Highstone Homes Site LP1109 Land South of Northedge Lane

Response to

Calderdale MBC Local Plan

Publication Draft 2018

Highstone Homes

Site LP1109 Land south of Northedge Lane, Hipperholme

September 2018

Contents

1. Introduction

2. General Policies in the Calderdale Publication Draft Local Plan

3. Rejected Site – LP1109

Appendices 1. Aerial Images of Questionable SD7 Housing Sites 2. Landscape Statement / Green Belt analysis – Pegasus April 2018 3. Highway Site Appraisal – Paragon Highways May 2018

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Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

1.0 Introduction

1.1 This statement has been prepared to respond to the Calderdale MBC Local Plan Publication Draft having regard to whether the Draft Plan is sound when considered against the four tests of soundness as set out in the National Planning Policy Framework (the “Framework”). Plans are ‘sound’ if they are:

- Positively Prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development; - Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence; - Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and - Consistent with national policy – enabling the delivery of sustainable development in accordance with policies in this Framework.

1.2 Johnson Mowat make the following comments in relation to a number of Draft Policies in the Publication Draft and to the rejection of site LP1109, Northedge Lane, Hipperholme, Brighouse on behalf of Highstone Homes, who have in interest in the site.

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Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

2.0 General Policies in Calderdale Publication Draft Local Plan

2.1 A brief summary of our comments are as follows:

- The Housing Requirement (Policy SD3) is not sound. The housing requirement should be a minimum target. It is based on the MHCLG Standard Methodology which may change at the end of September 2018. The housing requirement does not take account of the Council’s own evidence (OAN Review) and will fail to meet the baseline economic growth forecast and the forecast job growth identified in the Local Plan. In other words, it will harm economic growth and put undue upward pressure on house prices. Solution: Increase the housing requirement and identify additional land for housing.

- The distribution of growth is not adequately explained or justified within the Local Plan text.

- The Local Plan is too reliant on the delivery of two Garden Suburbs to deliver the housing requirement. We will produce evidence as to why these sites will not deliver in full over the life of the plan Solution: Identify additional land for housing.

- We question the deliverability of a number of identified housing sites in Policy SD7 on a number of grounds – density; location in relation to existing settlement; inadequate access; existing green space. A number of the smaller sites should not be included as housing allocations, and could be dealt with as windfall should they come forward. Solution: Remove non-deliverable sites. Avoid windfall duplication. Identify additional land for housing.

- Insufficient sites have been identified (regardless of our consideration that the housing requirement is too low) in order to provide a buffer in the event of existing commitments and allocations not coming forward as envisaged. Solution: Identify additional land for housing.

- Policy HW2 (Health Impact Assessment) is not justified. Sites selected / or allocations should be in sustainable locations. If so, there is no need for Health Impact Assessments.

- Policy IM5 (Ensuring Development Supports Sustainable Travel) requires further detail in relation to what constitutes ‘significant amounts of movement’.

- Policy HS5 (Self Build and Custom Housebuilding). We object to the unjustified requirement of 5% of sites above 100 dwellings requiring self-build and custom build plots.

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Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

Policy SD3 – Housing requirement

2.2 We object to the 840 dwelling per annum (2018/19 – 2032/33) housing requirement set out in Policy SD3, which is based on the MHCLG standard methodology, published in September 2017. We do not consider the housing requirement in Policy SD3 to be sound, as it fails the positively prepared, justified and effective tests on the Framework.

2.3 The previous Initial Draft Local Plan proposed a housing requirement of 1,125 dwellings, which is significantly higher than the proposed 840 per annum requirement in the Publication Draft. It is disappointing that the OAN Review May 2018 (Turley / Edge Analytics) that was commissioned by the Council and forms part of the Evidence Base, has not been taken into account, which concludes that in order to meet the baseline economic forecast, the OAN for Calderdale is 1,000 dpa (2016 – 2035). In order to meet the required job growth identified in the Local Plan 1,129 homes per annum will be required.

2.4 The OAN Review evidences that the requirement is considerably higher than that proposed in the Local Plan. It is clear that the Local Plan housing requirement falls short of the evidence base. Johnson Mowat are aware of analysis being undertaken by a consortium of developers in relation to the OAN information, which deals in detail with the evidence base and the shortcomings of the Local Plan chosen housing requirement.

2.5 The housing requirement in the Draft Local Plan is based on the MHCLG standard housing methodology published in September 2017. The Council should be minded that the figure may change following the publication of the household projections in September 2018, after which the methodology may be adjusted, resulting in a different requirement. Furthermore, aside from the fact that the MHCLG methodology may change, the methodology figure should be considered as a minimum starting point. This is acknowledged in the Council’s own evidence in the OAN Review.

2.6 Section 3 of the Housing Technical Paper informs that the housing requirement was chosen by Elected Members at a Cabinet meeting in February 2018, with Members opting for Option B which was the standard housing methodology excluding an uplift for undersupply, employment growth and flexibility of choice of sites. The Housing Technical Paper makes reference to the Turley / Edge Analytics OAN Review, concluding that Members resolved to plan to meet housing need calculated using the standard methodology. It appears that the Local Plan is politically driven, rather than based on appropriate, up to date evidence. There is no reference ______

Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

in the Housing Technical Paper about the MHCLG standard methodology being a minimum starting point. Consideration does not appear to have been given to attempting to justify a higher requirement, even though doing so would align with the Council’s spatial vision and objectives of aligning economic / jobs growth in the borough with the appropriate provision of housing.

2.7 In order to make Policy SD3 sound, it is recommended that the Council takes into consideration the available and up to date evidence contained in the OAN Review, which supports the Northern Powerhouse agenda, and the Leeds City Regional Local Enterprise Partnership, and aligns the housing requirement with the economic growth aspirations of the Borough. The housing requirement in Policy SD3 should be increased.

2.8 The consequences of increasing the housing requirement are obvious, in that the Council will be required to identify additional land for housing. Should the housing requirement be increased to 1,000 dpa for example, land for a further 2,400 dwellings will be required over the plan period (based on information contained in Table 6 of the Housing Technical Paper).

Distribution of Growth (Section 6.2)

2.9 Whilst there is some text relating to the distribution of the housing requirement, there is no specific policy. While Table 6.10 identifies the quantum of housing via allocations in each area, there is no justification regarding the distribution.

2.10 The text refers to the focus of development in Halifax and the historic distribution of nearly 50% in Halifax in the Core Strategy preferred options, and 20% to Brighouse, as well as identifying environmental constraints for continuing this focus (topography, flooding, SPA and SAC’s). The text lacks detail in terms of what the proposed solution is to distributing growth. The distribution of housing in Table 6.10 results in more development in Brighouse than Halifax (49% of new allocations are in Brighouse, compared with 30% in Halifax, and overall – including planning permissions and windfalls, Brighouse has 39% of the growth, and Halifax 33.6%). Information is lacking, linking the identified allocations with the spatial distribution. Further justification and explanation of the Council’s approach is required.

2.11 We welcome the Council’s acknowledgment that “identifying sufficient sites to meet the housing requirement in the context of the significant environmental constraints and supply of potential sites has been challenging.” Further, we welcome the acknowledgment that “there are now relatively few deliverable and viable previously developed sites in sustainable locations that are

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Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

capable of coming forward without public sector intervention.” This statement however doesn’t seem to align with the amount of small brownfield sites that are identified in the Local Plan as allocations, and contribute to the housing requirement. We have reservations on a number of sites that form part of the allocations. Whilst the text at paragraph 6.48 states that “there are opportunities for the reuse and redevelopment of brownfield sites within the existing Urban Area, contribution to the proportion of development on previously developed land” we consider that the Council has included too many undeliverable sites (both brownfield and greenfield) within the urban area, and hence the Local Plan fails to identify sufficient deliverable sites. This is referred to in more detail later in this response.

Policy SD7 – Allocated Housing Sites

Garden Suburbs:

2.12 The Local Plan is heavily reliant on the delivery of two garden suburbs, both of which lie on the eastern edge of Brighouse and fairly close to one another, with a combined anticipated dwelling capacity of 3,255 dwellings:

- LP1451 – Land between Bradley Wood and Woodhouse Lane, Rastrick, Brighouse – 1,257 dwellings

- LP1463 – Land between Highmoor Lane and Bradford Road, Brighouse - 1,998 dwellings

2.13 The Key Diagram doesn’t reference the Garden suburbs, which is considered an error. The Key Diagram should be updated to reflect to the Local Plan approach. Further to the above comments relating to the lack of justification or reasoning behind the distribution of growth, there is also a lack of detail relating to the context behind the Garden Suburb approach. There is little explanation as to why these sites have been chosen (nor is there any information in the Housing Technical Paper). Why has this approach been taken for two Garden Suburbs. What were the alternatives?

2.14 We question the approach taken and cannot understand what consideration has been given to reasonable alternative approaches. We question the deliverability of the two ‘garden suburbs’ (See below) and consider that the approach is neither justified nor effective in delivering the

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Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

housing requirement over the plan period. The approach places too much emphasis on the delivery of two large sites, with no contingency plan should these two sites fail to deliver.

2.15 The Housing Technical Paper includes a trajectory of delivery, which indicates both garden suburb sites will commence delivery in year 7 (2024/25) at a continual annual rate of 140 dwellings per annum for LP1451 and 222 dwellings per annum for LP1463.

2.16 We cast doubt over the commencement of delivery as well as the annual delivery rates, which will require numerous outlets on each site.

2.17 Our estimations are, that in order to deliver 222 dpa, there would realistically be 5 outlets required, and to deliver 140 dpa 3 outlets would be required. This equates to 8 outlets over the two garden suburbs. In the first instance, there are insufficient access points on site LP1463 to achieve 5 outlets developing at the same time and there is not enough competition on the market in this locality to sustain the number of outlets required to deliver the numbers envisaged year on year on just two sites. The housing market is not strong enough to deliver at this rate.

2.18 Our opinion of the over optimistic delivery rates is supported by the Nathaniel Lichfield Start to Finish (November 2016) report which reveals that the average annual build rate for schemes above 2,000 dwellings is circa 161 dwellings. This is a National average where the average reflects a rate of delivery above that typical of this District. The average annual build rate for 1,500 – 1,999 is circa 130 dpa, and for sites between 1,000 and 1,999 it is circa 110 dpa. These figures are significantly lower than the 222 and 140 dpa envisaged at the two Garden Suburb sites.

2.19 The Nathaniel Lichfield report states that:

“Large sites are typically not quick to deliver, in the absence of a live planning application, they are, on average, unlikely to be contributing to five year housing land supply calculations.” (NLP Start to Finish, pg 8)

2.20 On planning approval periods, the greater the number of homes on a site, the longer the planning approval period becomes. There is a big step-up in time for sites of in-excess of 500 units.

2.21 Based on the Nathaniel Lichfield build rates for the two proposed Garden Suburbs the shortfall of delivery compared with the Council’s assumed delivery is 267 dwellings and 828 ______

Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

dwellings, resulting in a combined shortfall of 1,095 dwellings against the Council’s anticipated delivery over the plan period. This is based on the two Garden Suburbs commencing delivery in Year 7, which as stated above, is considered to be unrealistic. The shortfall will obviously increase should commencement be delayed beyond Year 7.

Case Study: East Leeds Extension

2.22 In questioning the anticipated delivery rates of the two Garden Suburbs within the Local Plan, a comparable large strategic site in the north to draw upon is the East Leeds Extension (ELE). This was allocated in 2001, and in 2011 the site was released (Phase 3 sites released). Therefore there have been no barriers to delivery since 2011. Since 2011, no planning permissions have yet been granted. While 1 application has been submitted (which equates to 1/3 of the site) this hasn’t yet been approved, with delays relating to the S106 agreement.

2.23 Applications on the remaining 2/3 of the site have not yet been submitted, and are likely to be submitted in 2019. It is envisaged that should approval be granted in 2019, delivery of housing could commence two years on, in 2021 (to account for legal agreements, land purchase, etc) which is some 10 years on from the release of the site in 2011.

2.24 It is likely that the delivery rates across the three ELE quadrants, with multiple outlets will not achieve the 360 dpa that is anticipated on the two Brighouse Garden Suburb sites.

2.25 The three ELE quadrants, which are each in excess of 1,000 dwellings, are unlikely to achieve more than 300 dpa combined. ELE has three sites, compared with the two in Brighouse, and is undoubtedly in a better market location, and still will not deliver as many dwellings per annum as anticipated on the two Brighouse Sites. Based on this comparable strategic site, we cast serious doubt on the anticipated delivery of the two Garden Suburbs in the Local Plan.

2.26 The Local Plan is too heavily reliant on the delivery of the two Garden Suburbs in order to meet the housing requirement. It is considered these sites will not deliver as anticipated. The Local Plan needs to identify additional suitable, available sites to deliver in the early years of the plan period prior to the Garden Suburbs commencing delivery. Not only are we concerned that the housing requirement is too low, we have major concerns with the Council’s over reliance of the two Garden Suburbs.

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Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

Concerns with other identified Allocated Housing Sites.

2.27 Based on the detailed site information contained in Appendix 1 of the Publication Draft Local Plan and the Housing Technical Paper, we have a number of concerns relating to a number of sites that contribute to meeting the housing requirement within the Plan Period.

2.28 In the first instance, it would be helpful if the Local Plan could include a composite set of maps identifying the allocations in the Local Plan. It appears that this is only available electronically as an interactive map. It would be helpful for a set of maps that cover the district to be made available as part of the Publication Draft Local Plan documents. The Maps within Appendix 1 of the Publication Draft Local Plan (Maps 1.2 – 1.10) are not particularly clear, as the types of sites (housing, employment, mixed use) are not differentiated and it is difficult to appreciate the existing settlement areas, given the shading on the maps. There were a set of maps that went to the 11th June 2018 Cabinet meeting prior to the publication of the Calderdale Local Plan, however these do not appear to be available as part of the Publication Draft consultation process.

2.29 We have concerns relating to a number of sites, for varying reasons. These concerns relate to:

- The inclusion of a number of quarry sites; - Sites identified in isolated locations, remote and not well related to adjacent settlements; - The density assumptions of some sites are overly optimistic; - Access to some sites are unsuitable; and - We question the deliverability of some sites based on poor market areas.

2.30 Whilst a number of the housing sites identified in Policy SD7 may well deliver, it would be more appropriate for some sites to be included as windfalls, rather than as allocations. This applies to a number of small sites and previously developed sites, where their delivery is questionable.

Quarry sites 2.31 There are six quarry sites included in the Council’s housing allocations with a total indicative dwelling capacity of 474 dwellings (Sites 0945, 0950, 1032, 1053, 1077, and 1093). We cast doubt over the deliverability of these quarry sites. There are a number of added costs and

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Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

development hurdles associated with developing quarry sites which bring into doubt the viability and deliverability of former quarry sites. We identify the following issues.

- The remediation of former quarry sites is a costly and lengthy process and capital lenders will typically need to be satisfied that developers are making a greater allowance for developer profit, in order to account for the associated risks. - There is a greater potential for increased abnormal costs, e.g. foundation costs given that the land is generally bare hard rock; stabilising walls to account for gradients; considerable backfill required; ground contamination costs; risk of unidentified mine shafts that could affect the structural stability of development. - Gradient issues for access roads. - Given that quarries are below the ground level, backfill is required and there can be issues relating to light due to shading of the quarry sides. - Quarries generally lie under the water level, therefore requiring sewage and water to be pumped out of development schemes. - Landscaping can be an issue as the lack of soil makes it difficult to establish and grow adequate landscaping;

2.32 The below table provides examples of proposed housing sites identified in Policy SD7 where we question the suitability and deliverability of the sites based on our concerns identified above. We have undertaken a selective assessment of identified sites, and we are in no doubt there are further questionable sites. Indeed we are aware of other assessments of the Allocated Housing Sites having been undertaken that also raise concerns with the deliverability of sites. In total we identify 19 sites, including the 6 quarry sites with a cumulative capacity of 803 dwellings. Aerial images of the below list of questionable sites is contained at Appendix 1 to this document.

Site Ref / Address Indicative Comments Capacity (dwellings) LP1053 68 This site is a quarry and is not well related to the settlement edge, it is Squire Hill Quarry, surrounded by woodland, beyond which lies industrial land. It is not Brighouse close to existing residential areas and would be an isolated remote housing site.

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Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

The Housing Technical Paper identifies a suggested delivery in year 12 (2029). There is a ‘part unknown’ comment against the availability of the site, and comments refer to the owner of the land confirming its availability for housing, however the site requires restoration work due to previous quarrying. We recommend deletion of this site. LP1054 32 This site lies immediately adjacent to LP1053 Squire Hill Quarry. We Land off, Brookfoot have similar concerns to the above site – it is in an industrial area, Lane, Brighouse remote from residential development, with a resultant combined 100 dwelling unsustainable development. There are identified constraints (noise from Brookfoot Works / Road Traffic. The Housing Technical Paper identifies a suggested delivery in year 10 (2027), with comments suggesting it is likely to come forward together with Squire Hill Quarry. LP1060 23 This appears to be a well-used green space within an existing Land at Shirley residential area. Grove, Lightcliffe, This should be deleted and if it comes forward, it will be a windfall. Brighouse This is one of 41 new housing sites that the Council have added since the February Cabinet meeting. The Housing Technical Paper identifies a suggested delivery in year 2 (2019/2020) stating that the site has been identified in the Calderdale Together Investment Partnership, and delivery timescales have been provided by Together Housing Group. It is unlikely that this site will deliver next year, given that a planning application has yet to be submitted. LP1077 213 This site is a former quarry, which is likely to have significant constraints Southedge Quarry, that could affect the viability and therefore the deliverability of the site. Brighouse Road, The Housing Technical Paper identifies a suggested delivery in Year 6 Hipperholme (2023) LP1093 35 This is a former quarry site with likely constraints associated with quarry Former Hill Crest redevelopment that could affect the deliverability of the site. The site is Quarry, Halifax adjacent to housing site 1095, which is being promoted by a Road, Hove Edge, housebuilder. Brighouse The Housing Technical Paper identifies a suggested delivery in Year 7 (2024) ______

Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

LP0945 62 This is a quarry site, with numerous identified constraints including Pond Quarry, access (steep site), land stability, and contamination, which all add to Lightcliffe Road, the concerns regarding the viability and deliverability of the site. Brighouse Furthermore, given the constraints, it is considered the density assumptions are too high. The Housing Technical Paper identifies a suggested delivery in Year 9 (2026) and makes reference to viability having an impact on the delivery timescale. LP0338 22 This is a privately owned area of overgrown greenspace within the Land adjacent urban area. Access is identified as a constraint due to the sloping nature Whinney Hill Park, of the site. Given the location of the site within the urban area, it is telling Whinney Hill, that the site has no developer interest. This justifiably raises Brighouse deliverability concerns. The Housing Technical Paper identifies a suggested delivery in Year 4 (2021) and also refers to there being no agent or developer interest identified. It is questionable therefore how delivery in year 4 has been identified. LP1648 31 This site is an existing car park, located immediately north of a large Land north of industrial site (Crosslee Plc). It is unrelated to the built settlement edge. Crosslee, This should be a windfall site. Brighouse Road, This is one of 41 new housing sites that the Council have added since Hipperholme the February Cabinet meeting. The Housing Technical Paper identifies a suggested delivery in year 11 (2028). LP0146 31 We question the deliverability of this site on the basis of the access, Land to the west of which appears from the site plan and from google images, to be more West View, Church of a track, and unsuitable for a residential development of 30 dwellings. Lane, Stainland, Identified constraints (conservation area and flood storage area) cast Elland further doubt. Furthermore, there is an application currently pending consideration (17/00408/FUL) for ‘Change of use from agricultural land to mixed use of agricultural land with yard area, stable block (part used as utility block), stationing of caravans for residential occupation by Traveller family with associated works (hardstanding, fencing, walls, septic tank, alterations to access with entrance gates, electricity box and gas tank)- ______

Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

(part retrospective)’. The applicant is identified as the landowner on the forms and as such the site cannot be considered available for residential use. The Housing Technical Paper suggests a delivery in year 14 (2031) LP1030 14 There are access issues into this site, with third party land required to Land adjoining enable access from South Parade. The proposed developable area will South Parade, Adj separate the site from the settlement resulting in a small isolated Maple Fold, Elland development. This is one of 41 new housing sites that the Council have added since the February Cabinet meeting. The Housing Technical Paper suggests a deliver in year 8 (2025) and states that there is no housebuilder interest identified.

LP0261 91 This is public owned greenspace in current use within a high density Land at Turner residential area. We question the loss of this greenspace. Avenue South, The Housing Technical Paper suggests a delivery from year 6 (2023) Ovenden, Halifax LP0353 9 Again, this is public owned accessible greenspace in current use, Land to the rear (including a playground). We question the loss of this greenspace. 109 Fairfax The Housing Technical Paper suggests a delivery in year 4 (2021) Crescent, Southowram, Halifax LP0590 54 Access limitations. There is limitations due to width. Beacon Lodge This is one of 41 new housing sites that the Council have added since Quarry, Long Lane, the February Cabinet meeting. Halifax Housing Technical Paper includes delivery in year 9 and 10 (2026/27 – 2027/28) LP1215 11 This site does not relate well to the settlement edge, there are Land adjacent, topography issues, as well as existing trees, and noise issues due to Boothtown Road, proximity to commercial uses. Boothtown It is considered that this site should be considered as a windfall, should it come forward.

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Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

The Housing Technical Paper suggests a delivery in year 4 (2021) and also confirms there is no known housebuilder interest – confirming our doubt regarding its deliverability.

LP1379 41 This is Council owned, narrow linear strip of land. This is not an Heathmoor Park appropriate housing site. We question the density suggested. Road / Field Head If this site comes forward it should be a windfall. Lane, Illingworth The Housing Technical Paper suggests a delivery in year 3 and 4 (2021/21 – 2021/22). This is based on the Council’s Housing Services, considering site is identified in the Calderdale Together Investment Partnership. LP1486 - 1489 27, 14, 11, This is a collection of 4 sites which are currently open space within a 14. Land off housing development. We question the suitability of all the sites, which Cumulative Hambleton Drive, total = 66 would cumulatively impact on the open space in the locality and the Balkram Road, and provision of children’s play (as identified by the Council in the site Hambleton specific text relating to these sites. Crescent, The Housing Technical Paper suggests delivery from these sites from Mixenden, Halifax year 10 - 14 (2027/28 – 2031/32). TOTAL 803 Our selective assessment of identified housing sites in the Publication dwellings Draft Local Plan brings into question the deliverability of 803 dwellings within the Plan Period.

Policy HW2 – Health Impact Assessment

2.33 We question the justification of this policy which requires all residential development proposals above 30 dwellings to provide a Health Impact Assessment especially so if housing sites are selected in sustainable locations. There appears to be no justification for the 30 dwelling (3,000sqm) threshold at which a Health Impact Assessment is required. This is an unnecessary burden on applicants.

Policy IM5 – Ensuring Development Supports Sustainable Travel

2.34 Further clarification is required regarding the last part of this policy relating to Transport Assessments. The text states:

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Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

“Travel Plans, Transport Assessments and Transport Statements are expected for all developments that generate significant amounts of movement.”

2.35 It is not clear what ‘significant amounts of movement’ equates to. Further detail would be welcomed.

Policy HS5 – Self-Build and Custom Housebuilding

2.36 Whilst we have no objections to the Council’s aim of increasing and the self-build and custom build housing sector we do have concerns with the proposed approach of sites above 100 dwellings providing 5% of the overall capacity as serviced plots for self or custom build need. The 5% is not justified, nor is the evidence that those on the Self Build and Custom Housebuilding Register actually want sites within larger housing developments. Given the surroundings of any self-build plots will be a new-build ‘estate’ it is considered this environment is unlikely to be attractive to those people seeking self and custom-build opportunities. Smaller sites are more appropriate.

2.37 The introduction of plots for self and custom-built homes is likely to prevent comprehensive development and result in plots remaining undeveloped. Such plots are detrimental to the appearance of a development and at risk of attracting anti-social behaviour. Should self or custom-built housing be developed then this would differ from the design theme of the surrounding development. Should design consistency requirements be imposed, then it is unlikely that this would be attractive to self or custom-builders. Should self and custom-build plots be developed, then there will be complications of construction management with contractors unrelated to the main build contractors working in the same environment. This increases risk/liabilities and reduces efficiency.

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Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

3.0 Rejected Sites – LP1109 Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse.

Commenting on Rejected Sites (page 49)

3.1 We welcome the opportunity to comment on the filtered (rejected) sites and take the opportunity to comment on the following site on behalf of our client Highstone Homes.

3.2 We have set out in the preceding section, a number of reasons, based on evidence why the Local Plan needs to identify additional deliverable housing sites. We have identified concerns relating to the deliverability of a number of identified housing in the vicinity of Site LP1109. Rejected site LP1109 is a suitable, available and deliverable site that should be a housing allocation in the Local Plan.

3.3 The site would form a natural and logical rounding off to the existing residential area with existing development on all but one side.

Green Belt

3.4 The site does not fulfil a strategic Green Belt function, and its removal from the Green Belt would be wholly justified in order to meet the housing requirement in Calderdale MBC over the plan period. The loss of the site from the Green Belt would not cause overall harm to the purposes of the Green Belt. The site relates very well to the existing urban area, with the existing settlement of Hipperholme to its eastern, southern and western sides. Northedge Lane acts as a strong, defensible northern boundary, which neatly contains the site within the urban context.

3.5 The site represents a suitable area for release from the Green Belt when considered both against the five purposes of the Green Belt and in landscape and visual terms. Northedge Lane would form an appropriate new Green Belt boundary without impacting on the overall form of Hipperholme or leading to coalescence with any other settlements. Given the presence of existing urban development along Northedge Lane both to the east and west, the release of the land would infill the established pattern of development at this northern edge of Hipperholme.

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Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

3.6 Pegasus have been appointed to undertake a review of the findings of the Council’s Green Belt Review in relation to site LP1109. The following text is based on the findings of the Pegasus statement, which is attached in full at Appendix 2. The below text analyses the site against the five Green Belt purposes outlined in the Framework, with commentary regarding how the site scores against the five purposes compared with the Council’s findings in the Green Belt Review (2017) that forms part of the Local Plan evidence base.

Purpose 1 – ‘to check the unrestricted sprawl of large built up areas.’

3.7 We disagree with the Council’s interpretation in the Green Belt Review that the site fulfils Purpose 1. The site has a strong existing relationship with the surrounding built up area; development within the site would round off the existing build up area; the site is bounded along its remaining side by Northedge Lane, which constitutes a strong, defensible Green Belt boundary; and its release form the Green Belt and its potential development, would not appear isolated within the surrounding context. The site does not fulfil Purpose 1.

Purpose 2 – ‘to prevent neighbouring towns merging into one another.’

3.8 We agree with the Council’s conclusion that the site does not fulfil purpose 2. The size of the site (1.89 ha); the distance between the site and the nearest adjacent built up area (Northowram, which is 1km away to the north west); the fact that the site does not encroach any further north than existing development either side of it; and the fact that there is no inter- visibility between the site and the Northowram settlement edge, all contribute to the site not fulfilling Purpose 2. The site does not fulfil Purpose 2.

Purpose 3 – ‘to assist in safeguarding the countryside from encroachment.’

3.9 We disagree with the Council’s interpretation that the site fulfils Purpose 3. It is considered that the site peforms a minor role in protecting the countryside from encroachment. For the majority of its boundaries it is surrounded by existing residential land use; those boundaries are considered to be weak in reinforcing the Green Belt edge; there is no existing recreational use within the site, however a former use of part of the land as allotment gardens indicates further the relationship of the land with the adjacent built up areas, and to a reduced degree with the agricultural uses alluded to and accords with the ‘Urban Fringe Character. The development of the site would bring about little change to the perception of the landscape from the surrounding

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Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

areas. Development would appear among existing landscape elements within the land and the surrounding built form. The site does not fulfil Purpose 3.

Purpose 4 – ‘to preserve the setting and special character of historic towns.’

3.10 We agree with the Council that the site does not fulfil purpose 4, which states that the site “would have no effect on the setting and special character of historic features.” The site does not fulfil Purpose 4.

Purpose 5 – ‘to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.’

3.11 The Council’s Green Belt Review scored all parcels the same against this purpose, stating that all areas within the Green Belt by their nature and designation should contribute to the recycling of derelict and urban land. The site does fulfil Purpose 5.

3.12 Overall, it is considered the site only fulfils Purpose 5, and does not fulfil purposes 1 – 4. The site scores poorly when assessed against the five Green Belt purposes.

Calderdale MBC Site Assessment

3.13 The Council’s ‘Site Assessment Report – Show Stoppers’ for rejected (‘filtered’) Site LP1109 concludes the following:

 Flooding: No Show Stoppers - The site is in Flood Zone 1 and likely to be agreed after surface water flooding can be attenuated through SUDS implication and use of permeable surfacing. The site is suitable for the development.

 Highways: The Site Assessment Report highlights potential access issues which are resolvable. Paragon Highways have been commissioned by our client to undertake a Highway Site Appraisal, which refers to the suitability of the access at Northedge Lane and proposed highway improvements including widening of the carriage way and provision of a footway along the full site frontage. The Paragon Highways Site Appraisal is attached at Appendix 3. The ______

Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

site has been assessed based on an anticipated residential development of circa 80 dwellings. It is more likely that the site could deliver circa 60 dwellings.

The Local Plan Transport evidence Technical Note 5 Hipperholme Sensitivity Test states that it can be clearly demonstrated that the Hipperholme cross roads junction is at an unacceptable level of congestion currently and worsened by the overall predicted growth in traffic as a result of the wider Local Plan allocations. The in-combination effects of additional land released from the Green Belt within the Hipperholme area will have a significant and demonstrable detrimental impact on the A58 / A644 junction. Despite the Council’s conclusion there are a number of planned improvements to the Strategic Road Network serving Calderdale funded as part of the government’s Road Investment Strategy (RIS), which are intended to provide additional capacity at congested locations. The RIS schemes of relevance include:

- M1 / M62 Lofthouse Interchange - M62 junctions 20 – 25 - M62/M606 Chain Bar - M621 junctions 1 – 7 improvements.

As well as the above, additional capacity improvement measures have been identified as needed to cater for demand generated by development in Calderdale and neighbouring districts to 2030. A number of schemes are referenced in the Infrastructure Delivery Plan.

The Highway Site Appraisal that has been prepared for the site concludes that:

“Considering that the site is located within a sustainable location adjacent to the local bus services and within the accepted cycling distance of access to a railway station, the proximity of local schools, and the commitment to provide a Travel Plan and Residential Metrocards, the traffic generation would have the potential to be less than that normally predicted for a development of this size. It is considered that the level of traffic generated by the potential development can be accommodated on the surrounding highway network, and cannot have ______

Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

a significant impact on the road network given the unnoticeable increase in traffic along Denholme Gate Road, and would certainly not create a demonstrable detrimental impact on the A58/A644 as referred to by the Council’s Local Plan site assessment. Therefore, coupled with the highway improvements the development would have no material impact upon the Northedge Lane, the A644 Denholme Gate Road or its junction with the A58. The potential development would also result in a significant improvement along the site frontage of Northedge Lane with the provision of carriageway widening and a footway along the development side of the major road. The highway improvements would also result in significant benefits to drivers accessing and egressing the adjacent cul-de-sac known as Groveville in relation to visibility and accessibility.”

 Ecology: No show stoppers – No impact on environmentally sensitive areas.

 Historic Environment: No show stoppers – Some impact which could be mitigated.

3.14 The summary of the Council’s Site Assessment Report refers to the site being ‘filtered’ and not taken forward as an allocation due to the cumulative impact on the Hipperholme junction, outweighing the benefits attributable to the additional housing. We disagree with this conclusion, and consider that given the proposed future capacity improvements measures, the potential highway impacts are not insurmountable. There are clear benefits to the allocation of this site, which will deliver a mix of housing (likely to be circa 60 - 80 dwellings), included much needed affordable housing in accordance with emerging Local Plan Policy HS6 (25% provision). The site has housebuilder interest, with Highstone Homes having a contractual agreement in place with the landowner. Highstone Homes are a sister company to Highstone Housing Association, which are a non-profit registered provider who operate across Yorkshire, therefore resulting in the affordable housing provision on this site being delivered and managed in house.

3.15 This statement highlights the shortcomings of the Publication Draft Local Plan, concluding for a number of reasons that additional land for housing needs to be identified. For the reasons stated above, site LP1109 is an available, suitable and deliverable site that should be allocated for housing in the Local Plan. The site would be a wholly logical allocation that can tap into ______

Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

existing nearby infrastructure. It is accessible to public transport, and within walking distance of services in Hipperholme. The site performs poorly against the Green Belt purposes, and its removal from the Green Belt is wholly justified in order to meet the Borough’s housing requirement.

______

Calderdale Local Plan Publication Draft – September 2018 LP1109 – Land South of Northedge Lane, Northedge Lane, Hipperholme, Brighouse

APPENDIX 1 Appendix 1

Aerial Images of Johnson Mowat Questionable Policy SD7 Housing Sites

Squires Hill Quarry LP1053 and LP1054

Shirley Grove, Lightcliffe, Brighouse LP1060

Southedge Quarry, Brighouse Road, Hipperholme LP1077

LP1116 and LP1648 Brighouse Road, Hipperholme.

LP1648 is an existing car park

Former Hill Crest Quarry, Halifax Road, Hove Edge, Brighouse LP1093

Pond Quarry, Lightcliffe Road, Brighouse LP0945

Land adjacent Whinney Hill Park, Whinney Hill, Brighouse LP0338

LP0146 West View, Church Lane, Stainland, Elland

LP0261 Turner Avenue South, Ovenden, Halifax

LP1030 South Parade, Adj Maple Fold, Elland – 14 dwellings

LP0353 Land to the rear 109, Fairfax Crescent, Southowram, Halifax

LP0950 Beacon Lodge Quarry, Long Lane, Halifax

LP1215 Land adjacent Boothtown Road, Boothtown, Halifax

LP1379 Heathmoor Park Road / Field Head Lane, Illingworth, Halifax

LP1486 Hambleton Drive, Mixenden (27 dwellings)

LP1487 Balkram Road, Mixenden (14 dwellings)

LP1488 Hambleton Crescent, Mixenden (11 dwellings)

LP1489 Hambleton Crescent (south), Mixenden (14 dwellings)

APPENDIX 2 Pegasus Group

001.fh/P18.0725

20th April 2018

Lucy Lloyd Highstone Housing Association Broadstone Farm Browns Edge Road Ingbirchworth Sheffield S36 7GR

Dear Lucy,

Re: Land at Northedge Lane, Hipperholme

Calderdale Council published their ‘Green Belt Review Final Report 2016’ (“the Report”) in August 2016. In the Introduction to the Report the Council noted that during the production of the current plan, the Replacement Calderdale Unitary Development Plan (RCUDP), it was considered there was sufficient land proposed to meet future housing, employment and retailing needs, for the District until the end of the plan period (2016), without having to encroach significantly into the Green Belt. However, it was also noted by the Report that a strategic review of Calderdale’s Green Belt was now required due to the additional pressures for development that have been identified during the next plan period and the tightly drawn nature of the Calderdale Green Belt. The purpose of the Report was identified as being to provide an understanding of the current strengths and weaknesses of the existing Green Belt and provide the basis for recommendations to change the Green Belt where appropriate to provide certainty for the next 30 years or more.

Pegasus have considered the findings of the Report in relation to the parcel of land at Northedge Lane, Hipperholme.

The parcel of land lies adjacent to the existing settlement of Hipperholme and which encloses it to its eastern, southern and western sides. To its immediate north, the land is divided from wider farmland by Northedge Lane, flanked to each side by 1.5m high, intact, dry stone walls.

The Report concluded that all of the Green Belts Parcels considered in Calderdale were either ‘Mid Sensitive Green Belt Parcels’ noted as ‘Parcels having medium sensitivity’, or ‘Most Sensitive Green Belt Parcels’ noted as ‘Parcels having high sensitivity’. Mid Sensitive Green Belt Parcels were said to meet 0-2 of the identified purposes of the Green Belt and should therefore be considered for detailed study, whereas Most Sensitive Green Belt Parcels were said to meet 3-5 of the identified purposes of the Green Belt and should therefore be retained in the Green Belt.

Pegasus Group is a trading name of Pegasus Planning Group Limited (07277000) registered in England and Wales Registered Ofﬁ ce: Pegasus House, Querns Business Centre, Whitworth Road, Cirencester, Gloucestershire, GL7 1RT

Pegasus Group

We note that the finding of the Report in relation to GB198-00 was that it was considered to be one of the ‘Most Sensitive Green Belt Parcels’ proposed for retention in the Green Belt, on the basis that it meets 3 of the 5 purposes of the Green Belt. Pegasus do not agree with this conclusion and set out in the following reasons, that the land should justifiably be released from Green Belt when considered against the five Green Belt purposes.

The parcel of land is of relatively small scale, 1.98ha and as set out above, has a strong relationship with existing built up areas. Its limited size and enclosure by existing built form to all but the northern boundary, exerts a strong influence upon much of this land parcel.

There are several Tree Preservation Orders (TPOs) in place within or along some of the land boundaries (Excerpt 1). The protected trees include a group of hawthorn, 5 ash, 2 sycamore and 1 oak, however their limited extent and scattered locations offer little in the way of defining the existing Green Belt boundary.

Excerpt 1 Tree Preservation Orders on Parcel GB198-00 (https://www.calderdale.gov.uk/v2/maps/tpo, accessed 19.04.18), with land parcel shown with red outline.

An aerial map identifying Parcel GB198-00 is provided at Image 1 below.

Pegasus consider that the parcel GB198-00 would represent a suitable area for release from the Green Belt when considered both against the five purposes of the Green Belt and in landscape and visual terms. Northedge Lane would form an appropriate new Green Belt boundary without impacting on the overall form of Hipperholme or leading to coalescence with any other settlements.

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Pegasus Group

We have considered the Green Belt Parcel Survey Form prepared for GB198-00 and the manner in which it has addressed each of the five purposes of the Green Belt and consider that the site does not meet 3 of the 5 purposes, thereby indicating that it should be subject to further scrutiny within the Local Plan process.

We note that no appraisal was provided in relation to Green Belt Purpose 5 and that this purpose was excluded from the assessment undertaken. Our findings in relation to each of the remaining four purposes is however set out below.

Purpose 1 – ‘to check the unrestricted sprawl of large built-up areas’ The Report concludes that GB198-00 does fulfil purpose 1.

Within the Green Belt Review Methodology (2015), a series of questions and subsequent assessment criteria for Purpose 1 are set out.

Our desk top and site assessments query the conclusion of the Report that parcel GB0198-00 is ‘connected by two or less boundaries to the built up area’. As illustrated at Image 2 below, although the site is broadly triangular in shape, we put forward that there are three boundaries which adjoin existing built up areas, as illustrated at Image 2. A calculation of the percentage of the site boundaries which adjoin the built up area, equates to approximately 64% of the parcel boundary. By way of checking that such a percentage might be considered as being appropriate a measure and calculation for the nearby site ‘GB0570-00’ (shown outlined in blue on the aerial below), shares highly comparable percentages of 35%: 65% rural: built up areas.

The remaining approximate 36% of parcel GB0198-00 is comprised from Northedge Lane which offers a future strong, defensible boundary to the Green Belt.

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Pegasus Group

Image 2

It is also noted that there is existing urban development along Northedge Lane, in both easterly and westerly directions. Release of the parcel of land would therefore infill the established pattern of development at this northern edge of Hipperholme. The conclusion of the test undertaken within the Green Belt Review Report, that the removal of the land from the Green Belt would result in a high potential for unrestricted sprawl, is misconstrued.

Our assessment of the site and its role in checking unrestricted sprawl of large built up areas concludes that the site has a strong existing relationship with the surrounding built up area; development within the site would round off the existing built up area; the site is bounded along its remaining side by Northedge Lane, which constitutes a strong, defensible Green Belt boundary and; its release from the Green Belt and its potential development, would not appear isolated within the surrounding context.

Conclusion - It is not agreed that GB198-00 fulfils purpose 1.

Purpose 2 – ‘to prevent neighbouring towns merging into one another’ The Report concludes that GB198-00 does not fulfil purpose 2 and this is agreed with considering the size of the parcel of land and the distance between it and the nearest adjacent large built up area (Northowram), being 1km away to the north west and with which there is no inter-visibility.

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Pegasus Group

Conclusion - It is agreed that GB198-00 does not fulfil purpose 2.

Purpose 3 – ‘to assist in safeguarding the countryside from encroachment’ The Report concludes that GB198-00 does fulfil purpose 3. The site is located within the ‘Coalfield Edge Urban Fringe Farmland Character Area’ within the characterisation included within the ‘South Pennines Wind Energy Landscape Study’ (which forms the relevant published landscape character assessment for the area) and is identified as having an ‘Urban Fringe Character’.

At the time of visiting, the land was in use as grazed pasture. A Public Right of Way (pending upgrade to a bridleway) passes adjacent to the eastern land boundary for a distance of approximately 20m before passing between existing areas of housing (Excerpt 2). There was no evidence that the land is in use for recreational activity and no rights of way pass across the land itself. The Public Right of Way would not be directly affected by any future development and from a landscape and visual perspective and the effect upon users of the route would be very limited.

Excerpt 2 Public Rights of Way near Parcel GB198-00 (https://www.calderdale.gov.uk/v2/maps/leisure, accessed 19.04.18) with land parcel shown with red outline.

The Report concludes that there exists a ‘partial’ strong defensible boundary between the existing urban area and the parcel. As earlier described, the land use adjacent to the land boundaries to the eastern, southern and western sides, is residential. The boundary treatment of the parcel of land is predominantly a dry- stone wall which divides rear gardens of residential properties located to the eastern and southern boundaries. Walling in these locations is generally dilapidated and meaningful vegetation is limited to three mature trees (subject to a TPO) at the

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Pegasus Group

eastern-most part of this boundary. The western boundary is defined by a mature field hedgerow which divides the land from ‘Groveville’ a no through lane providing access to terraced properties. The lane doesn’t appear to have been constructed, or subject to maintenance to adopted standards and as such, the perception is one of a private road.

As set out within the Green Belt Review Methodology ‘strong’ boundaries are those anticipated to remain for the long term and are extremely difficult to alter or destroy by physical means or by planning decision’. Table 6 of the Methodology includes the following as ‘weak’ boundaries:

• Private/unmade roads; • Field boundaries; • Non-protected woodlands/trees/hedges; • Residential or other development with weak or intermediate boundaries.

With the exception of the northern boundary with Northedge Lane, all boundary treatments are comprised from elements of features included as ‘weak’ within the Calderdale Methodology. In considering the above, it is our conclusion that the boundary with Northedge Road, which is well defined to both the south (with Parcel GB198-00) and with the wider landscape to the north, presents a consistent, well defined boundary which offers a more robust Green Belt edge in this location. Indeed, in reviewing the consistency in approach to appraising the strength of existing Green Belt boundaries, we note that the conclusions drawn for the nearby Parcel GB057-00, is that there are no existing strong defensible boundaries. A conclusion which we might expect to also be the case for this land, given the similar adjacent land uses and location of groups of TPOd trees which form part of the existing Green Belt boundary.

When considering the various factors set out within the Green Belt Review Methodology, to determine whether land performs this Green Belt purpose, it is evident that the conclusions drawn in in this instance, relate predominantly to the virtue of it as ‘undeveloped agricultural land’. Indeed, our review of the land against the questions set out within the Green Belt Review, surmise that the land in fact has no existing strong, defensible, boundaries between it and the existing urban area and although not directly encroached upon by recent development, forms a remnant piece of land left over from previous residential development to the south and west of the land in the late 20s/early 30s and subsequently further east along Northedge Lane during the post war period. It is also of note that the north eastern- most field within GB198-00 is shown within the map of 1959, as being in use as allotment gardens. This part of the land, presently, did not present evidence of any current such use and appear to have been left largely unmanaged with self-set trees, taller ruderal grasses and boundaries which would be insufficient for the containment of stock. We suggest therefore, that this part of the land is not in current use as pasture or performing another agricultural function. As such we suggest that the land is not entirely performing the function of Green Belt land.

A key test to which would be the perception of the land from the surrounding area and whether development within it would give rise to a perception of encroachment.

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Pegasus Group

For the reasons set out above, we suggest that parcel GB198-00 performs a minor role in protecting the countryside from encroachment. For the majority of its boundaries it is surrounding by existing residential land use; those boundaries are considered to be weak in reinforcing the Green Belt edge; there is no existing recreational use within the site, however a former use of part of the land as allotment gardens indicates further the relationship of the land with the adjacent built up areas, and to a reduced degree with the agricultural uses alluded to and accords with the ‘Urban Fringe Character’.

Image 3 below shows a southerly view from Public Right of Way (Ref: Brighouse008) located approximately 340m north of Parcel GB198-00. Should Parcel GB189-00 be released from the Green Belt, potential development occurring within it would bring about little change to the perception of the landscape from the surrounding areas. Such development would appear among existing landscape elements within the land and the surrounding built form which, as illustrated at Image 3, presently comprises an element of views.

Image 3

Conclusion - It is not agreed that GB198-00 fulfils purpose 3.

Purpose 4 – ‘to preserve the setting and special character of historic towns’ The Report concludes that GB198-00 does not fulfil purpose 4, stating that development of the Parcel ‘Would have no effect on the setting and special character of historic features’.

Conclusion - It is agreed that GB198-00 does not fulfil purpose 4.

We have also considered the overall approach and methodology to the Green Belt Review. In particular, we have noted the calculation of the extent to which the land is connected by built up areas has been mis-represented through omission to include the southern boundary, therefore skewing the result that less than two boundaries adjoin built up areas.

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Pegasus Group

We note that paragraph 81 of the NPPF states that ‘once Green Belts have been designed, local planning authorities should plan positively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access; for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve derelict land’.

There is no public access to Parcel GB198-00 for recreation or leisure purposes and no public rights of way cross the Parcel such that the land provides visual amenity. The removal of this Parcel from the Green Belt would not therefore be detrimental to the aims of paragraph 81.

We are aware however that many of the identified ‘Mid Sensitive Green Belt Parcels’ are crossed by PROW or include leisure facilities such as golf courses, where their removal may serve to reduce the overall amenity function of the Green Belt. This matter does not appear to have been adequately addressed in the analysis undertaken and this is especially evident with reference to Parcel GB057-00, to the east of Parcel GB198-00. This land incorporates a network of footpath and bridleway routes. The land therefore serves to provide an amenity function in the Green Belt, which would be altered considerably if the site were to be developed. It therefore seems inappropriate for Parcel GB198-00 to have been deemed more sensitive in Green Belt terms than adjacent land with an equivalent proximity to the existing settlement, a higher degree of inter-visibility with the wider landscape and a notably higher perceived tranquillity than that of Parcel GB198-00.

Overall it is considered that Parcel GB198-00, has not been appropriately assessed with regard to its suitability for release from the Green Belt. The parcel of land could be developed in the future to allow retention of TPO trees and the definition which exists along Northedge Lane would form a more robust new Green Belt boundary in this location, without impacting on the overall form of Hipperholme, or leading to coalescence with any other settlements.

Yours sincerely,

Frances Horne Associate Landscape Architect E-mail: [email protected]

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APPENDIX 3 Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

POTENTIAL RESIDENTIAL DEVELOPMENT ON LAND AT NORTHEDGE LANE, HIPPERHOLME

HIGHWAY SITE APPRAISAL

1.0 Introduction

1.1 Paragon Highway Consultants have been appointed to carry out a Highway Site Appraisal for a residential development on land at Northedge Lane, Hipperholme. This site appraisal updates the previous report dated April 2016 and considers the existing infrastructure, site sustainability, means of access, and general traffic impact of a residential development of some 80 dwellings. This updated report also provides further information on the traffic impact of the development along Denholme Gate Road and its junction with the A58 at the centre of Hipperholme, and provides further information to satisfy the concern raised within the Council’s Local Plan Site Assessment Report (LP Site Ref LP1109). The site would be accessed from Northedge Lane.

2.0 Site Location and Local Highway Network

2.1 The site is situated within Hipperholme on land to the north of the settlement. The site is located between The Grove and Northedge Lane close to the northern side of Hipperholme. It is located 0.6km north of the town centre and 3km west of the Halifax Town centre. The site is an undeveloped site totalling some 4.5 acres, which mainly contains large grassed areas with dry stone boundary walls to most boundaries.

2.2 The site is bounded by Northedge Lane to the north, properties fronting The Grove to the south and properties adjacent to Groveville to the west and residential properties to the east.

2.3 The site has the potential to be accessed from Northedge Lane, which links into Denholme Gate Road to the west which is an A class Highway – A644. Denholme Gate Road at its junction with Northedge Lane is the subject of a 30mph speed limit and is lit to an appropriate standard. Denholme Gate Road

Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

in Hipperholme serves commercial premises, retail premises, side road junctions and vehicular access points to individual properties. A peak hour traffic count was undertaken on the 13th June 2017 along Denholme Gate Road/ Northedge Lane junction. From the survey it was identified that during the peak hour Denholme Gate Road was subject to 1077 two way traffic flow, with a 52/ 48 split in traffic flow to the south and north respectively. The proposals for vehicular access to the site are presented in more detail in para. 4.0 below.

2.4 Northedge Lane is a two way single carriageway and has a 30 mph speed limit. It has the benefit of street lighting and a far side (northern) footway opposite the site. Visibility for egressing drivers at the proposed new junction onto Northedge Lane, which would be located centrally on the site frontage, would meet the current sight line standards as set out in the Manual for Streets 1 & 2.

2.5 Groveville adjacent to the sites western boundary is a private cul-de-sac serving some 12 properties and is in a poor state of repair. Visibility for drives egressing Groveville onto Northedge Lane in the critical direction is severely restricted due to the road narrowing and the hedge line fronting the proposed site. See photograph immediately below of Groveville.

2.6 Northedge Lane some 160 metres east of its junction with Denholme Gate Road does change in character from a more traditional highway to a more rural route and the carriageway narrows noticeably just beyond the junction with Groveville. Along the full site frontage to Northedge Lane the site is bounded by a verge, which varies in width but has the benefit of a footway on the opposite side. See photograph immediately below.

Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

2.7 The site is located within walking distance of the bus services available on the Denholme Gate Road & those within Hipperholme. Further details of the bus services available from the local fare stages are shown in paragraph 3.0 below.

3.0 Sites Accessibility by other Modes of Transport

3.1 Policy

3.1.1 The National Planning Policy Framework (NPPF) was published on 27th March 2012. This document superseded a number of national Planning Policy Statements and Guidance Notes (PPS’s and PPG’s). The national transport policy relating to transport and development that was formerly set out in PPG 13 ‘Transport’ is now replaced by Section 4 of the NPPF.

3.1.2 However the guidance within PPG 13 is still useful as a reference until such time as the Local Planning Authority publishes their specific transport policies.

3.1.3 Paragraph 35 of the NPPF states that “developments should be located and designed where practical to: • accommodate the efficient delivery of goods and supplies; • give priority to pedestrian and cycle movements, and have access to high quality public transport facilities; • create safe and secure layouts which minimise conflicts between traffic and cyclists or pedestrians, avoiding street clutter and where appropriate establishing home zones;

Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

• incorporate facilities for charging plug-in and other ultra-low emission vehicles; and • consider the needs of people with disabilities by all modes of transport.

3.2 Bus Travel

3.2.1 Opportunities to access bus services exist on Denholme Gate Road (all less than 450m from the potential site). The nearest bus stop on the A644 (northbound) benefits from timetable information and a passenger shelter. The southbound fare stage on the A644 close to the junction with Bramley Lane has a flag and timetable information. The bus services available from the nearest stops are shown in Fig 3.2A below:

Service No From – To Frequency Late evenings Mon – Sat and Sundays Halifax – Southowram – Brighouse – 60 mins 571 60 mins Hipperholme – Shelf – Bradford Pm only Fig 3.2A - Bus Services – A644

3.2.2 It is acknowledged that the bus services on the Denholme Gate Road are not to a particularly high standard, however, some 880 metres to the south on the Halifax Road there are several more bus services with much better frequencies. These stops are considered to be not so far away from the site so as not to be used. The bus services available from these stops are shown in Fig 3.2B below:

Service No From – To Frequency Late evenings Mon – Sat and Sundays Halifax – Wyke – Scholes – Cleckheaton – 255 60 mins 60 mins Gomersal – Birkenshaw - Leeds 30 mins Sunday 548 / 549 Halifax – Hipperholme – Brighouse 15 mins daytime 60 evenings Fig 3.2B - Bus Services – Halifax Road

3.2.3 As can be identified from Fig 3.2A and Fig 3.2B there are frequent bus services that provide access to local settlements and to the major town of Halifax and the city of Leeds. Therefore, it is considered that these bus services will provide a very good alternative to the private car in line with current Government guidelines.

Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

3.3 Train Travel

3.3.1 The site is located some 4.1km to the north east of Halifax rail station which is within the accepted cycling distance for commuting. Halifax station is on the Calder Valley line and the local rail services available from this station are as shown below:

Calder Valley Line

Service frequency

Monday to Saturday

Frequency Sunday Route Frequency Late Daytime evening

Leeds - Bradford Interchange - Halifax 15 mins 30 mins 20 mins

Leeds - Bradford Interchange - Halifax - Rochdale - 30 mins 60 mins 60 mins Manchester Victoria

Leeds - Bradford Interchange - Halifax - Huddersfield 60 mins 60 mins 120 mins

Leeds - Bradford Interchange - Halifax - Blackburn - Preston - 60 mins 120 mins 60 mins Blackpool*

3.3.2 As can be identified from the train routes and services summarised above there are excellent train links available with frequent train services to the cities of Leeds, Manchester and Bradford and the large town of Huddersfield.

3.3.3 Halifax rail station has the benefit of 3 cycle lockers, 16 cycle stands and cctv coverage. There are also 32 car parking spaces at the station. Cycle hire is also available from Halifax Station (10 bicycles). This provides the opportunity for residents to use multi modal travel.

3.4 Access for pedestrians and cyclists

Pedestrian and cycling accessibility are to a standard commensurate with the local urban and rural parts of the area and those adjacent to the site.

3.4.1 Walking – Pedestrian accessibility within the development would be at a suitable gradient for all pedestrians including the ambulant disabled and will conform to Local Authority guidance.

Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

3.4.2 As part of the development proposals it is proposed to provide a footway along the site frontage to Northedge Lane which will be a major improvement to highway safety.

3.4.3 The local footway / footpath network provide a convenient and safe link to the bus service on Denholme Gate Road and the shops and services within Hipperholme. The A644 also has a pedestrian crossing facility located close to the Grammar school and children’s nursery.

3.4.4 Cycling - Within the accepted cycling distance for commuting (5km) there are significant employment opportunities within Hipperholme itself and also within Bailiff Bridge and Halifax. Within cycling distance there are also the neighbouring residential settlements and service centre areas of Northowram, Lightcliffe, Southowram and Wyke.

3.4.5 As mentioned above the Halifax Rail Station has 19 cycle spaces and 10 hire bicycles. The 548 and 549 bus service also provides a convenient link with the town of Halifax allowing for multi modal journeys.

3.5 Accessibility Conclusion

It is considered that the potential site is in a sustainable location being within close proximity of the nearest bus stops and cycling distance of the Halifax railway station and within acceptable walking distance of the many local services and amenities in and around Hipperholme. Within cycling distance of the site there are leisure amenities, educational institutions, and industrial and employment areas. Therefore the site conforms to current Government directives for ensuring developments are located in a sustainable locations.

Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

4.0 Proposed Development

4.1 It is anticipated that the site would be developed to provide a new residential development of 80 new dwellings, which would be sympathetic to nearby development. Green space will be retained within the site boundaries. The internal road layout would conform fully to current design criteria and Calderdale Councils design guide.

4.2 The potential site would be accessed via Northedge Lane. This access point would be located centrally along the site frontage to the major road. Junction radii and return footways will lead to an informal shared surface layout.

4.3 As part of the development proposals Northedge Lane will be widened to provide a minimum of 5.5 metre wide carriageway and a 2 metre wide footway along the full site frontage. The carriageway widening and the provision of a footway will also substantially improve visibility and general access for drivers egressing and aggressing the adjacent highway known as Groveville. These improvements are also suggested within the Council’s Local Plan Site Assessment Report (LP Site Ref LP1109).

4.4 The development proposals would also seek to provide passenger shelters where possible on the nearest fare stages to the site on Denholme Gate Road to further improve sustainability. The proposed development would also commit to a Travel Plan Framework that would provide Residential Metrocards for each of the proposed households, so that the use of sustainable transport is maximised for potential residents of the development.

4.5 Other sites identified within the plan to the south of Hipperholme have also been appraised. These sites include LP Site Refs LP1077, LP1116, LP1075, and LP0334 and are all allocated for housing within the draft Local Plan. There are serious highway related issues with these sites as demonstrated at Appendix D.

Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

5.0 Traffic Impact

5.1 The traffic generation of the potential development of 80 dwellings has been determined using the National TRICS database. From the TRICS data it is identified that the proposed development would generate 45 traffic movements during the peak hour, with 12 traffic movements arriving at the site and 33 traffic movements exiting the site.

5.2 To quantify the traffic impact the development would have on the A644 Denholme Gate Road and subsequently the A58 junction, all of the traffic movements to and from the site have been applied to the Northedge Lane/ Denholme Gate Road junction, providing a robust impact assessment. From the traffic survey it has been identified that 559 vehicles travelled southbound and 518 vehicles travelled northbound. Using these flow proportions it has been determined that 17 and 16 vehicles would turn from Northedge Lane onto Denholme Gate Road to the south and north respectively.

5.3 However, to accurately determine the proposed distribution of development traffic it has been necessary to interrogate the official labour market statistics from the Office for National Statistics for the location of usual residence and place of work based on the 2011 Census. The output can be found at Appendix E. From the 2011 Census information the trip distribution has been determined at the Northedge Lane/ Denholme Gate Road junction with 37% travelling north and 63% travelling south towards the A644/ A58 signalised junction. The proposed traffic flows and distribution can be found at Appendix F.

5.4 Therefore, the 21 vehicle movements travelling south towards the A58 junction from the site would equate to around 3% increase in traffic along Denholme Gate Road arm of the A58/ A644 junction, which equates to an average of one additional vehicle movement every 3 minutes. It should also be noted that the turning movements at the A58/ A644 signalised junction associated with the proposed development would be single figures on each arm as demonstrated on the traffic flow diagram at Appendix F. TD 41/ 95 ‘Geometric Standards for Direct Access’ within Design Manual for Roads and Bridges states “Any application which results in a material increase in the volume of traffic or a material change in the type of traffic entering or leaving the trunk road shall be carefully considered. Generally, a material increase is considered to be if the turning traffic flows, as a result of the new development, would increase by 5% or more”. It is apparent from the findings above that the development traffic would provide an increase of 3% at the most along Denholme Gate Road and its junction with the A58, with very low increases on all other arms of the A58/ A644 signalised junction.

Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

5.5 Therefore, such levels of increase would not be discernible from the daily fluctuations in flows that exist on Denholme Gate Road including its junction with the A58 and are neither material nor significant in terms of residual impact (paragraph 32 of the NPPF refers).

5.6 From the above it can be determined that the development would generate a very low non-material increase in traffic on Denholme Gate Road and very low increases on all other arms of the A58/A644 junction. Therefore, the potential development cannot have a significant impact on the road network and would not create a demonstrable detrimental impact on the A58/A644 as referred to by the Council’s Local Plan Site Assessment (Site Ref LP1109). Given the surrounding highway infrastructure which includes a nearby class 1 highway (A644) and that a suitable access point is proposed which would provide a safe arrangement onto Northedge Lane with highway improvements, which is a very lightly trafficked highway, then the potential development of 80 dwellings would be acceptable in traffic generation terms, and would not significantly add to congestion at nearby junctions (especially the A58/ A644 signalised junction) during the network peak periods, as the impact would not represent a material increase in traffic.

5.7 Considering that the site is located within a sustainable location adjacent to the local bus services and within the accepted cycling distance of access to a railway station, and the proximity of local schools, the traffic generation has the potential to be less than that normally predicted for a development of this size. The sites sustainable location would provide the opportunity to formulate a robust Travel Plan Framework as part of the potential development, which would promote sustainable transport initiatives such as encouraging the use of public transport, walking and cycling, and could offer incentives to reduce single occupancy private car use such as a commitment to fund the Residential Metrocard scheme for each household within the development. The Travel Plan would provide targets to reduce journeys by car, and could easily be used to mitigate against any perceived impact the development would have on the A58/ A644 junction.

5.8 The potential development would also result in a significant improvement along the site frontage of Northedge Lane with the provision for carriageway widening and a footway along the development side of the major road. The highway improvements would also result in significant benefits to drivers accessing and egressing the adjacent cul-de-sac known as Groveville in relation to visibility and accessibility.

Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

5.9 It is considered that the level of traffic generated by the potential development can be accommodated on the surrounding highway network, and cannot have a significant impact on the road network given the unnoticeable increase in traffic along Denholme Gate Road, and would certainly not create a demonstrable detrimental impact on the A58/A644 as referred to by the Council’s Local Plan site assessment (Site Ref LP1109). Therefore, coupled with the highway improvements and commitment to provide a Travel Plan, the development would have no material impact upon the Northedge Lane, the A644 Denholme Gate Road or its junction with the A58.

Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

6.0 Calderdale Council’s Local Plan (Initial Draft) – Suggested Housing Sites

6.1 As stated within paragraph 4.5, four alternative sites are suggested for housing use within Calderdale Council’s Local Plan (Initial Draft), which include LP1077 Southedge Quarry, LP1116 Brighouse Road, LP0334 Lightcliffe Works, and LP1075 St Giles Road. These sites contain a number of issues as described below: -

LP1077 Southedge Quarry, Brighouse Road • Based on 30 dwellings per ha, the 13.02ha site would result in a development of around 390 dwellings providing a traffic generation of circa 240 trips during the network peak period and over 2000 vehicle trips during the day. This would equate to approximately 120 vehicles travelling towards the A58/ A644 junction during the peak periods, and would easily present an increase in turning movements at the junction greater than 5% of the total turning movements. Therefore, this would provide a substantial material increase in traffic congestion at this junction as no suitable mitigation is offered. • Site Assessment Report states that there is a preference against an access off the A644. There is no suitable access available without involving third party ownership. Even if third party land is secured Station Road provides an unacceptable route given the poor junction alignment at the Tanhouse Hill/ A58 junction.

LP1116 Brighouse Road • The site cannot be safely accessed from the A644 given the alignment of the road. Visibility splays of 2.4m x 90m are required on both sides of any potential access (in accordance with Design Manual for Roads and Bridges for 30mph speed limit roads), which cannot be achieved. • The Site Assessment Report states that access directly off the A644 would not be acceptable. Therefore, site is only possible for access from the private Crosslee access road, which involves land in third party ownership

LP0334 Lightcliffe Works, Halifax Road • Based on 30 dwellings per ha, a site area of 3.50ha would result in a traffic generation of circa 64 trips during the network peak hours and 550 movements during the day. This would equate to approximately 32 vehicles travelling towards the A58/ A644 junction during the peak periods, and it is envisaged would present an increase in turning movements at the junction at or over 5%. Therefore, this would provide a material increase in traffic congestion at this junction as no suitable mitigation is offered.

Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

LP1075 Land at St Giles Road, Lighcliffe • Visibility at the site access with St Giles Road falls substantially short of the required 2.4m x 43m on both sides for 30mph speed limit roads in accordance with Manual for Streets. This shortfall cannot be mitigated by improvements given the road layout of St Giles Road. Therefore, safe access cannot be provided. • Visibility at the junction with St Giles Road and A649 falls short of the required 2.4m x 90m as required for 30mph speed limits within Design Manual for Roads and Bridges. The 90m splay to the west overruns eastbound traffic lane, substantially reducing visibility. Therefore, safe access cannot be provided from the A649. • The site cannot share access with the site to the west (LP1116) given that this would involve third party land.

6.2 As can be seen from the above, there are a number of highways issues associated with the alternative sites with no mitigation measures offered. It should also be noted that visibility is a cause for concern for LP1075 and LP1116 and cannot be resolved given road alignment. LP1077 and LP0334 would present an overall increase in turning movements at the A58/ A644 junction that would provide a material impact at the junction. Therefore, the alternative sites would present an overall severe cumulative impact on the surrounding highway network.

Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

7.0 Conclusion

7.1 This site appraisal considers the existing infrastructure, transport sustainability, and traffic impact of a potential residential development of circa 80 new dwellings on land at Northedge Lane, Hipperholme.

7.2 It is considered that the potential site is in a sustainable location being within close proximity of the nearest bus stops and within cycling distance of the rail station at Halifax and within acceptable walking distance of the local services and amenities within Hipperholme. Within cycling distance of the site there are leisure amenities, educational institutions, and industrial and employment areas. Therefore the site conforms to current Government directives for ensuring developments are located in a sustainable locations.

7.3 There are a number of highways issues associated with the alternative sites within Calderdale Council’s Local Plan (Initial Draft), with no mitigation measures offered. It should also be noted that visibility is a cause for concern for LP1075 and LP1116 and cannot be resolved given road alignment. LP1077 and LP0334 would present an overall increase in turning movements at the A58/ A644 junction that would provide a material impact at the junction. Therefore, the alternative sites would present an overall severe cumulative impact on the surrounding highway network.

7.4 Considering that the site is located within a sustainable location adjacent to the local bus services and within the accepted cycling distance of access to a railway station, the proximity of local schools, and the commitment to provide a Travel Plan and Residential Metrocards, the traffic generation would have the potential to be less than that normally predicted for a development of this size. It is considered that the level of traffic generated by the potential development can be accommodated on the surrounding highway network, and cannot have a significant impact on the road network given the unnoticeable increase in traffic along Denholme Gate Road, and would certainly not create a demonstrable detrimental impact on the A58/A644 as referred to by the Council’s Local Plan site assessment (Site Ref LP1109). Therefore, coupled with the highway improvements the development would have no material impact upon the Northedge Lane, the A644 Denholme Gate Road or its junction with the A58. The potential development would also result in a significant improvement along the site frontage of Northedge Lane with the provision for carriageway widening and a footway along the development side of the major road. The highway improvements would also result in significant benefits to drivers accessing and egressing the adjacent cul-de-sac known as Groveville in relation to visibility and accessibility.

Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

File ref: 1132C Date: May 2018

Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

Appendix A

Location plan and bus stop locations

Untitled map

Untitled layer

Site Bus stop Bus stop Bus stop Bus stop

SITE LOCATION

UNIT 2, THE OFFICE CAMPUS, BUS STOP LOCATION PARAGON BUSINESS PARK, RED HALL COURT, WAKEFIELD WF1 2UY Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

Appendix B

Pedestrian and Cycle Catchment Plan

Latitude 53.731499 Longitude -1.811650

5km CYCLE CATCHMENT

2km WALKING CATCHMENT

UNIT 2, THE OFFICE CAMPUS, SITE LOCATION PARAGON BUSINESS PARK, RED HALL COURT, WAKEFIELD WF1 2UY Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

Appendix C

Peak Hour Traffic Survey

C A From Leeds Road Location Northedge Lane Hipperholme B From Shelf A644 Date 13/6/2017 B A C Northedge Lane

A - B A - C B - A B - C C - A C - B Time Start Car LGV HGV Car LGV HGV Car LGV HGV Car LGV HGV Car LGV HGV Car LGV HGV 7:30 - 7:45 102 26 4 3 0 0 145 14 2 3 0 0 0 2 1 2 0 0 7:45 - 8:00 105 31 4 1 0 1 149 5 1 8 1 0 4 0 0 0 0 0 8:00 - 8:15 99 28 1 1 1 0 110 6 9 1 0 0 6 1 0 3 0 0 8:15 - 8:30 103 10 5 0 0 0 110 5 3 1 0 0 7 2 0 2 1 0 8:30 - 8:45 100 18 4 1 0 0 109 11 4 4 0 1 17 2 0 1 0 0 8:45 - 9:00 98 15 8 2 1 0 100 4 3 3 0 0 5 0 0 0 0 0 9:00 - 9:15 83 33 2 3 0 0 128 3 6 1 0 0 2 2 0 2 0 0 9:15 - 9:30 75 19 2 1 0 0 100 3 3 1 0 0 2 0 0 1 0 0 Total 765 180 30 12 2 1 951 51 31 22 1 1 43 9 1 11 1 0 Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

Appendix D

Alternative Housing Sites – Draft Local Plan

Suggested Housing Sites for Calderdale Council’s Local Plan – Initial Draft

LP Site Ref Description Highways Related Issues LP1077 Southedge Quarry, • Based on 30 dwellings per ha, would result in a traffic Brighouse Road, generation of circa 240 trips during the network peak Hipperholme – site area period and over 2000 during the day. This would 13.02ha equate to approximately 120 vehicles travelling towards the A58/ A644 junction during the peak periods, and would easily present an increase in turning movements at the junction over 5%. Therefore, this would provide a substantial material increase in traffic congestion at this junction as no suitable mitigation offered. • Site Assessment Report states preference against access off the A644. There is no suitable access available without involving third party ownership. Even if third party land is secured Station Road provides an unacceptable route given the poor junction alignment at the Tanhouse Hill/ A58 junction. LP1116 Brighouse Road, • The site cannot be safely accessed from the A644 Hipperholme – site area given the alignment of the road. Visibility splays of 1.83ha 2.4m x 90m are required on both sides of any potential access (in accordance with Design Manual for Roads and Bridges for 30mph speed limit roads), which cannot be achieved. • Site Assessment Report states access directly off A644 would not be acceptable. Therefore, site is only possible for access from the private Crosslee access road, which involves land in third party ownership. LP0334 Lightcliffe Works, Halifax • Based on 30 dwellings per ha, would result in a traffic Road, Hipperholme – site generation of circa 64 trips during the network peak area 3.50ha hours and 550 movements during the day. This would equate to approximately 32 vehicles travelling towards the A58/ A644 junction during the peak periods, and it is envisaged would present an increase in turning movements at the junction at or over 5%. Therefore, this would provide a material increase in traffic congestion at this junction as no suitable mitigation is offered. LP1075 Land at St Giles Road, • Visibility at the site access with St Giles Road falls Lightcliffe – site area substantially short of the required 2.4m x 43m on 0.59ha both sides for 30mph speed limit roads in accordance with Manual for Streets. This shortfall cannot be mitigated by improvements given the road layout of St Giles Road. Safe access cannot be provided. • Visibility at the junction with St Giles Road and A649 falls short of the required 2.4m x 90m as required for 30mph speed limits within Design Manual for Roads and Bridges. The 90m splay to the west overruns eastbound traffic lane, substantially reducing visibility. Safe access cannot be provided. • Cannot share access with site to the west (LP1116) given that this would involve third party land.

Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

Appendix E

Location of Usual Residence and Place of Work

ABCDEFG 1 WU03EW - Location of usual residence and place of work by method of travel to work (MSOA level) 2 ONS Crown Copyright Reserved [from Nomis on 18 May 2018] 3 4 population 5 units 6 date 7 method of travel to work 8 9

place of work E02002254 : Calderdale 011 10 11 E02002244 : Calderdale 001 15 12 E02002245 : Calderdale 002 6 13 E02002246 : Calderdale 003 35 14 E02002247 : Calderdale 004 9 15 E02002248 : Calderdale 005 14 16 E02002249 : Calderdale 006 13 17 E02002250 : Calderdale 007 16 18 E02002251 : Calderdale 008 374 19 E02002252 : Calderdale 009 2 20 E02002253 : Calderdale 010 16 21 E02002254 : Calderdale 011 167 22 E02002255 : Calderdale 012 70 23 E02002256 : Calderdale 013 3 24 E02002257 : Calderdale 014 21 25 E02002258 : Calderdale 015 112 26 E02002259 : Calderdale 016 26 27 E02002260 : Calderdale 017 20 28 E02002261 : Calderdale 018 35 29 E02002262 : Calderdale 019 163 30 E02002263 : Calderdale 020 14 31 E02002264 : Calderdale 021 63 32 E02002265 : Calderdale 022 1 33 E02002266 : Calderdale 023 19 34 E02002267 : Calderdale 024 22 35 E02002268 : Calderdale 025 95 36 E02002269 : Calderdale 026 13 37 E02002270 : Calderdale 027 10 38 E02002271 : Kirklees 001 12 39 E02002272 : Kirklees 002 15 40 E02002273 : Kirklees 003 13 41 E02002274 : Kirklees 004 1 42 E02002275 : Kirklees 005 25 43 E02002276 : Kirklees 006 2 44 E02002277 : Kirklees 007 3 45 E02002278 : Kirklees 008 4 46 E02002279 : Kirklees 009 2 47 E02002280 : Kirklees 010 2 48 E02002281 : Kirklees 011 6 49 E02002282 : Kirklees 012 1 50 E02002283 : Kirklees 013 1 51 E02002284 : Kirklees 014 1 52 E02002285 : Kirklees 015 6 53 E02002286 : Kirklees 016 7 54 E02002287 : Kirklees 017 8 55 E02002288 : Kirklees 018 0 56 E02002289 : Kirklees 019 1 57 E02002290 : Kirklees 020 0 58 E02002291 : Kirklees 021 3 59 E02002292 : Kirklees 022 8 60 E02002293 : Kirklees 023 6 61 E02002294 : Kirklees 024 6 62 E02002295 : Kirklees 025 12 63 E02002296 : Kirklees 026 5 64 E02002297 : Kirklees 027 4 65 E02002298 : Kirklees 028 0 ABCDEFG 66 E02002299 : Kirklees 029 47 67 E02002300 : Kirklees 030 2 68 E02002301 : Kirklees 031 6 69 E02002302 : Kirklees 032 1 70 E02002303 : Kirklees 033 15 71 E02002304 : Kirklees 034 15 72 E02002305 : Kirklees 035 0 73 E02002306 : Kirklees 036 1 74 E02002307 : Kirklees 037 1 75 E02002308 : Kirklees 038 3 76 E02002309 : Kirklees 039 8 77 E02002310 : Kirklees 040 0 78 E02002311 : Kirklees 041 0 79 E02002312 : Kirklees 042 15 80 E02002313 : Kirklees 043 3 81 E02002314 : Kirklees 044 4 82 E02002315 : Kirklees 045 1 83 E02002316 : Kirklees 046 0 84 E02002317 : Kirklees 047 0 85 E02002318 : Kirklees 048 1 86 E02002319 : Kirklees 049 5 87 E02002320 : Kirklees 050 2 88 E02002321 : Kirklees 051 5 89 E02002322 : Kirklees 052 0 90 E02002323 : Kirklees 053 2 91 E02002324 : Kirklees 054 1 92 E02002325 : Kirklees 055 1 93 E02002326 : Kirklees 056 4 94 E02002327 : Kirklees 057 1 95 E02002328 : Kirklees 058 1 96 E02002329 : Kirklees 059 3 97 E02002183 : Bradford 001 0 98 E02002184 : Bradford 002 3 99 E02002185 : Bradford 003 0 100 E02002186 : Bradford 004 2 101 E02002187 : Bradford 005 0 102 E02002188 : Bradford 006 2 103 E02002189 : Bradford 007 0 104 E02002190 : Bradford 008 5 105 E02002191 : Bradford 009 1 106 E02002192 : Bradford 010 2 107 E02002193 : Bradford 011 1 108 E02002194 : Bradford 012 0 109 E02002195 : Bradford 013 1 110 E02002196 : Bradford 014 0 111 E02002197 : Bradford 015 2 112 E02002198 : Bradford 016 1 113 E02002199 : Bradford 017 1 114 E02002200 : Bradford 018 4 115 E02002201 : Bradford 019 1 116 E02002202 : Bradford 020 14 117 E02002203 : Bradford 021 0 118 E02002204 : Bradford 022 3 119 E02002205 : Bradford 023 0 120 E02002206 : Bradford 024 0 121 E02002207 : Bradford 025 3 122 E02002208 : Bradford 026 0 123 E02002209 : Bradford 027 0 124 E02002210 : Bradford 028 0 125 E02002211 : Bradford 029 1 126 E02002212 : Bradford 030 2 127 E02002213 : Bradford 031 5 128 E02002214 : Bradford 032 1 129 E02002215 : Bradford 033 4 130 E02002216 : Bradford 034 5 131 E02002217 : Bradford 035 5 ABCDEFG 132 E02002218 : Bradford 036 2 133 E02002219 : Bradford 037 24 134 E02002220 : Bradford 038 11 135 E02002221 : Bradford 039 68 136 E02002222 : Bradford 040 0 137 E02002223 : Bradford 041 5 138 E02002224 : Bradford 042 0 139 E02002225 : Bradford 043 3 140 E02002226 : Bradford 044 24 141 E02002227 : Bradford 045 28 142 E02002228 : Bradford 046 13 143 E02002229 : Bradford 047 1 144 E02002230 : Bradford 048 23 145 E02002231 : Bradford 049 5 146 E02002232 : Bradford 050 3 147 E02002233 : Bradford 051 6 148 E02002234 : Bradford 052 1 149 E02002235 : Bradford 053 14 150 E02002236 : Bradford 054 6 151 E02002237 : Bradford 055 3 152 E02002238 : Bradford 056 6 153 E02002239 : Bradford 057 19 154 E02002240 : Bradford 058 11 155 E02002241 : Bradford 059 21 156 E02002242 : Bradford 060 36 157 E02002243 : Bradford 061 15 158 Barnsley 5 159 Craven 6 160 Doncaster 2 161 East Riding of Yorkshire 3 162 Hambleton 1 163 Harrogate 3 164 Kingston upon Hull, City of 1 165 Leeds 246 166 North East Lincolnshire 0 167 North Lincolnshire 0 168 Richmondshire 1 169 Rotherham 3 170 Ryedale 0 171 Scarborough 0 172 Selby 0 173 Sheffield 9 174 Wakefield 54 175 York 12 176 2,419 Potential Residential Development, Northedge Lane, Hipperholme Highway Site Appraisal

Appendix F

Traffic Flows & Distribution