first planning application submitted

We expect that Calderdale Council’s planning committee will soon consider the first planning application for the Thornhills Garden Suburb.

 The proposal is for 308 dwellings at the most isolated part of the site; whilst we may believe the entire proposal is flawed, phase 1a demonstrates everything we have stated for the last nine years.

Here’s what some of the government, local and statutory consultees have to say about the proposals:

active travel england

Deferral – This is Active Travel England’s (ATE) first involvement with the site, does not demonstrate sustainable transport as per NPPF. This application for the first phase of development however is a “stand-alone” residential scheme, which in the context of existing infrastructure, would have poor pedestrian, cycle and public transport access to nearby schools and local amenities and as such will fail to incentivise active journeys to and from the site and offer ‘a genuine choice of transport modes’ to encourage sustainable travel as required by the NPPF Transport 

Assessment info limited to peak hours based on 2011 census data. Route assessment to St John’s Primary, Brighouse Town Centre and Clifton Business Park has deficiencies; no analysis of primary active travel routes to and from the site. 

ATE consider pedestrian access to local amenities to be poor with access to the nearest primary school (approx. 1.2km away) alongside a poorly lit, 60mph A-road with uncontrolled crossings. 

The TA suggests the amenities of Brighouse town centre are a 20-25 minute walk from the site. A car-dependent development. In assessing access to public transport ATE consider whether all buildings are within 400m of a high-frequency bus stop or 800m of a rail/light rail station or tram stop, with appropriate facilities, using a well-designed route. 

It is noted that there are no bus stops in the vicinity of the site frontage with the nearest stop located approx. 650km from the site entrance however from dwellings within the site this distance increases. Brighouse Railway Station is located approximately 2km from the centre of the site. A643 upgrades directly relevant.

Criticsm of road layout, not deisgning side roads to provide level crossings along cycleways and footways. 

ATE states modal shift of 10% from cars (taken from 2011 census) is ‘unambitious’ considering government objective is 50% of all town and city trips to be walked, wheeled or cycled by 2030.

Targest need to be informed by all-day, multi modal trip generation analysis.

local flood authority

Further information is required before proposals can be agreed: 

Soakways are not viable. No construction surface water management plans or hydraulic modelling results were submitted, drainage design for permeable paving areas required, and greenfield runoff rates require further assessments using the latest Flood Estimation Handbook. 

Separate foul and surface water drainage systems must be provided. Drainage plan layout drawing required, drawing showing ownership and maintenance plan for the lifetime of development required, drawing required showing 1 in 30 year (plus allowance for climate change) flood exceedance routes

national highways

Planning permission not be granted: Review of the transport assessment and travel plan identified several areas where further information or additional work, is required: Unclear if TA considers DfT circular of delivery of Sustainable development.

Personal Injury Collision data re-calculated excluding COVID-19 restriction years

TA promotes non-car travel, but large allocation of parking spaces on site isn’t a deterrent

TA not applied from start of development

M62 J25 trip routing different to earlier data

Calderdale to confirm all committed developments within study area identified

WYCA should confirm likelihood of Cooper Bridge improvements and factor into assessments

Improvements at J25 for Clifton Business Park referred to, but not clear if calculated in the assessment

Assesment on J25 queuing (based on only one day’s data) not accepted by Nat Highways

No evidence A644/Clifton Business Park/Spine Road junction queues will not impact vehicles leaving M62 J25

calderdale highways

The proposals need to be in accordance with the Masterplan and Design Codes produce for the Thornhills Garden Community.

First phase is separated and remote from town centre, with poor connectivity on foot and cycle. A641 Highmoor Lane not suitable route for pedestrians or cyclists, particuarly a site that will form part of a garden community. the route and distance to existing public transport falls well below the standards required for a new development.

The nearest community is Clifton to the south. The footway on the length between the site and Clifton is unlit. The narrow footway on the upper section is separated from fast traffic by a narrow verge. Further south the footway is switches to the east side of Highmoor Lane. That is also below 2m wide in sections and has no streetlighting. 

Pedestrians would have to cross the A643 where the footway switches sides, with no crossing facility apart from dropped kerbs. This route would be used to access a primary school and public houses in the village.

Surprisingly the TA states that this route is suitable for pedestrians and cyclists. There is agreement with the comments in the Active Travel England (ATE) response on pedestrian and cycle access that this is presently poor, and that it is incumbent on the applicant to show how the deficiencies can be overcome.

The environment for pedestrians and cyclist is also poor further west along the A643 where it meets the A644 Wakefield Road.

Clifton Business Park access road requires further details, and should be secured by a planning condition that these in place before dwellings occupied. 

A641:A key element with respect to this application is the area immediately east of the A641 where the A643 Clifton Common and A644 Wakefield Road converge at a small roundabout. The current layout operates at capacity in peak periods with significant queuing and delays.

Existing footways to and from the site and key Brighouse locations are substandard.

Poor environment for cyclists, no cycle lanes and cyclists are very exposed on junction approaches becuase of widths and high proportion of HGVs. 

Public transport: School bus does not pass the site (700m walk from closest dwelling and over 1km from north and west parts) – significantly more than 400m maximum walking distance for bus access.

Traffic impact: traffic growth only applied to HGV movements; CLifton Business Park not included in list of committed developments. No traffic assigned to Heartshead Moor Top eastern arm, Only 14% of trips onto A644 Wakefield Road. 

The A641/A643/A644 junction has not been modelled despite around 100 additional vehicles expected in the peak hours

calderdale housing

Only 76 affordable dwellings, reduced because including bungalows. Housing mix is ‘a significant deviation away from the strategic housing market assessment. No evidence for reduction in 2-bed dwellings. Reduce 3 bed numbers and increase of 2 bed houses.

west yorkshire police

5 concerns highlighted where plans deviate from secured by design

natural england

No objection because the plans will not have a significant adverse impact on protected nature conservation sites or landscapes

calderdale biodiversity

No data from Calderdale Bird Conservation Group, despite being specific in pre-application advice. River Condition Assessment undertaken outside of optimal time, no details of earlier assessments and if ‘they are adequate’

clifton forum

Refuse until issues around Transport, Housing density, Housing mix, Collaboration among landowners, Travel plan and sustainable travel arrangements, Open space, LEAP and NEAP provision, Site layout, Three-storey building on Jay House Lane/Highmoor Lane and Construction issues resolved

sports england

The site layout plans does not show the provision of any formal sports provision to meet the new demand for sport that will arise from the development. The population of the proposed development is estimated to be 727 (rounded up) based on the average occupancy rate of 2.36 people per dwelling. This additional population will generate additional demand for sports facilities. If this demand is not adequately met then it may place additional pressure on existing sports facilities, thereby creating deficiencies in facility provision. In accordance with the NPPF, Sport England seeks to ensure that the development meets any new sports facility needs that arise as a result of the development. The Sports Facilities Calculator indicates that a population of 727 in this local authority area will generate a demand for a total of £303,954. Sport England objects to this application as it does not provide new sport facilities to meet demand nor have the principles of Active Design been demonstrated.