Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

4.28 Preferred Option – EN4: Historic Environment

Introduction

4.28.1 The Bradford District has a rich and diverse historic and natural environment which is evident in the survival of heritage assets from traces of the Bronze Age on Rombalds Moor to its industrial heritage of grand mills and associated developments from the late 18th and 19th centuries. Bradford City itself is one of England's great stone cities, with impressive Victorian neighbourhoods such as Manningham as well as Saltaire World Heritage Site and other notable heritage assets. The historic environment is unique and varied and greatly contributes to the identity, character and distinctiveness of the District as well as the quality of life of residents and the local and regional economy through leisure, culture and tourism attractions.

4.28.2 The historic environment faces a number of challenges resulting from minor, incremental alterations to significant and damaging changes which can affect the nature and authenticity of the structure or space. In most cases these changes are controlled by the Council through planning consents, however harm to the significance of heritage assets can also occur through neglect, lack of maintenance or small incremental changes which can, over time erode the character of these assets.

4.28.3 The District with its proud legacy of mills and industrial heritage presents a strong opportunity for the sensitive re-use and regeneration at a strategic and bold scale in some instances witnessed through the development of schemes such as Lister Mills. Viability may be challenging in some instances with a need for an holistic and wider area based approach to create the right investment and liveability context for the re-use of these important assets which punctuate the skyline of Bradford and many of its towns and villages.

Protecting Heritage and Balancing Growth

4.28.4 With the need for growth, new housing and new jobs over the plan period the District faces significant challenges – protecting its historic assets but accommodating sensitively located and well-designed development. It is essential that the Local Plan through Policy EN4 provides a positive strategy for the historic environment since protecting and enhancing the historic environment is one of the Government's core objectives in the promotion of sustainable development.

4.28.5 Policy EN4 contributes towards Local Plan Strategic Objective 12 and links to the following policies SP2, SP10, TR4 and EN5. The Council will work with partners, including landowners, agents, developers, local organisations and local communities to ensure that the implementation of Policy EN4 delivers the key strategic objective 12 of this plan to 'Safeguard, enhance and promote the diverse historic built and natural heritage of the District which helps reinforce the local distinctiveness of places.

4.28.6 The term 'heritage assets' refers to historical buildings, places and structures which form parts of the wider historic environment of the Bradford District. It includes designated and non-designated heritage assets which are set out further below:

Saltaire World Heritage Site

4.28.7 Of international, national, regional and local importance to the District is Sir Titus Salt's model village of Saltaire in Shipley built between 1851 and 1876, which was inscribed as a World Heritage Site by UNESCO in 2001. The village is a remarkably well preserved and outstanding example of a Victorian model industrial village. The regeneration of the village from the mid-1980s to the present day is an exemplar of regeneration through heritage.

4.28.8 World Heritage Sites are places of Outstanding Universal Value (OUV) to humanity, as set out in the 1972 UNESCO Convention Concerning the Protection of the World Cultural and Natural Heritage (the World Heritage Convention). The OUV of Saltaire World Heritage Site was defined in a retrospective Statement of Outstanding Universal Value adopted by the World Heritage Committee in 2010. Saltaire's OUV is embodied in its authenticity and integrity of its physical attributes including its river valley location, distinctive grid layout, the high quality and uniformity of its architecture and the range of amenities provided by Sir Titus Salt, which still provide for the village's thriving residential, business and student communities and attracts visitors from across the globe.

4.28.9 Criterion A and B of the policy seek to ensure the long term protection of the World Heritage Site. Any development proposals within or adjacent to the World Heritage Site and its buffer zone must have regard to Policy EN4 and be informed by the revised World Heritage Site Management Plan, the World Heritage Site Environmental Capacity Study and the Saltaire Conservation Area Appraisal.

Designated Heritage Assets

4.28.10 The Bradford District contains a vast array of designated historic assets which when viewed as an entity, form the essential characteristics of local distinctiveness and environmental identity. These elements are highly valued today for the positive contribution they make to the quality of the environment as well as for benefits to the local economy and tourism, in particular these include:

• Saltaire World Heritage Site
• 2,291 listed buildings, including 23 Grade I and 69 Grade II*
• 59 Conservation Areas
• 16 Historic Parks and Gardens
• 196 Scheduled Monuments
• 1 Historic Battlefield Site at Adwalton Moor, Tong

4.28.11 Criterion D and E of the policy seek to ensure the protection and enhancement of Listed Buildings. There are a number of heritage assets within the District which have fallen into a state of disrepair and are at risk of being lost. 27 of these assets feature on Historic England's 'Heritage at Risk' register, as of 2020. It is a priority for the Council to ensure that these assets are sensitively protected, conserved and brought back into a viable use. Where appropriate, heritage assets at risk will be secured through planning conditions and obligations.

4.28.12 Where support is given to development proposals which result in harm to designated or undesignated heritage assets, in advance of commencement of development the local planning authority may require by planning condition, the implementation of a programme of archaeological recording to the satisfaction of the authority's archaeological advisors.

Non Designated Heritage Assets

4.28.13 The Bradford District contains many other heritage assets in the form of buildings, structures, archaeological and below ground remains that are, as yet, undiscovered that are of local historic and conservation importance. These include local parks and gardens including: Heber's Ghyll; Milner Field; Cliffe Castle and Devonshire Park; and Bierley Hall Wood. Bradford's Conservation Area Assessments and Appraisals identify key unlisted buildings and structures within these conservation areas.

4.28.14 Criterion F of the policy recognises the important contribution that non-designated heritage assets can have within a local area. Although these assets are not afforded the same statutory level of protection through designation, they can make a significant positive contribution to the character and appearance of the area in which they are situated. In accordance with the NPPF non-designated heritage assets are subject to the objectives and policies within this strategy.

4.28.15 Criterion C and F of the policy seek to ensure the protection and enhancement of all heritage assets. In support of this policy, the Council requires development proposals affecting a heritage asset to be accompanied by a Heritage Statement which should demonstrate a full understanding of the significance of the asset and any mitigation measures that are required. Proposals will be expected to respect and reinforce the distinctive character of the asset and its setting. Account should be taken of the guidance adopted by the Council, particularly Conservation Area Assessments/ Appraisals and other guidance documents.

4.28.16 The link between regeneration and the built historic environment is strong and the two are not mutually exclusive. Criterion H of the policy recognises the important role the historic environment can play in regeneration schemes. There have been a number of successful schemes in recent years, particularly in the city centre and principal towns. Whilst heritage focused regeneration opportunities must be encouraged, restoration and re-use of heritage assets for the specific benefit of their significance must also be supported.

4.28.17 Policy EN4 contributes towards Local Plan Strategic Objective 12 and links to the following policies SP2, SP10, TR4 and EN5.

Reasonable Alternatives – EN4: Historic Environment

• No alternatives considered - the policy is considered comprehensive in scale and no reasonable alternatives has been considered.

(154) Consultation Question 42

4.29 Preferred Option – EN5: Landscape

Introduction

4.29.1 The European Landscape Conventions definition of landscape is 'an area, as perceived by people, whose character is the result of the action and interaction of natural and/or human factors'. One of the definitions of landscape in 'The Guidelines for Landscape and Visual Impact Assessment' is as follows:

'Landscape results from the interplay of the physical, natural and cultural components of our surroundings. Different combinations of these elements and their spatial distribution create the distinctive character of landscapes in different places, allowing different landscapes to be mapped, analysed and described.'

4.29.2 Natural England emphasises that England's landscapes are valued by people for a variety of reasons and each is characterised by its own pattern of geology, landform, soils, vegetation, land use and human settlement, which creates local distinctiveness.

Bradford District Landscape Character

4.29.3 Natural England has defined a series of National Character Areas for England. The three main character areas which cover the Bradford District include: the Southern Pennines, the Yorkshire Southern Pennine Fringe and the Nottinghamshire, Derbyshire and Yorkshire Coalfield. The Millstone Grits of the Southern Pennines to the west of the District give rise to substantial areas of upland heath and blanket bog. In contrast, the coalfield areas of Bradford are more dominated by urban influences, and the rapid expansion of industry, settlement and transport networks interspersed by woodlands and valley wetlands.

4.29.4 Significant areas of the District form part of the Yorkshire Southern Pennine Fringe, a transition zone, characterised by gritstone industrial settlements in the valleys surrounded by pastoral agriculture in the foothills. The gritstone terraces and stone walls of the pasture give a visual unity to the landscape.

4.29.5 The landscape character analysis starts to make the link between the features and appearance of the landscape with the ecosystems services it provides. The District contains internationally important mosaics of moorland habitats which support rare bird species and are also important in relation to water supply with many reservoirs providing water for nearby conurbations. This dramatic landscape offers a sense of escapism for those living in the urban areas and inspired the writing of the Brontes.

Safeguarding and Protecting Landscape Character

4.29.6 The purpose of Policy EN5 is to safeguard and enhance the character of local landscapes and the setting of settlements within the district and essentially rolls forward policy EN4 from the adopted Core Strategy with very minor changes.

4.29.7 It is essential to maintain and enhance valued and distinctive landscapes in circumstances when in order to accommodate growth in the District's population, greenfield sites are being put forward for development and a need for local green belt releases has been identified in the Local Plan. Work that describes and identifies the key component elements of local character needs to be used to determine potential locations for all types of development including housing, commercial uses, energy and transport infrastructure and minerals exploitation, and to appraise individual proposals. Changes in land management regimes can also have an impact on the landscape and need to be assessed.

4.29.8 A detailed landscape character assessment of Bradford District was carried out by the Council to support the RUDP, based upon the approach to distinct landscape character developed by Natural England and is now an adopted Landscape Character SPD. The descriptions of the different character areas and principles identified in the SPD will be used to inform decision-making and appraisal of proposals.

4.29.9 The SPD identifies ten specific, distinct and unique landscape character areas (see Figure 4.29.1), and sets out a description of each area. Important positive features and detractors are identified and an analysis provided of the areas sensitivity to change. Landscape character assessment allows proposals to be addressed in relation to the key characteristics, sensitivities and special qualities of a local landscape typology.

Figure 4.29.1

4.29.10 One of the distinctive qualities that landscapes of the South Pennines in Bradford District have are the locations, settlements, features and viewpoints that have cultural associations with the writings of the Brontes, who lived in Haworth. Rombalds Moor, settled since prehistoric times, and rich in remains (including numerous scheduled ancient monuments of carved rocks, burial mounds and stone circles) and the distinctive cow and calf rocks is also of significant value.

4.29.11 Landscape character assessments recognise the important role that boundary structures play in relation to the ecology, landscape and history of the District. Hedgerows and drystone walls can be threatened both directly by development decisions and indirectly when land use change leads to a more gradual process of neglect. Other historic elements in the landscape may relate to early agricultural systems and field patterns or to features linked to stages in the development of the textile industry, including trans-pennine routes and associated bridges and locks.

4.29.12 Work carried out at a district level by West Yorkshire Ecology to identify potential grassland, woodland, wetland and heathland habitat networks also forms part of the evidence base for this policy. The output maps from this work help to reinforce the importance of landscape features identified in character assessments, they can be used to focus the efforts of local authorities, key stakeholders and partners to maintain, restore and re-create landscapes and achieve biodiversity enhancement. Trees and woodlands throughout the District also play an important role in defining landscape character. Policy EN3 set out the approach to protecting trees and woodland.

4.29.13 The character of the Districts' landscape is therefore very varied, ranging from the rugged open moorland of the South Pennine uplands to rolling farmland, and open river valleys to wooded hillsides. The diversity of landscape character areas form an important element in Bradford's identity and the quality of life of its residents. The landscape backdrop is a significant influence on the character of individual settlements. Identified landscape character is therefore considered to be a key component of local distinctiveness that helps to create a 'sense of place'.

4.29.14 Within Bradford open moorland provides the backdrop to the wide shallow valleys of the rivers Aire and Wharfe, where locations along the moorland edge offer long extensive views. Within such an open landscape, in areas where there are few other structures, there is a need for extreme sensitivity in introducing vertical elements such as wind turbines within the wider landscape setting and protecting long range views where possible.

Policy Directions

4.29.15 The policy seeks to ensure that proposals for development and other projects, that could have an impact on the landscapes within the district, particularly, but not exclusively, those on the edge of settlements, contribute towards the management and enhancement of the District's landscapes, biodiversity and heritage resources.

4.29.16 The landscape policy contributes towards a range of other objectives, including the maintenance and restoration of habitats and the protection of historic assets (including parks and gardens) and their settings. The landscapes of the District are of tourism, leisure and recreational value and make a significant contribution to the appeal and character of the District. The policy has evolved in response to issues raised by consultees and the sustainability appraisal; key concerns were local distinctiveness, securing biodiversity gains and the need for landscape enhancement, particularly in the urban fringe. The issue of local distinctiveness is also addressed in Policy DS2: Working with the Landscape.

4.29.17 This policy reinforces the criteria identified in Policy SP10 in relation to elements that contribute towards Green Infrastructure. It complements the heritage policy EN4 in relation to historic elements in the landscape, the importance of setting and cultural associations. It has strong links with Policy EN2 relating to biodiversity as it also seeks to encourage greater connectivity and enhancement of habitats. Establishing ecological networks and landscape enhancement can achieve significant benefits for areas within the urban fringe where landscapes have been greatly influenced and/or degraded by human activity. In appropriate locations, protecting and linking belts of woodland can enhance the landscape and improve habitat connectivity. Reducing habitat fragmentation and increasing woodland cover can also make a contribution towards the District's resilience to climate change.

4.29.18 The NPPF supports the setting out of criteria based policies against which proposals for development affecting landscape will be judged and which give appropriate weight to the contribution made to wider ecological networks. Protecting and enhancing valued landscapes, geological conservation interests and soils is one of the means identified through which planning should make a contribution towards conserving and enhancing the natural environment. Planning policies and decisions should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes.

Reasonable Alternatives – EN5: Landscape

• No alternatives considered - the policy is succinct and grounded in the evidence base and SPD work and no reasonable alternatives have been considered.

(9) Consultation Question 43

4.30 Preferred Option – EN6: Countryside and Development

4.30.1 Outside the City of Bradford, there are significant areas of the District defined as countryside which are intrinsic to the identity of the area including the South Pennine Moors, the Airedale Valley and Wharfedale Valley. Several areas are recognised in national planning policy (SSSI and SPA/SAC) as they provide a valuable recreational resource as well as having landscape and biodiversity benefits.

4.30.2 Policy EN6 aims to protect the countryside and manage development in a way that supports rural communities and the rural economy whilst maintaining its essential attributes.

4.30.3 The countryside is defined as everywhere outside of the settlement boundaries and the majority of the designated countryside is identified as Green Belt through Policy SP5 which seeks to restrict further development. Any proposals in such areas will also have to be determined through the requirements of Policy SP5.

Reasonable Alternatives – EN6: Countryside and Development

4.30.4 The reasonable alternatives considered:

• No policy – which would leave some part of the district and countryside potentially unprotected.
• Integrate policy focus within landscape or other policy area – specific policy interest may not be effectively represented.

(150) Consultation Question 44

4.31 Preferred Option - EN7: Flood Risk

Introduction

4.31.1 The overall objectives of Policy EN7 are to appraise, manage and reduce the risk of flooding. The policy identifies the principles to guide the process of identifying locations for future development while seeking to reduce flood risk, assess proposals that come forward and adopt a positive approach to water management. Flood risk is defined in the PPG as: 'a combination of the probability and the potential consequences of flooding from all sources – including from rivers and the sea, directly from rainfall on the ground surface and rising groundwater, overwhelmed sewers and drainage systems, and from reservoirs, canals and lakes and other artificial sources'.

4.31.2 The NPPF requires Local Plans to take account of climate change over the longer term and plan new development to avoid increased vulnerability to the range of impacts arising from climate change. The sequential testing approach is supported and technical guidance has been produced setting out how this policy should be implemented. Key principles identified are; safeguarding land from development that is required, or likely to be required, for current and future flood management; using opportunities offered by new development to reduce the causes and impacts of flooding; and developing policies to manage flood risk from all sources. When applying sequential testing principles to the choice of sites for future development, where data exists, all sources of flood risk will be taken into account, including those associated with ground water flooding.

4.31.3 The Flood and Water Management Act 2010 has given Lead Local Flood Authorities responsibility for identifying sources of local flood risk and reducing the likelihood and impacts of local flooding. These sources include surface water run-off, groundwater and flooding from smaller rivers and streams. The Act ends the automatic right to connect surface water drains and sewers to the public sewerage system, with developers being required to use Sustainable Drainage Systems (SuDS) in new development, where practicable. Issues relating to the adoption and future maintenance of SuDS will need to be resolved by local authorities and developers.

4.31.4 The most important principle, in terms of managing risk, is that development should only be permitted in areas of high flood risk when no alternative land in areas of lower flood risk is available and the overall benefits of the development outweigh the risks from flooding. Risk should be reduced, at a strategic level, by safeguarding land from development that is required for flood water storage and defences, and using the opportunities offered by new development to incorporate SuDS, green infrastructure for water storage and the re-creation of the functional flood plain.

Local Environment

4.31.5 Bradford District includes the catchment areas of the River Aire and the River Wharfe, the latter forming a main river within the River Ouse catchment. Both the Aire and the Ouse play an important role in the future planning of neighbouring authorities within the Leeds City Region and beyond. The strategic level of appraisal that has been carried out to date, identifies flood risk as an important issue that needs to be addressed, particularly in the Regional City of Bradford and in Keighley and Ilkley.

4.31.6 The River Aire within Bradford District is characterised by a number of swift flowing upland streams which then flow down through the towns along the valley. The upper reaches of the River Aire within Bradford District have a largely rural character and the flood plain in the Silsden and Steeton with Eastburn area is quite extensive. The River Worth is one of the larger contributing catchments and joins the River Aire at Keighley.

4.31.7 The middle reaches of the River Aire are heavily urbanised and contain the towns of Keighley, Bingley, Shipley and the City of Bradford. Between Keighley and Leeds the valley floor steepens and becomes narrower. The density of development within the valley has resulted in significant restrictions to the natural floodplain.

4.31.8 Periods of heavy rainfall in the uplands can therefore produce high flows in the tributary catchments between Keighley and Bradford. This problem becomes most acute in densely developed areas where gradients are steep, for example within the heavily modified Bradford Beck corridor.

4.31.9 The functional floodplain identified for the Beck has been based on the Bradford Beck Model. Information from the modelling work and subsequent SFRA has been used to inform the approach taken to managing flood risk in the City Centre and Shipley & Canal Road Corridor areas, particularly in terms of the provision of blue and green infrastructure and restoring the natural character of the Bradford Beck where possible.

4.31.10 The River Wharfe skirts the settlements of Addingham, Burley-in-Wharfedale and passes through the central area of Ilkley. It is a fast reacting river with flood flow rapidly passing downstream. As well as flows that come down from the upper Wharfe, there are a number of smaller streams and becks descending from the moors in Wharfedale, which can be a source of flood risk in extreme rainfall events. The importance of flood storage provision within the Aire and Wharfe corridors and of flood risk from the Becks and links with green infrastructure are key challenges.

Surfacing Water Flooding

4.31.11 Surface water flooding can occur where extensive rainfall exceeds the drainage capacity in an area. The shape of the landform in Bradford, especially in and around a number of the built-up areas, makes the district potentially prone to flooding caused by direct rainfall, due to the extent of hard surfaces and a lack of sufficient sewer capacity. In addition to causing flooding to property, surface water runoff can lead to water quality issues and potential health risks.

Policy Development and Technical Assessments

4.31.12 All forms of flooding and their impact on the natural and built environment are planning considerations. The Council's commitment is to achieve the overall objectives of this policy including those of appraising, reducing and managing all sources of flooding. Policy EN7 should also be read alongside Policy SP9 (Climate Change); Policy SP10 (Green Infrastructure) and Policy EN9 (Environmental Protection) as a set of inter-related policies.

4.31.13 A Level 1 Strategic Flood Risk Assessment (SFRA) was prepared for the Bradford District in 2019 and provides data and guidance to inform the flood risk policies and allocations in the Local Plan. However, following objections from the Environment Agency, an update to the SFRA has been commissioned to take account of updated river models which are in the process of being prepared. These new models are not yet fully available or have not been signed-off by the Environment Agency and therefore the revised SFRA has not yet been completed. The preparation of the Local Plan for this consultation stage has therefore relied on the best available evidence at the time (the 2019 SFRA) and supplemented with updated flood risk information where possible.

4.31.14 The Council is aware that the Local Plan will need to be updated once the revised SFRA has been produced to take account of any changes which have been identified due to the new river modelling. It will also allow the Council to carry out a Level 2 SFRA for those allocations which fall within an area of flood risk.

4.31.15 The SFRA identifies the functional flood plain (Flood Zone 3b), comprising largely of open and undeveloped land where water has to flow or be stored in times of flooding. It also identifies areas naturally vulnerable to surface water flooding and considers the potential impact of climate change which will help to identify locations for future development.

4.31.16 The SFRA provides a framework for the overall appraisal and management of risk. It allows the identification of land with the lowest probability of flooding that would be appropriate to the type of development or land use proposed. Information from the SFRA and Sustainability Appraisal will be used to demonstrate the principle of sequential testing at a strategic level.

4.31.17 Policy EN7 supports the extent of the functional flood plain identified in the SFRA, allowing only water compatible uses and essential infrastructure after the Exception Test has been passed. The SFRA indicates that the functional flood plain forms a very important planning tool in making space for flood waters when flooding occurs and that development should be directed away from these areas.

4.31.18 While major parts of urban Bradford lie outside the flood plain, the SFRA notes that some built up areas are at risk of flooding from a number of different sources. Flooding has been recorded when the River Aire overtops into the Leeds-Liverpool Canal, causing increased flood risk to communities located close to the canal network. Shipley is identified as an area at risk from a number of different sources of flooding, as is Keighley which has experienced groundwater and surface water flooding as well as fluvial flooding.

Reasonable Alternatives – EN7: Flood Risk

• No reasonable alternatives identified - the policy is strengthened relating to Surface Water run-off, SuDS and Natural Flood Management. The policy has been updated to reflect new SFRA and other flood risk management strategies. However, with a number of new river models being prepared by the Environment Agency, the SFRA will require a further update and consequentially the policy may require further changes.

(158) Consultation Question 45

4.32 Preferred Option - EN8: Air Quality

Introduction

4.32.1 Historically, the main air pollution problem in the UK has typically been high levels of smoke and sulphur dioxide emitted following the combustion of sulphur-containing fossil fuels such as coal, used for domestic and industrial purposes. Today the major threat to clean air is now posed by traffic emissions and particularly in locations next to busy roads. Petrol and diesel-engined motor vehicles emit a wide variety of pollutants, principally carbon monoxide (CO), oxides of nitrogen (NO_x), volatile organic compounds (VOCs) and particulate matter (PM_{2.5 & 10}), which have an increasing impact on urban air quality. The most dangerous pollution is made up of nitrogen dioxide (or NO₂) and fine particles or particulate matter. It has been shown that diesel cars can produce significantly more emissions than petrol cars. Wood burning stoves are also a significant source of air pollution, producing over 30% of particulate emissions.

4.32.2 In addition, pollutants from these sources may not only prove a problem in the immediate vicinity of these sources, but can be transported long distances. Photochemical reactions resulting from the action of sunlight on nitrogen dioxide (NO₂) and VOCs, typically emitted from road vehicles, lead to the formation of ozone. Ozone is a secondary pollutant, which often impacts rural areas far from the original emission site as a result of long-range transport.^[6]

4.32.3 Improving air quality within Bradford District is a key priority and the Local Plan can influence air quality through a number of policy areas and measures including:

• where development is located and how it is supported – overall growth and distribution strategies and proximity to services, facilities and travel options;
• the types of places that are built – development of active healthy streets, levels of green infrastructure and open space.
• effective infrastructure planning – to provide real alternatives to private car use through developing bus and rail options and cycling and walking alternatives

4.32.4 In circumstances where air pollution is prevalent, planning can also promote design to minimise the potential impacts on human health, welfare and the natural environment.

4.32.5 This policy is concerned with ensuring that the implications of growth in relation to air pollution are minimised at a strategic level and developments are designed to minimise the impact of pollution where this in prevalent in the short-term.

National Planning Policy

4.32.6 The NPPF (paragraph 181) indicates that planning policies and decisions should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and Clean Air Zones, and the cumulative impacts from individual sites in local areas.

4.32.7 New development should therefore identify opportunities to improve air quality in affected areas and ensure sufficient mitigation of any impacts resulting from the development is put in place. This may include traffic and travel management, and the provision and enhancement of green infrastructure.

4.32.8 Air pollution doesn't just have an impact on human health, the NPPG highlights the need to take into account air quality management areas, and Clean Air Zones and other areas including sensitive habitats or designated sites of importance for biodiversity where there are specific requirements or limitations on new development in habitat assessments, strategic environmental assessments and sustainability appraisals.

4.32.9 The NPPF is also clear that when it comes to planning decisions, any new development in Air Quality Management Areas and Clean Air Zones is consistent with the local air quality action plan.

Local Picture

4.32.10 The Council has been monitoring real time air pollution levels since 1999 and several locations have been identified in the Bradford District where levels of nitrogen dioxide are higher than the legal limits. Pollution levels can vary because of changes in the weather, time of year and time of day. The following figure shows those areas within the study area which have the highest average levels of Nitrogen Dioxide (shown in purple and dark brown).

Figure 4.32.1: Bradford and Air Pollution

4.32.11 Bradford has declared four Air Quality Management Areas (AQMAs) where the annual mean levels of nitrogen dioxide have exceeded the maximum legal limits. Poor air quality is linked to respiratory illnesses, heart disease and asthma and is a major public health concern.

4.32.12 Research by Born in Bradford has shown that during pregnancy exposure to pollutants commonly found in the air, such as those from traffic, causes babies to be born at a lower birth weight, even where the pollution is at levels well below those allowed in current European Union (EU) air-quality rules. A low birth weight is serious because it is a predictor of other health problems in childhood and later life. The research has also shown that having a local natural 'green' environment to walk in, such as parks and woods, has a beneficial effect for both mothers and children.^[7]

Strategies and Proposals

4.32.13 The Council has prepared both an Air Quality Strategy (2011) and Low Emission Strategy (2013) setting out its commitment to taking a pro-active stance in addressing air quality issues. The impact of transport is a cross-boundary issue and the five West Yorkshire Local Authorities have prepared the West Yorkshire Low Emissions Strategy (2016-2021) which outlines the key challenges in relation to air quality within West Yorkshire.

4.32.14 At a national level the government has prepared a UK Air Quality Plan and a Clean Air Zone Framework as part of its response to addressing air quality breaches across the country and to comply with EU legislation on Limit Values. Bradford Council has received Ministerial Direction from the Government to produce a business case for an Air Quality Plan to achieve air quality compliance in the shortest time possible. The Council is preparing this plan and has consulted with residents about launching a Charging Clean Air Zone (CAZ). The CAZ is scheduled to commence in January 2022 and certain non-compliant vehicles, excluding private cars, will be subject to a daily charge shown in the Clean Air Zone charging table.

4.32.15 The CAZ is a defined area where targeted action is taken to improve air quality. It can be confined to a single road, part of a city or an entire district. The main objective of the Clean Air Zone is to discourage the use of older, more polluting vehicles from entering the zone by setting a charge for entering. Through the use of this charge the Council will encourage vehicle owners to consider upgrading their vehicles to compliant standards. The zone has special signs and is enforced with automatic number plate recognition (ANPR) cameras.^[8]

4.32.16 The area covered by the CAZ proposals are detailed below in Figure 4.32.2.

Figure 4.32.2: Proposed Clean Air Zone

Making the Connections

4.32.17 The Government's Clean Air Zone Framework highlights the best use of the local authority role in land use planning and specifically details where a Clean Air Zone is introduced it should be identified in the local plans and policies and local transport plan at the earliest opportunity to ensure it is consistent with wider ambitions.

4.32.18 How and where building and other developments are planned and built can have an effect on air quality. Approaches to planning in Clean Air Zones can help support a range of themes in this framework and encourage more sustainable behaviour, for example in the way people use electric vehicles and by making cycling and walking easier and more attractive. There are also opportunities to make strong links to approaches to other environmental behaviours including nature conservation, waste minimisation and energy efficiency.^[9]

4.32.19 Addressing air quality issues is recognised within the local plan to be complementary to the aim of achieving a reduction in emissions from transport. This is reflected in transport policies including SP7, TR1, TR2, TR3 and TR5 and the overall strategic approach to addressing climate change (Policy SP9) and creating healthy places (Policy SP15). The local plan also features a strong focus upon protecting and enhancing open spaces (Policy CO1), protecting biodiversity (Policy EN2) and integrating and further developing the District's green infrastructure network (Policy SP10).

4.32.20 The need to accommodate growth particularly in the Bradford 'basin' and transport corridors leading out of the city is likely to exacerbate air quality issues in the future if actions are not instigated to address them. This may lead to serious impacts on the health of residents, who already see relatively high incidents of death from heart disease and a high number of cases of asthma. Furthermore, for the first time air pollution has been linked as a major contribution to the death of a child in 2013 following a Coroner Court case in 2019.^[10]

4.32.21 As well as addressing air quality in the AQMAs there is a need to look at the broader impacts of emissions and air pollution on the wider environment. The policy seeks to ensure that development proposals which are likely to have an adverse impact on air quality suitably address these issues.

4.32.22 Further air quality modelling work is to be carried out to assess the possible effects of sites and traffic flows on areas of air quality concern, including the European Designated sites for nature conservation. The modelling will look at the effects on air quality from increased traffic as a result of the potential development of the sites selected for allocation. It will consider the impact of those effects on the European sites and the surrounding communities. This information will be used to put in place relevant mitigation measures to ensure that there are no adverse effects on the European sites. The policy is therefore likely to be updated in light of this modelling work.

Reasonable Alternatives – EN8: Air Quality

4.32.23 The reasonable alternatives considered included:

• Reducing the threshold from major developments to all developments in relation to air quality requirements and assessment – this is subject to further questioning as part of this consultation.

• Increasing threshold to developments of 50 units and over for residential and similar threshold setting for non-residential – this would exclude a significant proportion of the District's historic housing supply and potentially lead to a more ineffective policy.

• Keeping policy detail within the wider environmental policy context – the increasingly specific and technical nature of the policy justifies separate detailing.

(151) Consultation Questions 46

4.33 Preferred Option - EN9: Environmental Protection

4.33.1 The NPPF (paragraphs 178-180) sets out the requirements for addressing the risks posed by pollution and contamination. It specifically indicates that planning policies should ensure that proposals take account of ground conditions and any risks arising from land stability and contamination. It also requires development to be appropriate for its location having regard to likely effects of pollution on health, living conditions and the natural environment. Any potential adverse impacts should be kept to a minimum and adequately mitigated.

4.33.2 It is important that the quality of land, air and water in the District is protected and not adversely affected by new development. Policy EN9 covers a number of areas relating to pollution control including land, nuisance, and water quality. The development of Brownfield land is likely to raise some of these environmental protection issues due to former land uses. However, development of greenfield or Green Belt land may also raise issues such as land stability linked to former mining activity, the presence of pollutants associated with current agricultural practices or health and safety concerns associated with electricity pylons and power lines.

Contaminated Land

4.33.3 The legacy of past manufacturing, engineering and industrial processes, has resulted in the potential for residual contamination of sites across the District. The focus on encouraging the recycling of Brownfield land and the need to identify suitable sites for accommodating future growth means that land contamination is an important planning consideration. Sites must be subject to appropriate investigation and assessment of potential risks associated with previous land uses in order to determine their suitability for alternative uses. Any such contamination issues will need to be resolved before development can progress.

4.33.4 Soil is an important resource for wildlife, food production and the general ecological well-being of the planet, and should be protected from being polluted or becoming contaminated through development processes. Where soil is found to be contaminated on a development site, measures should be put in place to ensure adequate remediation and/or safe disposal of the effected soil.

Hazardous Installations

4.33.5 There are a number of sites within the District where significant quantities of potentially hazardous chemicals are used and stored. This can place significant restrictions on the amount and types of development that can be located in the surrounding area.

Nuisance

4.33.6 Nuisance issues can include noise, dust, odour and lighting which can have a significant impact on the quality of life. When identifying land for development and in responding to development proposals, consideration of existing land uses within the vicinity of the site need to be taken into account.

Water Quality

4.33.7 There are a number of important water assets within the Bradford District, including the Rivers Aire, Wharfe and Worth, which continue to shape the landscape and provide valuable wildlife habitats, areas for recreation, and a supply of water for consumption. It is therefore imperative that the water environment is protected from pollution and contamination, and efforts are made to improve the quality of these water assets.

4.33.8 The Water Framework Directive (WFD) establishes the legal framework for the protection of surface and ground waters. It provides a set of common objectives, principles and basic measures for the management of the water environment.

4.33.9 The Environment Agency has prepared a number of River Basin Management Plans to support the implementation of the WFD. Bradford District is covered by the management plan for the Humber and addresses the integrated management of the water environment, supporting initiatives to prevent and mitigate the effects of floods and droughts.

4.33.10 Policy EN9 seeks to support the delivery of the main aims of the directive and recommendations of the Humber River Basin Management Plan, which include:

• preventing the deterioration of aquatic systems;
• helping to restore polluted surface water and ground water to a good ecological and chemical status. (This may in part be achieved through the restoration of physically modified water courses, to allow the water body to return to a more natural state);
• reducing pollution;
• promoting water efficiency in new development;
• identifying opportunities for ecological enhancement;
• promoting use of sustainable drainage systems (Policy EN7);
• ensuring flood risk is not increased and is reduced where possible (Policy EN7).

4.33.11 The policy addresses the need to protect water resources and water quality and ensures the efficient use of water. It recognises the potential impact that new development and growth could have on water resources and quality in the District.

Reasonable Alternatives – EN9: Environmental Protection

4.33.12 The reasonable alternatives considered:

• No change to the previous iteration of the policy – this would see the retention of the air quality section (now included in a standalone policy due to the acute issues found in Bradford which requires a separate policy response), explicit references to soils not being included, and less clarity on achieving the Water Framework Directive objectives.
• Include a separate policy on the Water Environment – this would provide a stronger, separate focus on water quality and resource issues, however, it would reduce the comprehensive nature of this environmental protection policy which considers pollution and contamination issues as a whole.

(155) Consultation Question 47

4.34 Preferred Option: EN10: Energy

Introduction

4.34.1 Policy EN10 should be read in conjunction with strategic policy SP9 which focuses upon climate change, environmental sustainability and resource use and policy HO9 Housing Standards. The purpose of the energy policy is to provide a practical policy framework to support a move to a lower carbon future, although it is recognised that further technical evidence is required in relation to aspects of the policy to support the next edition of the plan.

4.34.2 Energy use solely in UK housing accounts for 27% of total carbon emissions with heating and powering all types of buildings accounting for 40% of total energy usage and therefore minimising energy use, improving energy efficiency and using more renewable and sustainable energy sources is fundamental to tackling climate change.^[11]

4.34.3 As noted previously at a sub-regional and local level, both the Council and the wider Leeds City Region have declared a Climate Emergency and have formed a Climate Coalition which aims to achieve a net zero carbon region by 2038, with significant progress being made by 2030. Net zero carbon means emissions produced and emissions taken in are balanced. A significant focus within the declaration concerns energy related issues, with headline practical projects by the Council ranging from reducing the energy used in street lighting; delivering a District heat network; expanding the network of electric vehicle (EV) charging points and numbers of EV vehicles, to increasing renewable energy and electricity generation on the council estate and embracing opportunities for the use of hydrogen.

National Planning Policy and Guidance

4.34.4 National planning policy is clear that the planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure (NPPF paragraph 148).

4.34.5 Under national policy (paragraph 151), local plans should provide a positive strategy for the use and supply of renewable and low carbon energy and heat that maximises the potential for suitable development, while importantly ensuring that adverse impacts are addressed satisfactorily (including cumulative landscape and visual impacts). Plans should also consider identifying suitable areas for renewable and low carbon sources and supporting infrastructure together with opportunities for development to draw its energy supply from decentralised, renewable or low carbon energy supply systems and for co-locating potential heat customers and suppliers.

4.34.6 LPAs are also encouraged as part of the wider Development Plan to support community-led initiatives for renewable and low carbon energy, including developments outside areas identified in local plans or other strategic policies that are being taken forward through neighbourhood planning (paragraph 152). Neighbourhood Development Orders and Community Right to Build Orders can be used to grant planning permission for renewable energy development. To support community based initiatives the NPPG details that local planning authorities should set out clearly any strategic policies that those producing neighbourhood plans or Orders will need to consider when developing proposals that address renewable energy development.

4.34.7 The NPPF also includes a footnote (49) which indicates that wind energy development involving one or more turbines should not be considered acceptable unless it concerns the repowering of existing wind turbines or is in an area identified for wind energy in the development plan and following consultation the planning impacts have been fully addressed and the proposal has the local community's backing.

4.34.8 National policy guidance indicates that while there is no 'hard and fast' rules for suitable areas for renewable energy in considering locations they need to take into account the requirements of the technology and critically the impacts on the local environment including cumulative impacts. Suitable areas for wind energy development will need to have been allocated clearly in a Local or Neighbourhood Plan – planning applications should not be approved unless the proposed development site is in an area identified as suitable for wind energy development in the Development Plan.

4.34.9 In developing an area strategy and approach to renewable and low carbon energy there is extensive published national policy guidance covering:

• methodologies for identifying suitable areas for energy projects;
• technical considerations for siting projects generally and specific planning considerations in terms of hydropower, active solar technology, solar farms and wind turbines;
• decentralised energy;
• decommissioning infrastructure, and
• planning application considerations.

4.34.10 In relation to building standards, local planning authorities may include policies in their local plans which require developers to comply with energy efficiency standards for new homes that exceed the minimum requirements of the Building Regulations. The Planning and Energy Act 2008 was amended in 2015 to provide Government with powers to stop local planning authorities from being able to exceed the minimum energy efficiency requirements of the Building Regulations, but this amendment has not been commenced.

4.34.11 In 2015 Government also set out in a Written Ministerial Statement an expectation that local planning authorities should not set energy efficiency standards for new homes higher than the energy requirements of Level 4 of the Code for Sustainable Homes, which is equivalent to a 19% improvement on the Building Regulations Part L 2013 standard. This position over standards setting has naturally caused confusion for LPAs and developers and Government has recently, through its response to the Future Homes Standard, stated that LPAs will retain powers to set local energy efficiency standards for new homes - although this may be utilised less frequently as energy efficiency standards for new homes improve.

Wider Policy Directions

4.34.12 In 2017, the UK Government set out its blueprint for a low carbon future in the 'Clean Growth Strategy' linking investment in green energy to economic growth. A further focus upon environmental policy and supporting green jobs to accelerating a route to net zero was published by the UK Government in 'The Ten Point Green Plan for a Green Industrial Revolution' (November 2020).

4.34.13 The ten-point green plan focuses upon a wide range of environmental priorities, including:

• Offshore wind: Producing enough offshore wind to power every home, quadrupling how much we produce to 40GW by 2030, supporting up to 60,000 jobs.
• Hydrogen: Working with industry aiming to generate 5GW of low carbon hydrogen production capacity by 2030 for industry, transport, power and homes, and aiming to develop the first town heated entirely by hydrogen by the end of the decade.
• Nuclear: Advancing nuclear as a clean energy source, across large scale nuclear and developing the next generation of small and advanced reactors, which could support 10,000 jobs.
• Electric vehicles: Backing our world-leading car manufacturing bases including in the West Midlands, North East and North Wales to accelerate the transition to electric vehicles, and transforming our national infrastructure to better support electric vehicles.
• Public transport, cycling and walking: Making cycling and walking more attractive ways to travel and investing in zero-emission public transport of the future.
• Jet Zero and greener maritime: Supporting difficult-to-decarbonise industries to become greener through research projects for zero-emission planes and ships.
• Homes and public buildings: Making our homes, schools and hospitals greener, warmer and more energy efficient, whilst creating 50,000 jobs by 2030, and a target to install 600,000 heat pumps every year by 2028.
• Carbon capture: Becoming a world-leader in technology to capture and store harmful emissions away from the atmosphere, with a target to remove 10MT of carbon dioxide by 2030, equivalent to all emissions of the industrial Humber today.
• Nature: Protecting and restoring our natural environment, planting 30,000 hectares of trees every year, whilst creating and retaining thousands of jobs.
• Innovation and finance: Developing the cutting-edge technologies needed to reach these new energy ambitions and make the City of London the global centre of green finance.

4.34.14 Many of the priorities are filtered into national regional and local strategies for tackling climate change, including the recent announcement by Government on the Future Homes Standard.

Future Homes Standard and Building Regulations

4.34.15 The Government has recently provided its response to proposed changes to the Building Regulations in relation to an uplift in the energy efficiency of new homes through changes to Part L (Conservation of fuel and power) of the regulations^[12] and also published as part of the future building standards consultation proposed new energy and ventilation standards for new and existing non-domestic buildings and existing buildings, as well as addressing overheating in residential buildings.^[13]

4.34.16 Key directions from Government in the consultation response on the Future Homes Standard indicates that:

• the performance standard set for the Future Homes Standard should produce 75-80% less CO₂ emissions than built to current requirements;
• heat pumps will become the primary heating technology for new homes built under the Future Homes Standard;
• heat networks will also have an important role to play integrating the lowest-carbon heat sources and exploiting larger scale renewable and recovered heat sources such as energy from waste, waste heat and heat from other sources;
• delivering carbon reductions through the fabric and building services of a house rather than relying on carbon offsetting;
• local planning authorities will retain powers to set local energy efficiency standards for new homes;
• legislation on Future Homes Standard in 2024 with implementation from 2025, and
• an interim uplift to Part L standards (2021) (all building types) to come into effect in 2022 with the expectation that homes built under this interim standard will produce 31% less CO₂ emissions compared to current standards.

4.34.17 The Government's consultation on standards for non-domestic and existing buildings is ongoing but with the ambition that the Future Buildings Standard will be implemented by 2025.

Local Energy Strategy Directions

4.34.18 Research by Leeds City Region suggests that clean growth could add £11bn to the city region economy and create 100,000 extra skilled jobs for local people. The Leeds City Region Energy Strategy and Delivery Plan concentrates upon five key zero carbon energy economy ambitions:

• Resource-efficient businesses and industry – we will increase support to help companies reduce their energy costs and carbon emissions
• New energy generation – we will develop an energy network that provides locally generated low-cost, low carbon energy to homes and businesses, including district heat networks and the landmark H21 hydrogen energy project in Leeds
• Energy efficiency and empowering consumers – we will help households become more energy-efficient, lower their energy bills and reduce fuel poverty
• Smart grid systems integration – we will develop the technology and infrastructure that enables people and businesses to use energy more intelligently
• Efficient and integrated transport – we will target investment and influence transport operators to develop a sustainable transport network, including a greater proportion of electric and hydrogen-powered vehicles and increased opportunities for cycling and walking

4.34.19 The West Yorkshire Combined Authority and Leeds City Region Enterprise Partnership (LEP) joint commission on Emission Reduction Pathways sets a process to determine what measures are required to create a zero carbon economy across buildings, industry, land use and agriculture, power and transport. Its key findings suggest that to reduce emissions by 100 per cent and achieve a 2038 net-zero target this will require:

• between 73% and 82% of emissions savings – translating broadly to:

1. 1.  For transport - reducing private car travel by 21% through shifting demand to public, shared and active travel e.g. walking and cycling; increasing travel by walking by 78%; increasing travel by bike by 2,000%; increasing travel by bus by 39% and increasing travel by rail by 53%.
   2.  For buildings and industry - retrofitting nearly 700,000 homes with energy efficiency measures such as loft and cavity wall insulation, and installing heat pump heating systems in 665,000 homes and businesses.
   3.  For power - generating enough electricity from onshore wind and solar to power more than 162,000 homes and implementing carbon capture and storage technology at four existing waste facilities and at two new proposed sites.
   4.  For land use and agriculture - increasing the area of tree coverage by the equivalent of 452 football pitches; restoring 100% peatland and reducing food waste by 38%.

• the remaining 27% to 18% could be reduced through a combination of specific ambitious measures and innovative new technologies as they become available - examples of more ambitious measures we could take include:

1. 1.  Increasing the amount of land allocated to the planting of trees.
   2.  Generating more electricity from large-scale solar farms.
   3.  Maintaining levels of remote working seen throughout the COVID-19 pandemic.
   4.  Providing funding and support for innovative emission reduction technologies.

4.34.20 The emission pathway work recognises that West Yorkshire produces only a quarter of the power it consumes and is dependent on importing power from the National Grid. It lacks large-scale power plants such as those seen in neighbouring North Yorkshire and is forecast to see an increase in demand for electricity over the study period to meet demand from population growth and people living in urban areas. Emissions from power could be reduced variously by increasing local power generation, and furthering the growth of solar PV and onshore wind.

4.34.21 The emission pathway programme forms part of a wider range of regional green economy measures including scaling up energy efficiency and new heating systems for houses; improving the energy efficiency of SMEs and supporting innovation in delivering low carbon and energy efficient schemes across West Yorkshire (including LED street lighting in Bradford).

Bradford District

4.34.22 The Council's Sustainable Development Action Plan (2020-21) builds upon the local assets and activity including priority projects identified when the Council first declared a Climate Emergency in 2019:

• Reducing the energy used for street lighting - reduce the energy used in street lighting, saving emissions and also saving us money in energy bills.
• Delivering a district heat network, with the potential for saving on Council and partner heating costs. Set up a District Heat network to save on heating costs of the council estate (our property and land) and of partner organisations in the civic quarter.
• Expanding the network of electric vehicle ^[14](EV) charging points and numbers of EV vehicles - increase the proportion of EV (Electric Vehicle) hybrid vehicles used in our fleet and support the roll out of EV charging points across the district to help promote uptake of electric vehicle use.
• Increasing renewable energy and electricity generation on the Council estate.
• Embracing the opportunities offered by hydrogen.
• Embrace the opportunities provided by the H21 Leeds City Region scheme.
  23. Box 1 below sets out some of the key energy related initiatives currently progressing within the Bradford District in further detail.

Box 1: Bradford District – Energy Initiatives

Local Plan - Policy Focus

4.34.24 It is clear in order to meet both the Government and Bradford Council's carbon-cutting ambitions, significantly higher levels of energy efficiency and greater use of low carbon and renewable energy are required. Measures should focus not simply on achieving renewable means of producing electricity but also on renewable forms of heating and the implications for transport.

4.34.25 The focus within the policy is broadly split into two areas – measures in relation to improving the energy performance of developments and a second area about strategic planning for energy projects.

Developments and Energy

4.34.26 In relation to the first policy area, the energy hierarchy provides a useful tool for classifying energy options and has been used in land use planning and other settings:

• reduce the need for energy;
• use energy more efficiently;
• use renewable energy;
• use low carbon sources, and
• use conventional energy.

4.34.27 Policy EN10 takes a similar approach to the energy hierarchy reducing the need in the first instance for the use of energy and where required using energy in a more efficient manner and from increasing more renewable and low carbon sources.

4.34.28 The policy includes provision for a stronger role for smarter technology to be built into building design to minimise energy use and this theme connects to other policies in the plan supporting a step change in the provision of digital infrastructure in developments (Policy ID1).

4.34.29 In setting building standards for energy, opportunities exist in every development to integrate renewable technologies such as heat pumps and photo voltaic cells, but the provision needs to be proportional to the development concerned particularly in recognition that there are significant viability challenges in many part of the District. This is not however a static situation and as building regulation standards improve and the use of renewable technologies increases then the costs are likely to fall.

4.34.30 It is also acknowledged that further work is required on standard setting within the policy and this is covered within the section on key questions and policy responses.

Energy Infrastructure

4.34.31 Policy EN10 provides a supportive policy context to deliver renewable and low carbon energy projects within the District and support ongoing innovation in relation to the district heat network. Importantly however in structuring the policy strong consideration also needs to be applied to the environmental and other practical constraints within the District. Policy EN10 therefore requires that applicants fully appraise the environmental impacts and identify any mitigation measures to be incorporated into the proposal. The requirements identified in Policy EN5 Landscape, in relation to potential impacts on landscape character and the need for the application of visualisation techniques therefore need to be applied. Cumulative impacts are of particular concern.

4.34.32 The Local Plan Habitats Regulations Assessment (HRA) identifies the potential for adverse impacts on important bird species via the impact pathway of collision mortality risk and/ or displacement from wind turbine developments. Any assessment of potential impacts, in relation to HRA stipulations, would also need to take account of Strategic Policy SP11 relating to the South Pennine Moors Zone of Influence and EN2 relating to biodiversity.

4.34.33 Policy TR7 Aircraft Safety also safeguards areas around aerodromes where new development will only be permitted where it will not result in a serious safety hazard to aircraft.

Further Technical Work

4.34.34 While the policy continues to show intent in relation to allocating suitable areas and opportunities for low carbon and renewable energy development, further technical work will be undertaken to inform the next iteration of the plan in relation to an area strategy and approach to renewable and low carbon energy, which balances the need for new infrastructure with the particular constraints within the District. A call for sites for renewable energy and low carbon site options runs alongside this consultation and the outcomes will be used as part of further technical analysis.

4.34.35 Further technical work is also required on standard setting and viability considerations.

4.34.36 It is likely that guidance will be required to support applications in consideration of energy requirements and assessments. This will also form part of considerations linked to the Regulation 19 local plan.

Reasonable Alternatives – EN10: Energy

4.34.37 The reasonable alternatives considered:

• Expand Policy SP9 and further integrate energy detail – strategic policy provides the wider context to the more development management orientated focus within EN10 – although it does also include an allocation element to the lower order policy.

• Reduce policy coverage and make minor adjustments to Core Strategy Partial Review drafting – there has been a significant move forward in relation to tacking climate change and energy related issues since the policy was first drafted.

• Set out a series of broad areas of search for the development of strategic scale energy projects – this is subject to a call for sites.

• Provide a different range of standards within policy – see questions detailed below.

(155) Consultation Questions 48

4.35 Preferred Option - EN11: Minerals Supply and Landbanks

Introduction

4.35.1 National planning policy highlights that it is essential to ensure that there is a sufficient supply of mineral to provide the infrastructure, buildings and goods that the country needs. It requires Mineral Planning Authorities (MPAs) to provide a policy framework for the extraction of mineral resources of local and national importance and to plan for a steady and adequate supply of aggregates^[16].

4.35.2 The latter is done by preparing a Local Aggregate Assessment (LAA) and taking part in an Aggregates Working Party (AWP). The LAA is prepared jointly by the five West Yorkshire MPAs, based on a rolling average of 10 year's sales data and other relevant local information as well as an assessment of all other supply options, whilst the Yorkshire and Humber AWP produces an annual monitoring report providing aggregate sales and reserves data for each of four sub-regions (Humber, North Yorkshire, South Yorkshire and West Yorkshire). MPAs are required to maintain landbanks of at least 7 years for sand and gravel and at least 10 years for crushed rock.

Bradford District

4.35.3 Within the Bradford District, the principal mineral resource is sandstone, however there are also deposits of sand and gravel as well as clay and coal.

Sandstone

4.35.4 The sandstones of the Bradford District are renowned as a resource capable of producing some of the highest quality building, roofing and paving stones in the country. The eight active quarries within the District work stone of varying, colours, textures and bedding characteristics, allowing a wide range of natural stone building materials to be produced, either on-site or at stone yards. Products include riven paving and roofing flags, ashlar walling stones and architectural masonry. These materials are used in new build development projects, public realm paving schemes, and the repair and extension of traditional buildings. The market for stone products extends throughout the region and beyond, with a demand for bespoke natural 'York Stone' masonry for quality development projects throughout the country. The extent of sandstone quarrying in the past has left a significant legacy, both in terms of the high quality and distinctive local character of the traditional built environment, including iconic buildings built from local stone such as Bradford City Hall, but also in relation to the land stability problems which can be associated with historic surface and underground stone mining.

4.35.5 Stone extraction is currently concentrated in the Elland Flag, Rough Rock and Woodhouse Grit rock units; however, a number of other distinct sandstone types occur within the District and there is therefore the potential to further diversify the supply of building stones, particularly in relation to the courser grained sandstones found within the northern parts of the District.

4.35.6 Although the District's sandstones are primarily valued as a resource for the production of high quality building, roofing and paving stones they are also of secondary importance for the production of aggregates. Their characteristics mean they are generally unsuitable for high specification aggregates, but are sold for a variety of lower specification uses including building sand, engineering fill and material for the repair of tracks and paths. Whilst Recycled and Secondary Aggregates (RSA) can often be used as a suitable alternative material for engineered fill; this is not the case for building sand or footpath surfacing material. Therefore, the use of the lower specifications sandstones which are produced as a by-product of building stone quarrying for such purposes is generally considered to represent a sustainable use of resources, allowing aggregates quarried elsewhere which meet higher engineering specifications to be reserved for use in more demanding applications.

4.35.7 The latest West Yorkshire LAA (2018)^[17] highlights that the sub-region is heavily dependent on higher specification crushed rock aggregate of imports from neighbouring areas. The West Yorkshire authorities continue to engage with neighbouring authorities via the AWP and production of the LAA to ensure continuity of supply. There are substantial crushed rock aggregate reserves within West Yorkshire but they are not of a sufficiently high specification. Crushed rock reserves stood at 38.78 million tonnes^[18], Therefore, the landbank (based on 10 year average sales level of 0.85 million tonnes) stands at 45 years and 7 months.

4.35.8 Although Bradford is not a significant aggregate producer the small quantities of crushed sandstone aggregate by-product which are produced do contribute towards redressing the trade imbalance highlighted above and absorbing some local demand for lower specification bulk aggregates and building sand. Therefore, notwithstanding the fact that the West Yorkshire landbank calculated in the 2018 LAA (based upon historic average sales) is substantially in excess of the 10-year minimum, it is considered inappropriate to adopt a strongly negative policy position towards the extraction of crushed rock aggregates in the District.

Sand & Gravel

4.35.9 Although sandstone is the primary commodity extracted within Bradford, the District also possesses sand and gravel resources which were an important source of construction in the past and may become so again in the future. No significant sand and extraction has taken place in over four decades, other than the production of sand from crushed sandstone. However, changes in extraction technology and commodity prices may change this.

4.35.10 West Yorkshire is heavily reliant on sand and gravel imports from neighbouring areas, as there are limited reserves within the sub-region. The West Yorkshire authorities continue to engage with neighbouring authorities via the AWP and production of the LAA to ensure continuity of supply. Although there are no reserves within the district, BGS Mineral Resource Mapping indicates potentially viable sand and gravel resources including river terrace deposits along the Wharfe and Aire Valleys. However, previous research suggested that minerals industry was sceptical whether this would economically viable to extract due to the constrained nature of remaining deposits.

4.35.11 The latest West Yorkshire LAA (2018)^[19] highlights that the sand and gravel reserves stood at 0.67 million tonnes. Therefore, the landbank (based on 10-year average sales level of 0.09 million tonnes) stands at 7 years and 5 months. Notwithstanding this, and given the reliance on imports, it is considered inappropriate and unsustainable to adopt a policy position that would not be supportive of any environmentally acceptable proposals for the extraction of sand and gravel resources within the District which may come forward within the plan period.

Clay

4.35.12 Clay extraction tends to be driven by a demand for a clay resource which meets certain specifications, in terms of porosity or engineering qualities, for specific purposes. The Council are aware that there is currently a demand for mudstone/clay with properties which make it suitable to produce high quality engineering bricks, however, it is not feasible to predict with any degree of certainty the level or nature of the demand for clay likely to persist within the plan period. Clay continues to be extracted in the district at Soil Hill to the south of Denholme.

Policy Approach

4.35.13 The policy seeks to maintain the same approach to mineral supply as set out in adopted Core Strategy policies EN10 (A to D) and EN11 (A to C). It will support the delivery the objectives embedded in policy SC1SP2 by encouraging new investment in the local quarrying industry, to realise an enhanced supply of high quality building stones, whilst seeking to minimise the potential adverse social and environmental impacts associated with minerals development by setting out environmentally considerate area of search criteria.

4.35.14 In addition, it seeks to support the managed supply of aggregates and respond to the local aggregates context by setting out a favourable policy environment for proposals involving the production of building sand and allowing the production of other types of crushed rock aggregates where this is supported by the LAA or the type of aggregate proposed to be produced can otherwise be demonstrated to be needed to fulfil an unmet demand. To prevent any restraint on aggregates from adversely affecting building stone production, the policy also supports the production of aggregates in circumstances where it is a secondary activity required to ensure the viability of a building, roofing or paving stone quarry, providing that the achievement of high quality quarry restoration is not prejudiced.

4.35.15 It is also supportive in principle of proposals for sand and gravel extraction, within an area of search constrained by specified environmental criteria, except in the unlikely event that the LAA indicates that no additional permitted reserves of sand and gravel are required. In relation to clay it retains a flexible approach by indicating that support will be given for clay extraction where a specific demand is demonstrated.

Consultation

4.35.16 Policies EN10 and EN10 were not previously considered as part of the earlier stages of the Core Partial Review.

Reasonable Alternatives – EN11: Minerals Supply and Landbanks

4.35.17 The reasonable alternatives considered:

• No other reasonable alternative considered as the policy approach has not been amended.

(1) Consultation Question 49

4.36 Preferred Option – EN12: Mineral Allocations

Introduction

4.36.1 There are a nine of operational and permitted mineral extraction sites within the district that provide minerals, in particular sandstone, for the local, regional and national markets. The majority of the sites involved the extraction of sandstone for building, paving and roofing stone, with a limited amount of aggregates being produced as a by-product.

Policy Approach

4.36.2 The policy seeks to protect existing mineral extraction sites that will continue to contribute to mineral supply in Bradford District over the lifetime of the plan. It also identifies potential new sites and location that may be suitable. In relation to the existing sites, all relevant constraints and issues have been identified and mitigation put in place through existing planning permission. It is expected these sites will be worked in line with their planning permissions including associated planning conditions and agreed restoration and aftercare plans.

4.36.3 Where proposals for mineral extraction come forward on the proposed sites, planning applications should be supported by a range of assessments that address the various environmental and community. Proposals will be determined against policy EN15 as well as other relevant Local Plan policies.

Reasonable Alternatives – EN12: Mineral Allocations

4.36.4 The reasonable alternatives considered:

• Do not include specific site allocations/policy - National planning policy requires those authorities maintaining a steady and adequate supply of minerals. The policy will also ensure the impacts of mineral extraction on the wider environment are given due consideration by developers and decision makers and provides a clear framework for developers and decision makers that should be considered when dealing with proposals for mineral extraction. The no policy option is not considered a reasonable alternative.

(5) Consultation Questions 50

4.37 Preferred Option – EN13: Minerals Safeguarding

Introduction

4.37.1 Minerals are a finite, but essential, resource and can only be extracted where they occur. As such the best use needs to be made of them to secure their longer conservation.

4.37.2 National policy^[20] requires the Mineral Planning Authorities (MPAs) need to safeguard nationally and locally important mineral resource from sterilisation by non-mineral development. A resource is sterilised when surface development occurs which would severely inhibit its extraction. This is done through the use of Mineral Safeguarding Areas (MSAs) and the adoption of appropriate policies. Where an MSA is defined it does create a presumption in favour that the resource will be worked or policy support for its extraction (other than other than prior-extraction to recover minerals before an approved surface development goes ahead). The MSA is also a tool to alert developers to the presence of a mineral resource.

Bradford District

4.37.3 The mineral resources found within the District which are considered to be of local and national importance are coal, sandstone, sand and gravel. Coal is considered to be nationally important due to the strategic need for security of supply of energy minerals, sand and gravel is considered to be regionally importance due to the relative scarcity of concrete grade sand and gravel within West Yorkshire and the local sandstone resource is considered to be important due to its suitability for the production of the high quality building stones necessary to maintain the character of the historic built environment and also its secondary value as a source of aggregates and, in particular, building sand.

Policy Approach

4.37.4 The policy seeks to maintain the same approach to mineral safeguarding as set out in adopted Core Strategy EN12. It is key to the implementation of Policy SP9, which includes the aspiration of seeking to assess and manage the impact of future decisions on the District's natural resources and the objective of encouraging better resource use.

4.37.5 MSAs for sandstone, sand and gravel and coal, based on relevant evidence, including British Geological Survey (BGS) mineral resource information, as well as the Minerals Safeguarding Plan (see Appendix 4), will be shown on the Policies Map. It should be noted that sandstone and coal resources are coincident in various parts of the District. In such areas a hierarchical approach has been adopted whereby the Coal MSA overlays and obscures the sandstone MSA. The reason for this approach is that coal is the more valuable mineral and is generally more suitable for prior extraction than sandstone bedrock. Separate Areas of Search will be defined which illustrate the parts of the District within which minerals extraction will be supported in principle (see Policy EN14).

4.37.6 The effect of the policy is to apply a safeguarding policy to all proposals involving major development within the Coal and Sand and Gravel MSAs and to all proposals involving the development of over 1 hectare of land within the Sandstone MSA.

4.37.7 The policy will continue to support prior extraction of minerals from development sites, rather than strongly restrain non-mineral development where the fall within an allocated MSA. This is provided that it would be consistent with other Local Plan policies, in particular the environmental criteria set out in policy EN15. Prior-extraction of minerals can result in significant benefits for developers including direct profit gained from the sale of the mineral, offsetting construction costs through the on-site use of the mineral as a construction material and the use of prior extraction to mitigate natural, mining or other geological hazards as part of required site preparation works. In addition, it is recommended that prior extraction be considered for sites below the thresholds set out in the policy may be viable and appropriate as part of their development projects.

4.37.8 Where proposals fall within threshold outlined in the policy and are within an MSA, developers should commission a minerals resource assessment to ascertain whether there is a mineral resource beneath the site which could be viable for extraction as part of the development project. If a potentially viable mineral resource is thought to be present, then the first option should be to amend the development project to allow for extraction of the viable part of the resource as part of the site preparation work.

4.37.9 The planning application should be supported by the minerals resource assessment and include details of the quantity of minerals to be extracted, extraction methods to be employed, the expected duration of the prior-extraction operation and transportation arrangements. If prior extraction is deemed to be unviable due to cost/ benefit factors or development scheme practicalities supporting documentation should be submitted which identifies the factors which are consider to preclude prior extraction.

4.37.10 The policy also recognises that the extension of existing mineral extraction sites provides one of the main viable opportunities for releasing additional mineral reserves. Therefore, development within the vicinity of existing active minerals extraction sites needs to be carefully controlled. It prohibits all non-householder developments within 500m of existing minerals extraction sites unless it can be shown that the development would not prejudice the extension of the extraction site. Existing active minerals extraction sites are identified within the Minerals Evidence Base Report and on the Policies Maps. The 500m safeguarded buffers will be shown on the Policies Map. Developers intending to build on land within 500m of extraction sites are encouraged to utilise the Council's pre-application enquiry process in order to ascertain whether there would be any conflict with potential future extension options and, if so, whether this impact could be mitigated.

4.37.11 It also seeks to safeguards historic quarry voids in order to ensure that they are not unnecessarily sterilised by non-minerals development. They can potentially present sustainable opportunities for renewed minerals extraction activity to facilitate the release of new minerals reserves, and can often contain remaining stone resources with particular characteristics, in terms of texture and appearance, which make them a suitable source for matching stones to facilitate the repair or restoration of historic buildings, particularly where that quarry was the original source of such building stones.

Reasonable Alternatives – EN13: Minerals Safeguarding

4.37.12 The reasonable alternatives considered:

• No reasonable alternative considered - it is not proposed to amend the policy approach. It remains broadly in line with national policy.

(2) Consultation Question 51

4.38 Preferred Option – EN14: Minerals Area of Search

Introduction

4.38.1 Areas of search represent one of three ways in which Mineral Planning Authorities can plan for a steady and adequate supply of minerals. These are classed as area where knowledge of mineral resources may be less certain but within which planning permission may be granted, particularly if there is a potential shortfall in supply^[22]. This does not guarantee that planning permission will be granted, as all proposals will need to be compliant with all relevant national and local planning policies.

Bradford District

4.38.2 Areas of search for minerals were set out in the Bradford Replacement Unitary Development (RUDP) (May 2005) and shown on the accompanying Proposals Map. They were established under RUDP Policy NR5, which was saved following the adoption of the Core Strategy DPD in July 2017.

4.38.3 13 Areas of Search (9 for sandstone; 4 for sand and gravel) being defined in the RUDP and shown on the accompanying Proposals Map to assist the mineral industry and public in identifying where the mineral resources and main planning constraints were thus providing an indication as to where new mineral working may be located. There is not a presumption that planning permission will be granted within the 'Area of Search'. These areas of search were:

4.38.4 The adopted Core Strategy (2017) (Policies EN10(E) and EN11(E)) sought to continue with the identification of Areas of Search for sandstone and sand and gravel, through a future Allocations DPD. The policies established four criteria that would be used to define Areas of Search.

Policy Approach

4.38.5 The Local Plan policy approach seeks to identify potential Areas of Search for sandstone and sand and gravel within the district. The existing Areas of Search (as identified in the RUDP) will form the starting point for this exercise. Future areas will be defined using the criteria from the existing adopted Core Strategy policies EN10(E) and EN11(E).

4.38.6 A further mapping exercise is required in order to the refine the exact extent of the any Areas of Search. Further engagement will also need to take place with the minerals industry and other key consultees. The outcome will be presented as part of the evidence base for the Local Plan and used to inform the final policy to be published at the Regulation 19 stage.

4.38.7 Until times as new Areas of Search are defined, developers can use these criteria to assist them in identifying potential mineral extraction sites.

Reasonable Alternatives – EN14: Minerals Area of Search

4.38.8 The reasonable alternatives considered:

• Do not define specific Areas of Search – it is not proposed to amend the overall policy approach as set out in adopted policies EN10(E) and EN11(E), as such this not considered to be reasonable alternative.

(1) Consultation Question 52

4.39 Preferred Option – EN15: Managing Development and Operation of Mineral Sites

Introduction

4.39.1 National planning policy requires Mineral Planning Authorities to identify criteria against which planning applications for mineral workings will be assessed so as to ensure that permitted operations do not have unacceptable adverse impacts on the natural and historic environment or human health^[23].

Bradford District

4.39.2 Maintaining a steady and adequate supply of minerals is essential to the economy, both locally and at a wider regional/ national scale. Mineral resources within the District are primarily most suited to the production of construction materials, particularly building and paving stones but also building sand, crushed rock aggregates and clays suitable for brick making, engineering or as a refractory material. However potentially viable hydrocarbon, sand and gravel resources are also thought to remain within the District which may, in the future, be capable of contributing towards the supply of concrete making materials and indigenous energy minerals.

4.39.3 Supporting new investment in minerals extraction is both a responsibility, in terms of Bradford playing its part in supplying the raw materials necessary for economic growth, but also an opportunity, in terms of enhancing Bradford's reputation as a supplier of high quality building materials and increasing skilled employment particularly in rural areas. One of the key challenges for the District over the plan period is to develop a thriving local economy and accommodate significant levels of new development without degrading the quality of the built and natural environment.

Policy Direction

4.39.4 The policy seeks to maintain the same approach to managing development as set out in adopted Core Strategy policy EN9. It will be the overarching policy that against which all proposals for development involving mineral extraction will be tested, irrespective of location. This includes quarries, pits, opencast mines, underground mines and all forms of underground hydrocarbon exploitation.

4.39.5 The policy is intended to strike the necessary balance between the promotion of investment in new minerals development and the protection of the District's human and natural resources by offering policy support for sustainable minerals development, which meets key environmental criteria. The criteria set reflect the objectives for environmental protection/ enhancement and prioritisation of previously developed land set out in core policies SP2, SP4 and SP10.

4.39.6 Its primary purpose is to support new investment in minerals extraction within the District, where such development can be undertaken sustainably, without resulting in an unacceptable level of harm to communities or the natural environment. A secondary objective is to reduce the need for minerals development to take place on new greenfield sites by encouraging developers to consider any options they may have to fully exhaust remaining reserves within existing workings, or to extend those workings, before looking at opening up new sites.

4.39.7 The criteria are essentially intended to ensure that:

• Proposals for minerals development are consistent with the minerals policies within the Local Plan,
• Sufficient mitigation is proposed to ensure that unacceptable adverse impacts on people or the environment do not occur (taking account of cumulative effects);
• The site proposed to be worked does not include any irreplaceable habitats or green infrastructure essential to the functioning of a wider ecological network; and
• Restoration proposals adequately compensate for any loss of biodiversity brought about by the minerals extraction activity.

4.39.8 It also includes a test to ensure that any applicant for a new working has fully explored any options they may have for extending existing workings under their control and that extensions to existing workings are not allowed if the original working still contains significant remaining permitted reserves or opportunities for phased restoration have not been taken. Underlying the policy is therefore an implied hierarchy whereby exhausting existing permitted reserves is preferred to extending sites and extending or reopening existing sites is preferred to opening up new sites.

4.39.9 The logic behind this hierarchy is that it is environmentally beneficial to minimise the size of existing workings, by ensuring that parts of sites where reserves are exhausted are restored before permission is granted for extensions, and that the extension of existing sites will usually (but not always) result in less environmental harm than the opening up of new sites. The exceptions set out in criteria EN15(A)(5) are intended to ensure that the policy does not restrict proposals for prior-extraction or proposals which would result in an increase in the diversity of minerals products supplied from the District (including building stones of specific qualities or characteristics).

4.39.10 It functionally related to policies EN11, EN13 and EN17, and links to other policies with the Local Plan which set out environmental criteria against which all new development proposals should be tested. Such policies include: EN2 (Biodiversity and Geodiversity), EN4 (Historic Environment), EN5 (Landscape), EN7 (Development and Flood Risk), EN8 (Air Quality), and EN9 (Environmental Protection). Policy EN9 is particularly relevant to new minerals development as it sets out details of the Council's aspirations and expectations for the protection of the environment in terms of the quality of air, land and water resources and the potential for new development to cause nuisance to existing residents.

Reasonable Alternatives – EN15: Managing Development of Mineral

Sites

4.39.11 The reasonable alternatives considered:

• Retain the existing Core Strategy Policy EN9 as drafted – this would the policy wording being maintained as currently drafted with limited updates to wording and reasoned justification.

(1) Consultation Question 53

4.40 Preferred Option – EN16: Mineral Site Restoration and Aftercare

Introduction

4.40.1 Mineral extraction is a temporary use of land, but often one that can last over a number of years. However, it is also one that can have substantial benefits for the environment and local communities. National policy requires Local Plans to set out policies to ensure that mineral workings are reclaimed at the earliest opportunity, and that high quality restoration and aftercare takes place^[24].

4.40.2 Mineral workings have been restored in a way that secures green infrastructure, environmental or community benefits. Examples of these benefits include nature conservation, biodiversity enhancement, landscape enhancements and habitat creation as well as leisure and recreation uses. Others have been restored for agricultural use.

Policy Direction    

4.40.3 The policy seeks to ensure that the proper restoration of mineral sites takes place in a timely manner when extraction and operations cease, and that the proposed after use is appropriate to the site and its surroundings. It also seeks to deliver environmental and community benefits. As such it is an important consideration in determine whether or not a proposal is acceptable.

4.40.4 Developers will be encouraged to address restoration and after-use early in the planning process, including when submitting a planning application. Applications should be accompanied by a detailed plan and proposals for the restoration and aftercare, that reflect the proposed after use of the site.

4.40.5 The responsibility for restoration and aftercare lies with the site operator and/or the landowner. Proposed after uses will be determined by a number of factors including;

• The aspirations of the landowner(s) and the community
• The characteristics of the site and its surrounding area
• Relevant plans and strategies for the district, for example Local Plan policies and Green Infrastructure and biodiversity strategies or Landscape Character Assessment.
• The nature, scale and duration of the proposed development; and
• The availability and quality of soil resources/restoration materials.

4.40.6 Restoration and aftercare are normally secured through the use of planning conditions attached the granted of planning permission. Developers will be encouraged to engage with the Council in relation to proposals for mineral extraction and future plans for site restoration and aftercare.

Reasonable Alternatives – EN16: Mineral Site Restoration and Aftercare    

4.40.7 The reasonable alternatives considered:

• No reasonable alternative considered. National policy requires Mineral Planning Authorities set out a planning policy framework to support the reclamation of mineral workings at the earliest opportunity, and deliver high quality restoration and aftercare of sites.

(1) Consultation Question 54

4.41 Preferred Option – EN17: Energy Minerals

Introduction

4.41.1 National planning policy requires Mineral Planning Authorities to plan for the exploration for and production of energy minerals, namely oil, gas and coal. Oil and gas, more formally known as hydrocarbons, play a key role in society. They are essential in generating power for homes and industry, producing fuel for transport to move people and goods, and within industry. They remain an important element of the country's energy mix as it moves towards low carbon energy supply sources and zero carbon.

4.41.2 There are two types of hydrocarbons – conventional and unconventional. Conventional hydrocarbons are oil and gas that are found in porous sandstone or limestone formations. They can be found both off-shore and onshore, and tend to be easier to extract. Unconventional hydrocarbons are found in shale and coal seams. It is commonly known as shale gas and tends to be found at deeper levels. In recent years, developments in technology have made shale gas more accessible and its extraction more financially viable.

4.41.3 MPAs are required to set out policies that distinguish between the three phases for onshore hydrocarbon extraction – exploration, appraisal and production.

4.41.4 The amount of coal used within the country has reduced significantly over recent years as the focus shifts to increasing the use of renewable and low carbon energy sources. The Government intends to shut down all coal power plants in the United Kingdom by 2025.

Bradford District    

4.41.5 There are no proven oil or gas resources within the district. To date there has been no interest in initiating exploratory works in connection with either conventional or unconventional onshore oil or gas extraction. However, the potential for future interest in oil or gas extraction cannot be entirely discounted, as part of the southern half of the district is underlain by the East Pennine Coalfield, which could potentially contain resources suitable for Coal Bed Methane exploitation or Underground Coal Gasification, and part of the northern half of the District is underlain by the Lower Bowland-Hodder Shale Unit, which could potentially contain shale oil or gas resources. The district is not subject to any Petroleum Exploration and Development Licences (PEDLs).

4.41.6 As mentioned above, the southern half of the district is underlain by the East Pennine Coalfield. This area is known to contain relatively lower rank coals which have already been subject to significant historic extraction activity over a period of around 200 years. However, it cannot be assumed that the surface coal resource area within the District contains significant quantities of accessible coal of sufficient quality to be used as an energy mineral

Policy Approach    

4.41.7 The policy seeks to main the approach set out in the adopted Core Strategy policy EN11(C) and (D). It sets out a general policy applying to energy minerals. This includes all forms of conventional and unconventional oil and gas exploitation, and coal extraction. It also reflects the Government's Planning Practice Guidance for Minerals (2014 onwards) and National Planning Policy Framework (NPPF) paragraphs 209 and 211.

4.41.8 The policy addresses the exploration and appraisal and production phases separately and planning permission granted during the exploration and appraisal phases will not commit the Council to subsequently granting planning permission for full commercial oil or gas production. The information and evidence required to be submitted to support applications for oil or gas exploration, appraisal and production should be proportionate to the scale of development and phase of the project. However, developers should ensure that consideration has been given to all of the impacts listed at Paragraph 13 of the on-line Planning Practice Guidance for Minerals.

4.41.9 During the process of site selection for boreholes and infrastructure proper consideration should be given to environmental and community sensitivities as well as geological and technical factors. Where there is reason to suspect that the development may lead to adverse impacts, sufficient evidence should be submitted to understand the likely nature and magnitude of those impacts and the extent to which adverse effects can be mitigated. Appropriate planning conditions and/ or obligations will be sought to secure mitigation or necessary infrastructure improvements; however, the Council will endeavour to ensure that such conditions and obligations do not duplicate the controls exerted through other regulatory regimes.

4.41.10 In relation to coal extraction, the policy generally reflects the advice contained in paragraph 209 of the National Planning Policy Framework, with the modification that provisions for the co-extraction of fireclay are also included. This slightly modified local approach reflects the local context, in that the fireclays within the District have historically been valued as a high quality refractory material (co-extraction of coal, ironstone and fireclay has been common in Bradford's mines in the past). Therefore, given this, developers wishing to extract coal resources must also ensure that provisions are made for the co-extraction of fireclay, unless it can be shown that such co-extraction would be unviable.

4.41.11 In line with paragraph 211 of the NPPF, the policy also specifies that proposals for coal extraction must be tested for their environmental acceptability and, where unacceptable environmental impacts are identified, it must be considered whether any demonstrable national, local or community benefits associated with the development outweigh this adverse impact. Although a similar test of environmental acceptability is applied to all types of minerals extraction development, as expressed in policy EN15, specific emphasis is given to the need for coal extraction proposals to demonstrate environmental acceptability, or provide overwhelming benefits, as certain coal extraction activities can be particularly environmentally intrusive.

4.41.12 Development involving the extraction of coal to prevent it from being sterilised by another form of development are not required to meet the criteria set out at EN17(C), as policy for this type of prior extraction development is set out in EN13.

Reasonable Alternatives – EN17: Energy Minerals    

4.41.13 The following reasonable alternatives considered:

• Don't include a specific policy – this would not be consistent with national planning policy, which requires Mineral Planning Authorities to include a policy framework within their Local Plans for hydrocarbon (oil and gas) and coal extraction.
• Retain existing policy (Core Strategy Policy EN11) as drafted – this would result in the policy framework for hydrocarbon (oil and gas) and coal extraction being included alongside other mineral rather than separately.

(2) Consultation Question 55

4.42 Preferred Option – EN18: Waste Management Development

Introduction

4.42.1 Waste management facilities can have an impact on local communities and the wider environment. Therefore, it is essential that facilities are sited in the most appropriate locations and that due consideration is given to the managing the impacts of waste management.

Policy Approach    

4.42.2 The approach seeks to bring together the key elements of policies W4 to W7, WDM1, WDM2 and WDM7 from the adopted Waste Management DPD into a single policy that can be applied to all future proposals for new or expanded waste management facilities and sites in Bradford district. It seeks to build on Policy SP12, by providing more detailed policy guidance for developers and communities on where potential facilities may be acceptable and addressing the impacts that may arise from waste management developments, which is a key concern for the Council. It aims to support and encourage the management of waste in line with the Waste Hierarchy.

4.42.3 The Council will expect the applicant to demonstrate how the proposed waste management scheme contributes to addressing the identified facility capacity gap. It will also be expected that the applicant will demonstrate its contribution to the delivery of Bradford's waste hierarchy; and then to establish how the site performs in relation to site location and assessment criteria.

4.42.4 Applicants are strongly encouraged to engage with the Council at an early stage to establish what supporting information is likely to be as an important element of applying for permission for waste development. Similarly, consultation with local communities is encourage at early stages in line with Council's Statement of Community Involvement. Engagement with the Environment Agency is also encouraged, as most facilities will involve the need for an Environmental Permit.

4.42.5 The policy should be read in conjunction with other local and national planning policies, including relevant sections of the Local Plan.

Reasonable Alternatives – EN18: Waste Management Development    

4.42.6 The reasonable alternatives considered:

• Retain existing policies W4 to W7, WDM1, WDM2 and WDM7 as set out in the Waste Management DPD – this would result in some minor amendments to the policies and reasoned justification to reflect any changes in the wider national policy context since they were adopted in 2017. However, it would result policy repetition.

(3) Consultation Question 56

4.43 Preferred Option – EN19: Waste Management Allocations

Introduction

4.43.1 The National Planning Policy for Waste, requires Waste Planning Authorities to identify sites and/or areas for new or enhanced waste management facilities in appropriate locations. It provides guidance on the matters that authorities should consider when preparing Local Plans and assessing the suitability of sites and/or areas^[25].

Bradford District    

4.43.2 In preparing the adopted Waste Management DPD (2017), evidence in the form of a Waste Needs Assessment, Capacity Gap Analysis and Site/Facility Requirements Study was undertaken. This study established future requirements for waste management facilities and the capacity in provision that needed be address through identification/allocation of sites over the period up to 2030. The DPD allocated at total of 17.62ha of land and six site allocations, which were illustrated in policy WM3.

4.43.3 To identify suitable sites, a comprehensive assessment was undertaken to identify site allocations for waste management facilities. A long list of sites comprising of existing employment allocations (from the Replacement Unitary Development Plan) and sites submitted through a call for sites process were evaluated through the first stage of the site assessment process. The list of sites not excluded by stage 1 were then further evaluated using a traffic light system to assess which were most appropriate for waste management facilities. A number of sites were allocated as having potential to accommodate more than one type of waste management facility, subject to Environmental Permits being obtained from the Environment Agency.

4.43.4 In order to determine the suitability of sites a Site Assessment Criteria Methodology was established and an Assessment Paper produced.

Policy Approach    

4.43.5 The policy will seek to continue to identify appropriate sites for waste management facilities. However, additional work needs to be undertaken to update the Waste Needs Assessment, Capacity Gap Analysis and Site/Facility Requirements Study, to identify future needs up to 2038. This will assist in determining whether further sites are required.

4.43.6 A number of the sites put forward in the DPD have since been developed for other uses. Site WM1 at Princeroyd Road, Listerhills has planning permission (granted April 2020) for an event/exhibition venue and employment use, whilst site WM5 at Merrydale Road is used by a truck/trailer rental firm, parking and service yards with some remaining as open, greenfield land. Sites WM2 at Ripley Road, Bowling and WM3 at Aire Valley Road, Keighley have both received planning permission for waste management facilities and as such area classed as committed sites. Sites WM4 and WM6 are operational waste management sites (a Household Waste Collection & Recycling Site and scrap metal site), whilst site WM2 is used for storing skips. As such, it is proposed to carry these sites forward as potential allocations within the Local Plan, at this stage.

4.43.7 Subject to updating the evidence base, it may be appropriate to identify further site allocations for waste management facilities within the district. Accordingly, a Call for Sites exercise is being undertaken as alongside this iteration of the Local Plan. All sites will be assessed against an updated version of the Site Assessment Criteria Methodology published alongside the Waste Management DPD.

Reasonable Alternatives – EN19: Waste Management Allocations    

4.43.8 The reasonable alternatives considered:

• Do not identify specific waste managements and rely on criteria based policies to assess proposals on a site-by-site basis.

(3) Consultation Question 57

4.44 Preferred Option – EN20: Safeguarding Waste Management Facilities

Introduction

4.44.1 Bradford's supply of existing waste management facilities and sites allocated through the Local Plan represent a valuable resource in helping the Council to meet its European and national obligations and to deliver local waste objectives in accordance with forecast future waste arisings. The loss of any well-located facilities could have an effect on the district's ability to meet its needs for sustainable waste management.

Policy Approach    

4.44.2 The policy approach remains identical to the existing policy WDM3 of the adopted Waste Management DPD. As such, the Council will safeguard existing waste management facilities and allocated waste sites which are important to the delivery of Bradford's waste management hierarchy.

4.44.3 The Council will resist the loss of existing facilities and allocated sites unless there is no realistic prospect of the site being used for waste management purposes. Particular circumstances will need to demonstrate how the loss of an existing facility, or development of an allocated waste site for another unrelated purpose, does not adversely affect the Council's ability to meet the District's vision and objectives.

Reasonable Alternatives – EN20: Safeguarding Waste Management Facilities    

4.44.4 The reasonable alternatives considered:

• No other reasonable alternative considered as the policy has not been amended.

(1) Consultation Question 58

4.45 Preferred Option – EN21: Waste Management within Development

Introduction

4.45.1 The principles of sustainable design, construction and demolition must be taken into consideration for all new and expanded development in the District, including waste management facilities.

Policy Approach    

4.45.2 The policy sets out the objectives for the construction and operation of development, principally relating to waste management. All new and expanded developments will be required to demonstrate that any buildings associated with the development have regard to sustainable construction methods. Applicants should be mindful of environmental management regulations and best practice during the on-site use and recovery of CDEW to ensure it does not cause undue nuisance to surrounding communities.

Reasonable Alternatives – EN21: Waste Management within Development    

4.45.3 The reasonable alternatives considered:

• No other reasonable alternative considered as the policy has not been amended.

(3) Consultation Question 59

4.46 Preferred Option - CO1: Open Spaces, Sport and Recreation

Introduction

4.46.1 The National Planning Policy Framework (paragraph 96) indicates that access to a network of high quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities.

4.46.2 A wide variety of different types of open space, ranging from parks and gardens, natural and semi-natural greenspaces, green and blue corridors, amenity greenspace, outdoor sports facilities, provision for children (play areas), cemeteries and civic spaces, exist within the District and are valued by local communities. Retention of the vast majority of existing open space and sports and recreation facilities, making improvements to the quality and nature of the resource and meeting the existing and future needs of a growing and diverse population are challenges to be addressed in order to provide a good quality of life for the District's residents.

4.46.3 Open space plays an important role in the sustainable development of settlements. There is a growing body of evidence that shows the importance of providing good quality and publically accessible open space as it provides a number of quality-of-life benefits to communities including: providing the opportunity for people to live active and healthy life styles, encouraging physical activity, helping to improve mental and physical health, providing a connection to the natural environment, supporting wildlife and biodiversity, and helping to mitigate against the impacts of climate change.

4.46.4 The NPPF indicates that planning policies should be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities. The Council has been working to update its evidence base in relation to the existing provision of open space, sport and recreation facilities and the needs and demands for such facilities in the future.

Open Space    

4.46.5 The Bradford Open Space Needs and Demand Assessment and the Bradford Open Space Audit provide an up-to-date evidence base on the amount of open space in the District and the levels of satisfaction with the existing provision. This information has been used to help set local standards for the provision of, and access to, open space and in particular identifies where there are deficiencies of the different typologies of open space in each settlement and sub-area.

4.46.6 The evidence indicates that there are notable differences between the provision of open space in each of the settlement areas of District. In terms of performance against the quantity standards, there are a number of settlement areas which have considerable amounts of open space relative to the size of their populations and residents in those areas benefit from good levels of provision. However, in some of the larger more densely populated urban areas, there are notable deficits of certain types of spaces. As part of the policy approach, it will be important that new development does not exacerbate these deficiencies and where possible should aim to help reduce them. The Audit and Needs and Demand Assessment makes a number of recommendations as to the types of open space which are a priority to provide in each settlement area. Section 5 of the Local Plan sets out Area Strategies for each settlement and provides a summary of those open space priorities.

4.46.7 The Council has also prepared a Playable Spaces Strategy which sets out how the Council will prioritise the refurbishment and enhancement of the range of play facilities that it manages across the District and to set out a spending and delivery programme.

Playing Pitches    

4.46.8 The Council along with its partners has developed a Playing Pitch Strategy (PPS) which shows where there are capacity issues in terms of pitch provision across the District. The PPS looks at the supply and demand for football, rugby and cricket pitches, 3G artificial grass pitches, and other artificial grass pitches used for sports including hockey. It also looks at outdoor bowling greens, outdoor tennis courts and athletics tracks.

4.46.9 The PPS shows that the existing position for all pitch sports is that either demand is being met by the current provision, or that there is a shortfall in provision. The future position shows the exacerbation of current shortfalls and additional shortfalls in some areas and for some sports. For football the evidence shows that there are shortfalls in all areas for one or more pitch formats, with these shortfalls increasing with future demand. There are notable current and future shortfalls for full sized 3G pitches for football team training and cricket, as well as for senior pitch types for rugby union and rugby league. There is sufficient capacity to meet current and future demand for tennis, bowls and athletics, although improvements to the quality of provision will be required. Of particular note is the need to secure the tenure and improve the track quality at Horsfall Stadium.

Protection of sites and loss of provision    

4.46.10 Given the levels of open space deficiency within some parts of the District, and the important role that open space plays for people and the environment, Policy CO1 provides protection against the development of those existing open spaces as identified on the Policies Map, where they are required to meet current and future needs and demands. The provision and access to such sites and facilities is important in ensuring communities can participate in active and healthy lifestyles. Policy CO1 therefore restricts the loss of open space, sport and recreation sites, and sets out the exceptions where losses may be acceptable. It also looks to protect those smaller, locally valued spaces which fall below the site size threshold – recognising the importance such provision can play within communities.

Requirements for new provision    

4.46.11 The residents of new housing developments should have access to good quality open space, sport and recreation facilities. Policy CO1 sets out the requirements for the provision of new open space and/or the enhancement of existing open space as part of new housing developments – ensuring that adequate provision is made. The Open Space Audit has set out a new set of local open space standards (quantity and accessibility) for the District, these are also provided in Appendix 11. Applications for new housing should use the findings of the Audit and the standards to determine the amount of new space that should be provided.

4.46.12 Where new or enhanced open space is to be provided as part of a development scheme, an adequate maintenance regime must be secured as part of the planning permission to ensure the open space can be managed for its lifetime.

4.46.13 Open space sites can play an important role in the wider Green Infrastructure network in the District. They are often spaces which are multifunctional in form, offering a range of benefits. Policy SP10 of the Local Plan sets out the requirements for the provision of additional Green Infrastructure as part of new developments, the provision of Open Space under Policy CO1 will be considered as part of this GI provision.

4.46.14 The policy also requires that major developments make a contribution to the provision of additional or enhanced built sports and recreation facilities where the Playing Pitch Strategy shows there is a deficiency of provision in the area where the development is to take place.

South Pennine Moors and Local Green Space    

4.46.15 The Habitats Regulations Assessment identifies that the level of growth proposed in the Local Plan may potentially have an impact on the South Pennine Moors Special Protection Area (SPA) and Special Area of Conservation (SAC), particularly in terms of the recreational pressures which may occur due to the increases in population and the number of visits to the moors. Policy SP11 looks specifically at the mitigation measures that will be necessary to address these impacts and these are further detailed in the South Pennine Moors SPA/SAC Planning Framework Supplementary Planning Document (SPD). One of the potential mitigation measures outlined in the SPD is the provision of Suitable Alternative Natural Green Space (SANGS) and this would be supported through Policy CO1.

4.46.16 The NPPF allows for another type of designation similar to open space, known as Local Green Space. This designation is designed to allow communities to identify and protect green areas that are important to them through the local and neighbourhood plan process. The Local Plan has not specifically identified areas of Local Green Space, but there are a number of Neighbourhood Plans which have identified such sites and these will be afforded the relevant protection. Policy CO1 supports the further identification of Local Green Space through the Neighbourhood Plan process.

Reasonable Alternatives – CO1: Open Spaces, Sport and Recreation

4.46.17 The reasonable alternatives considered:

• Separating policy components into a range of individual policies – possibly split between open space protection and requirements – the policy as drafted presents a focused succinct approach to the policy topic.

(25) Consultation Question 60

4.47 Preferred Option – CO2: Community and Health Facilities

Introduction    

4.47.1 Community facilities within the District are varied and extensive and have an essential and indispensable role in creating and supporting sustainable communities and places. More broadly they are a key part of an area's infrastructure provision.

4.47.2 There are many existing facilities of varying scales and nature that are embedded across Bradford's communities which provide for their ongoing health and well-being, social, educational, recreational, leisure, spiritual and cultural needs. Some of these, such as community centres or corner shops may only serve a very local community whilst others including schools, leisure centres or medical centres may cover a wider catchment or serve a cluster of settlements/communities. Some facilities such as hospitals, theatres or concert halls act as key facilities for the district as well as attracting people from beyond its boundaries across the wider West Yorkshire area.

4.47.3 As part of promoting healthy and safe communities, national policy recognises the need to plan positively for the provision community facilities such as shops, meeting places, sports venues, open space, cultural buildings, public houses and places of worship as well as other local services to enhance the sustainability of communities and residential development. It also seeks to ensure that such facilities are preserved and un-necessary loss be avoided^[26].

Protecting and Enhancing Community Facilities and Services    

4.47.4 Having regarding to national policy, the Plan seeks to support the provision of new or enhanced community infrastructure/facilities within the district and guard against the unnecessary loss of valued facilities and services, particularly where this would reduce the ability of local communities to meet their day-to-day needs.

4.47.5 In order to be sustainable, suitable good quality facilities should be provided locally, whilst those that attract large numbers of visitors are located where they accessible by walking, cycling and public transport. This particularly benefits those who are less mobile and more deprived members of the community. In addition, they should be designed to accessible of all sections of the community as well as being flexible in order to adapt to changing requirements.

4.47.6 It is recognised that there may be instances where facilities become demonstrably no longer fit for purpose and it can be demonstrated that there is no longer an existing or future community need for the facility, either in situ or elsewhere. Where the policy refers to 'redevelopment' this also includes proposals for the demolition, change of use and other forms of development that would result in the loss of an existing community facility.

Working Together    

4.47.7 As mentioned above, community facilities can vary in scale and nature and have different catchments. Due to this some will require a range of facilities and built infrastructure to support their provision. The types of community facilities/ infrastructure that would fall into this category include healthcare, education and leisure services.

4.47.8 As part of planning the long-term development of Bradford district, it is essential to ensure that its communities have the appropriate infrastructure. The capacity, quality and accessibility of services and facilities are all key components in ensuring people can enjoy living, working and visiting the area. The Council will continue to work closely with a wide range of providers and others to determine the impacts of future growth on community infrastructure capacity and provision. The Local Infrastructure Plan (LIP) will continue to play an essential role in identifying future physical, social (including health) and environmental infrastructure needs to support growth and development in the district. This will be published alongside the Local Plan.

Healthcare Infrastructure    

4.47.9 Improvements and new investment in the quality and accessibility of health care facilities will be supported within the District. The Council will continue to work with the Clinical Commission Group, Hospital Trusts and other health care providers to ensure that the capacity and quality of health care facilities within district meets the requirements of the current and future population and their changing needs.

4.47.10 It is recognised that there are very significant challenges in the secondary health care sector due to the current condition, maintenance costs and locational constraints of existing hospitals that deliver both physical and mental health services. This means that urgent action is required to establish a new vision, direction and delivery of essential health infrastructure within the District and certainly within the plan period.

4.47.11 Airedale NHS Foundation Trust which employs over 2,500 staff and has its main hospital facility (Airedale Hospital) at Steeton with Eastburn, is an award winning NHS hospital and community services trust providing high quality, personalised, acute, elective, specialist and community care for a population of over 200,000 people from a widespread area covering 700 square miles within Yorkshire and Lancashire – stretching as far as the Yorkshire Dales and the National Park in North Yorkshire, reaching areas of North Bradford and Guiseley in West Yorkshire and extending into Colne and Pendle in the East of Lancashire.

4.47.12 The trust has recently revealed plans for a new state of the art building (Europe's first zero carbon facility of its kind) driven in part by the long term structural problems with the present main hospital building. The local plan includes provision for a potential new Airedale Hospital in Steeton with Eastburn with supporting services, and is supportive of the strong environmental focus that the hospital trust is driving. There may be opportunities for wider linked infrastructure improvements in this part of the District and this will be subject to further technical assessment and collaborative working.

4.47.13 Bradford Teaching Hospitals NHS Foundation Trust (BTHFT) is responsible for providing hospital services for the people of Bradford and communities across Yorkshire. It operates six hospitals including Bradford Royal Infirmary (BRI) and St. Luke's Hospital. The Trust serves a core population of around 500,000 people and provides specialist services for some 1.1 million people. As a teaching hospital, BTHFT is at the forefront of education and development in healthcare, and has an excellent reputation for research performance. The Trust is one of the leading centres in conducting applied research in the country, particularly in quality and safety, elderly care and rehabilitation.

4.47.14 The Trust has developed, and invested in, its facilities, but nonetheless the estate needs renewal to support the delivery of 21st century healthcare. BTHFT has recently embarked on a programme of works to improve and future-proof the built environment. A substantial part of this programme is the new £28m hospital wing at Bradford Royal Infirmary (BRI), which has been operational since spring 2017. However, with the opening of the new wing, there is now little remaining space for further expansion on the existing site.

4.47.15 Growing demands for services and the configuration of the existing estate presents a challenging in delivering these services. The age of the estates and constrained nature of both sites is also a challenge. The Trust is currently in the early stages of exploring options for its estate and how it will meet future needs and growing demands for its services. This includes seeking funding for the provision of a new hospital, based on the "The Model Hospital" principle which was initially developed to meet the recommendations of Lord Carter's review (February 2016) of operational productivity and performances of England's acute hospitals.

4.47.16 The Trust is committed to working proactively with the Council, NHSI/E, the Department of Health and Social Care and others to keep stakeholders abreast of future plans and to seek support for the development.

4.47.17 Where proposals for new or additional health care facilities and infrastructure come forward, they should be located where they can be served by existing and/or future public transport services or well-related to existing and/or future walking and cycling routes. Where appropriate, opportunities for the multi-use and/or co-location of facilities with services in accessible locations will be supported, in order to assist in the co-ordination of local service provision and allow greater convenience for residents.

4.47.18 Discussions with health infrastructure planers has also highlighted opportunities for improvements in community health, GPs and mental health facilities across the District. The local plan is being designed to be sufficiently flexible and area / community focused to include new investment opportunities as they arise. Work on infrastructure planning to underpin the plan is ongoing and will be updated as the plan progresses.

Education Infrastructure

4.47.19 It is important that there is a sufficient choice of school and educational places to meet the needs to existing and new communities. As part of the developing the Local Plan, collaborative working is taking place with the Local Education Authority to identify future requirements resulting from the level of growth proposed. Initial trends suggest the pressures for provision are moving from the primary to the secondary schools as well as increased demand for SEN provision. There are also a number of uncertainties that may affect education provision include Brexit. Further work will continue take place in order to identify the links between housing growth and the demand for school places as part of the developing the next stage of the Local Plan. Engagement will also take place with neighbouring Local Education Authorities, particularly North Yorkshire and Leeds to identify any impacts on the cross boundary movement of pupils to/from the district.

Other Community Infrastructure

4.47.20 In addition to healthcare and education infrastructure outline above, there are a number other key pieces of community infrastructure that are essential to the district.

4.47.21 The first of the these is the provision of crematoria and cemeteries. As part of its Bereavement Services Strategy, the Council is seeking to upgrade and enhance its existing service and facilities. The strategy includes the provision of two new crematoria to replace the existing ones at Scholemoor and Nab Wood as well as the refurbishment of Oakworth Crematorium. It also includes the extension of the Muslim burial ground at Scholemoor Cemetery in Bradford. Sites for the new crematoria have been identified at Shetcliffe Lane, Bierley and off Long Lane, Heaton.

4.47.22 The provision of indoor and outdoor sports facilities is essential to supporting the health and wellbeing of the district's population. Outdoor facilities, including playing fields form an important part of the Green Infrastructure network. There are a number of facilities located across the area including swimming pools and leisure centres. There has been recent investment in new leisure centres in the Bradford urban area. Sedbergh Sports and Leisure Centre in Low Moor opened in 2017, whilst work is progressing on the Squire Lane Sports and Leisure Facility in the Girlington area.

4.47.23 Community centres, places of worship and libraries also play an important as hubs for their communities. The policy supports their retention and enhancement as well as the provision of new facilities.

Delivering Community Infrastructure

4.47.24 The Local Infrastructure Plan (LIP) is central in ensuring the appropriate infrastructure, including community infrastructure, is delivered across the district to support the growth and development outlined in this Plan. Its preparation will involve working closely, on an ongoing basis, with internal and external partners to identify the specific infrastructure projects to be delivered.

4.47.25 It will include an Infrastructure Delivery Schedule (IDS) that will identify what new or improved infrastructure is planned, who will be involved and the resource implications. This will provide a detailed investment plan for infrastructure requirements in the District and will help the Council to negotiate levels of, and obtaining, planning contributions. It will also assist the Council in attempts to secure funding for infrastructure and key projects.

4.47.26 The LIP, including the IDS, is a "live document". It will be monitored, as part of the Annual Monitoring Report process, and reviewed and updated to ensure that appropriate infrastructure is delivered.

4.47.27 Where required, community infrastructure will be secured through developer contributions in line with the provisions of policies ID1 and ID2.

Reasonable Alternative – CO2: Community Facilities

4.47.28 The alternatives considered were:

• Do not include a policy – national policy requires Local Plans to ensure that they planning positively for community infrastructure as part of creating healthy and safe communities as well as avoid their un-necessary loss.
• Include separate policies to address specific community infrastructure types - the single policy approach is simple to understand and provides quick access to material.

(7) Consultation Question 61

4.48 Preferred Option - CO3: Health Impact Assessments    

Supporting Healthier Communities

4.48.1 The built and natural environment are major determinants of physical and mental health and wellbeing. The National Planning Policy Framework (NPPF) sets out the purpose of the planning system as being to "contribute to the achievement of sustainable development"^[27]. Ensuring a strong, healthy and just society is recognised by the NPPF and Securing the Future (UK Sustainable Development Strategy) as one of the guiding principles' of sustainable development.

4.48.2 The NPPF also seeks to ensure that Local Plans enable and support healthy lifestyles, especially where this would address identified local health and well-being needs, as well taking into account and supporting the delivery of strategies to improve health, social and cultural well-being for the all sections of the community^[28]. In addition, it expects plans to set out a strategy for and make provision for community facilities including health infrastructure^[29]. Planning Practice Guidance highlights that a Health Impact Assessment is a useful tool to use where developments are expected to have significant impacts on the health and wellbeing of the local population or particular.

4.48.3 Strategic Policy SP15 sets out a clear 'healthy places framework' for the Local Plan which is interlinked with a wide range of related policies. It highlights the need to effectively evaluate the degree to which development proposals have taken into consideration health and wellbeing through screening and a Health Impact Assessment (HIA).

Health Impact Assessment (HIA)

4.48.4 HIA is a tool that allows developers to assess the potential effects of a development on the health of a local population or specific groups. It is not meant to be an onerous process. Undertaking a HIA on development proposals enables the developers to demonstrate their assessment of the health and wellbeing implications. It should not only identify potential harms such as poor air quality and noise pollution but also highlight any positive health benefits it brings to an area for example: good quality housing, social cohesion and access to public services. The aim is to ensure that

4.48.5 The inclusion of the HIA as part of the planning application process enables developers to ensure the creation of sustainable developments that support communities by:

• Demonstrating that health impacts have been properly considered when preparing, evaluating and determining development proposals.
• Ensuring developments contribute to the creation of a strong, healthy and just society.
• Helping applicants to demonstrate that they have worked closely with those directly affected by their proposals to evolve designs that take account of the views of the community.
• Identifying and highlighting any beneficial impacts on health and wellbeing of a particular development scheme.
• Identifying and taking action to minimise and mitigate against any negative impacts on health and wellbeing of a particular development scheme.

HIA and Major Developments

4.48.6 HIA are usually undertaken for major developments. In Bradford district, major development for the purposes of planning applications is defined as being for 10 or more dwellings, any development of 1,000 square metres of gross floorspace, and development involving a site of 0.5ha and over. It also includes proposals for quarry or landfill proposals, any waste management facility processing over 5,000 tonnes per annum^[30].

4.48.7 The first step in the HIA process is to undertake a screening exercise. The screening stage involves considering whether or not to perform a HIA. Not all planning proposals will require a HIA, as this will depend on the type, scale and location of the development or proposal. Issues such as timing and the likely impact on residents should be considered.

4.48.8 Policy CO3 sets out the criteria for screening and when a HIA will need to be submitted with a planning application.

4.48.9 As part of supporting healthy lifestyles and improved health and wellbeing, creating a healthy food environment is also a key element. The district has a number of health and wellbeing challenges including high and rising levels of excess weight in children and adults, as well as areas of high deprivation. The district has a large number of hot food takeaway establishments (595 in 2019). Many of these concentrated in those areas where the described above health and wellbeing challenges are present. It is essential, therefore the health impact of further hot food takeaways is understood. As such it is considered appropriate for proposals for takeaways and hot food outlets to be accompanied by a Health Impact Assessment

4.48.10 The potential for achieving positive mental and physical health outcomes will be taken into account when considering all development proposals and policy SP15 should be read in conjunction with this policy. The Council will seek to develop a Health Impact Assessment tool, which will set out guidance on the HIA process and how it should be used. This will include advice on the content of HIAs and the issues they should address.

Reasonable Alternative – CO3: Health Impact Assessments

4.48.11 The following reasonable alternatives have been considered:

• Setting a specific dwelling and commercial threshold for health impact assessments – the major development threshold is already established and used for applications.
• Excluding hot food takeaways from the policy – taking positive action to change the food environment within the District is part of public health policy.
• Integrate policy within SP15 strategic policy – the requirements of HIAs are quite specific and better suited to a development management policy structure.

(7) Consultation Question 62

4.49 Preferred Option – DS1: Achieving Good Design     

Introduction

4.49.1 Achieving good design requires an inclusive, multi-disciplinary and collaborative approach to help shape the physical setting for urban life and make places better than would otherwise be the case.

4.49.2 The proposed update of Policy DS1 identifies the importance of getting the process right and supports guidance in the Homes and Neighbourhoods SPD which sets out what is expected at different stages in the evolution of schemes linked to pre-application discussions and community involvement. This includes the need to establish a project brief at the outset which can then inform a design concept or masterplan before the preparation of detailed drawings. The updated policy is also consistent with the revised NPPF which highlights the value of using appropriate tools and processes to achieve good design.

Reasonable Alternatives – DS1: Achieving Good Design

4.49.3 The reasonable alternatives considered:

• Don't update the policy – this would still provide a level of policy support for the SPD Homes and Neighbourhoods: a guide to designing in Bradford but not as comprehensively.

• Consider a more extensive rewrite of the design policies to more closely follow the structure set out in Homes and Neighbourhoods: a guide to designing in Bradford – this could allow for easy cross-reference between the two documents but it would likely overlap with other related policy areas and require a wider rethink of the overall structure of the plan.

(6) Consultation Question 63

4.50 Preferred Option – DS2: Working with the Landscape     

4.50.1 Few sites in Bradford District come as a blank canvas. Many have existing landscape features such as trees, slopes or watercourses. Responding positively to such features can help to create distinctive places which integrate well with their surroundings, as well as reducing their environmental impact.

4.50.2 The proposed update of Policy DS2 strengthens the need to respond to the District's sloping topography, to reinforce and expand its networks of blue and green infrastructure, and to take opportunities to make developments 'green' through the design of the streets and spaces. These changes reflect key priorities in the Homes and Neighbourhoods SPD with regard to distinctiveness, health and wellbeing, biodiversity and prioritising the environment.

Reasonable Alternatives – DS2: Working with the Landscape

4.50.3 The reasonable alternatives considered:

• Don't update the policy – this would still provide a level of policy support for the SPD Homes and Neighbourhoods: a guide to designing in Bradford but not as comprehensively.

• Consider a more extensive rewrite of the design policies to more closely follow the structure set out in Homes and Neighbourhoods: a guide to designing in Bradford – this could allow for easy cross-reference between the two documents but it would likely overlap with other related policy areas and require a wider rethink of the overall structure of the plan.

(6) Consultation Question 64

4.51 Preferred Option – DS3: Urban Character     

4.51.1 The urban areas of Bradford benefit from a rich and varied character which contributes to local distinctiveness and a sense of place.

4.51.2 Minor additions are proposed to Policy DS3 to further strengthen the priorities in the Homes and Neighbourhoods SPD of making places which are distinctive to the District and of creating attractive green streets and spaces.

Reasonable Alternatives – DS3: Urban Character

4.51.3 The reasonable alternatives considered:

• Don't update the policy – this would still provide a level of policy support for the SPD Homes and Neighbourhoods: a guide to designing in Bradford but not as comprehensively.

• Consider a more extensive rewrite of the design policies to more closely follow the structure set out in Homes and Neighbourhoods: a guide to designing in Bradford – this could allow for easy cross-reference between the two documents but it would likely overlap with other related policy areas and require a wider rethink of the overall structure of the plan.

(4) Consultation Question 65

4.52 Preferred Option – DS4: Streets and Movement     

4.52.1 Policy DS4 seeks to ensure that new developments get the movement framework right by creating a network of routes which connect to where people want to go, and which offer choice and a pleasant experience, particularly for those travelling by foot.

4.52.2 Changes are proposed to DS4 to further support the priority in the Homes and Neighbourhoods SPD of promoting healthy, active lifestyles and the role street design can play in this, and also to provide additional emphasis on the need to make cycling an attractive travel option on new developments.

Reasonable Alternatives – DS4: Streets and Movement

4.52.3 The reasonable alternatives considered:

• Don't update the policy – this would still provide a level of policy support for the SPD Homes and Neighbourhoods: a guide to designing in Bradford but not as comprehensively.

• Consider a more extensive rewrite of the design policies to more closely follow the structure set out in Homes and Neighbourhoods: a guide to designing in Bradford – this could allow for easy cross-reference between the two documents but it would likely overlap with other related policy areas and require a wider rethink of the overall structure of the plan.

(2) Consultation Question 66

4.53 Preferred Option – DS5: Safe and Inclusive Places     

4.53.1 Good design can help to foster a sense of community by creating places where people of all ages, abilities and backgrounds feel safe and at ease and can meet and interact with each other.

4.53.2 The proposed update to Policy DS5 identifies the importance of considering this at all scales from the neighbourhood to the streets, the spaces and the buildings, and it further supports the priority for inclusive places in the Homes and Neighbourhoods guide emphasising the needs of older people, those with disabilities and children and providing opportunities for play and community spaces. It is also consistent with the revised NPPF and its expanded section on healthy and safe communities.

Reasonable Alternatives – DS5: Safe and Inclusive Places

4.53.3 The reasonable alternatives considered:

• Don't update the policy – this would still provide a level of policy support for the SPD Homes and Neighbourhoods: a guide to designing in Bradford but not as comprehensively.

• Consider a more extensive rewrite of the design policies to more closely follow the structure set out in Homes and Neighbourhoods: a guide to designing in Bradford – this could allow for easy cross-reference between the two documents but it would likely overlap with other related policy areas and require a wider rethink of the overall structure of the plan.

(2) Consultation Question 67

^[1] Edge Economics 'Future Employment Analysis Paper' 2021

^[2] Job type information is based upon Census 2011 and is now quite dated.

^[3] People, Skills, Prosperity | Bradford Council

^[4] LBIA Route 2030 – Strategic Development Plan

^[5] RTPI-Dementia-and-town-planning-Report.pdf (housinglin.org.uk)

^[6] Causes of air pollution - Defra, UK

^[7]Air Pollution: The Magical Power of Nature – Born In Bradford

^[8] breathe better BRADFORD | Bradford Council – useful website dedicated to air quality plan and CAZ

^[9] DEFRA / DfT 'Clean Air Zone Framework: Principles for Setting up Clean Air Zones in England' February 2020 P.7

^[10] Air pollution death ruling: What comes next? - BBC News

^[11] Is this the future smart home? | Ofgem and Department for Business, Energy & Industrial Strategy, 2019. The Grand Challenge missions. Available online: https://www.gov.uk/government/publications/industrial-strategy-the-grand-challenges/missions

^[12] The Future Homes Standard: changes to Part L and Part F of the Building Regulations for new dwellings - GOV.UK (www.gov.uk)

^[13] The Future Buildings Standard - GOV.UK (www.gov.uk)

^[14] Information reproduced from the Council's Sustainable Development Action Plan 2020-2021

^[15] The requirements expressed in this policy will apply unless it is demonstrated through open book accounting that they would make the development unviable, having regard to the policy requirements of the Local Plan.

^[16] National Planning Policy Framework (NPPF) (February 2019) – Paragraphs 204(a) & 207

^[17] West Yorkshire Local Aggregate Assessment 2018 (2017 data), West Yorkshire Combined Authority & West Yorkshire Mineral Planning Authorities

^[18] As of 31^st December 2017

^[19] West Yorkshire Local Aggregate Assessment 2018 (2017 data), West Yorkshire Combined Authority & West Yorkshire Mineral Planning Authorities

^[20] National Planning Policy Framework (NPPF) (February 2019) – Paragraphs 203 & 204(c to e)

^[21] As defined by the Town and Country Planning (General Development Management) Order 2010

^[22] Planning Practice Guidance (2014 onwards) – Minerals - Reference ID: 27-008-20140306

^[23] National Planning Policy Framework (NPPF) (February 2020) – Paragraph 204(f)

^[24] National Planning Policy Framework (NPPF) (February 2019) – Paragraphs 204(h) and 205(e)

^[25] National Planning Policy for Waste (NPPW) (October 2014) – Paragraphs 4 & 5

^[26] National Planning Policy Framework (NPPF) (February 2019) – Paragraph 92

^[27] National Planning Policy Framework (NPPF) (February 2019) – Paragraphs 7 and 8

^[28] National Planning Policy Framework (NPFF) (February 2019) – Paragraphs 91 and 92

^[29] National Planning Policy Framework (NPPF) (February 2019) – Paragraph 20(c)

^[30] Pre-Application Advice for Major Developments, City of Bradford MDC website.