moving traffic but without the benefit of a footway for their safe passage.
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.
Approximately 70% of the site consists of Wildlife Habitat Network/ Wildlife Corridor and is the last link between Wood Fall/North Wood to the south and the wider greenbelt to the north. It is therefore an important Green Infrastructure Asset for Shelf, something that the Local Plan claims to promote through its various GI policies but shows little evidence of support for on the ground.
Development will destroy all but a very narrow strip of the corridor a matter of a few meters wide. However, this strip is already closed off at the north end by residential development, thus an ‘island’ of WHN surrounded entirely by development, would be created. Whilst Conservation (Ecology) have suggested some small mitigation measures they are woefully inadequate given the extent of the proposed loss. The remaining strip of WHN will be so compromised by recreational disturbance from this development that it will cease to operate as an effective area for wildlife or biodiversity.
The Wildlife Corridor/WHN in and around Shelf has become fragmented and development proposals in the Local Plan are set to increase that fragmentation. Conservation have failed to show whether the cumulative impact of this loss has been assessed or show any results of such an assessment.
The site consists of semi-improved grassland currently used for grazing and hay production. The site assessment calls for mitigation in the form of the creation of areas of unimproved, species rich grassland and hedgerows 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.
The site assessment suggests that an Ornithological Survey may be required and that the “development should ensure the provision of locally native species rich unimproved grassland, restoring gaps in the Wildlife Habitat Network”. This falls far short of what is required, I suggest that a full species survey is required to identify the range of flora and fauna present in this area of WHN.
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, most notably ‘Journey time to Town Centre’ which is shown as “less than 15mins”.
Referring to the WYMETRO ‘Journey Planner’ software this gives a total journey time to town centre of 40mins at a.m. peak time Mon to Fri. far greater than the ‘less than 15mins’ journey stated in the Accessibility RAG scores. The total journey time increases to 41mins 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. Although there are no public bus services from the site to the school, the shortest route will still pass the nearest bus stop on Wade House Road. The school is a further 500m from the bus stop giving a walking distance of up to 2.5km. A more realistic journey time will be about 40mins.
Notwithstanding the comments above, how can journey times or distances stated on the Site Assessment be relied upon when Highways DM have not determined where and how many points of access there will be to the site. Location of access points will obviously make a great deal of difference when deciding if it is time efficient OR EVEN SAFE to walk to school or a bus stop.
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?
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.
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
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
This site should be removed from the Local Plan
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.
Commenting on site LP1543 is now complete
If you wish to comment on another site please return to our Proposed Sites Page and select that site to see our suggested comments.