Statement of Community Involvement 2025

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3. Preparing Planning Policies
and Supplementary Planning Documents

This chapter is about Preparing Planning Policies and Supplementary Planning Documents.

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3.1 Current Development Plan

3.1.1 The local planning policy context is complex in Bradford but moving to a more streamlined and simple approach. There are two main types of Local Development Documents (LDDs) – Development Plan Documents (DPDs), such as a Local Plan or its constituent parts which form part of the statutory development plan and Supplementary Planning Documents (SPDs) (which do not form part of the statutory development plan). The combination of the Local Plan and Neighbourhood Development Plans make up the overall 'Development Plan' for the District - the starting point for planning decisions.

3.1.2 SPD's support policies with additional technical information but cannot introduce new policy or amend existing policies and must conform with national policies. These documents go through a formal consultation and adoption process and are outlined further in this section of the SCI.

3.1.3 Planning decisions have to be in line with the development plan unless indicated otherwise by other important matters (known generally as 'material considerations'). The overall Development Plan as currently structured is set out below:

Bradford Replacement Unitary Development Plan (RUDP) – Saved Policies (June 2020 schedule) – the RUDP was adopted in May 2005 and the majority of its policies have since been superseded by the Core Strategy, AAPs and Waste Management DPD, however a number of the policies remain extant.
Core Strategy DPD (July 2017) – this sets out the broad aims and objectives for sustainable development within the District over the period 2013 to 2030 and provides broad policies for guiding and restraining development. It also sets out broad locations for new housing, employment and infrastructure investment alongside a broad range of important policy topics.
Bradford City Centre Area Action Plan (October 2017) – this covers a key regeneration/transformation area for the District. The AAP sets out detailed planning policies to guide development proposals and associated infrastructure in the city centre, along with details of how these proposals will be delivered. It includes policy frameworks/visions for the regeneration of specific parts of the city centre together with site allocations and other designations.
Shipley & Canal Road Corridor Area Action Plan (December 2017) – this covers another key regeneration/transformation area within the District that runs from the northern edge of Bradford City Centre to the town of Shipley. The AAP sets out a detailed planning policy framework to direct future development and investment. This including allocates land for development, defining areas which will be protected and identifying the supporting infrastructure required to ensure delivery.
Waste Management DPD (October 2017) – this expands on the waste management policies set out in the Core Strategy (Policies WM1 & WM2) and provides the overall spatial strategy and approach for dealing with all types of waste within the District. It identifies waste management sites for dealing with the main streams of waste such as Municipal Solid Waste (MSW) and Commercial and Industrial waste, together with criteria-based policies for the management agricultural, CDE, hazardous and residual waste.
Adopted/Made Neighbourhood Plans – formally "made" (adopted) neighbourhood development plans.

3.2 New Local Plan Approach

3.2.1 The Council is moving from this mixed 'portfolio approach' to a single comprehensive local plan. This decision was based on a range of work undertaken as part of the development of the different DPDs and took account of earlier consultations as well as more recent circumstances and changes to national policy.

3.2.2 The Council is also engaged in the development of the Mass Transit Sustainable Development Framework (Part 1) (DPD) which will be a Joint Development Plan for Bradford, Calderdale, Kirkless, Leeds and Wakefield. Consultation and engagement will be in accordance with legislation and national planning policies and guidance.

3.2.3 Council officers also prepare a number of other planning documents, including:

Infrastructure Funding Statement (IFS) and Community Infrastructure Levy Charging Schedule updates - The IFS is a document which provides a summary of financial and non-financial developer contributions relating to Section 106 and CIL Agreements within the Local Planning Authority over a particular period. The IFS statement is updated and published annually to reflect the summary of obligations and agreements for each monitoring period. The Community Infrastructure Levy (CIL) is a levy which the Council may charge on new developments in the District. The money raised will help the Council pay for infrastructure such as schools, transport, parks, open spaces and other community facilities required to support new housing and economic development in the District.
Local Development Scheme (LDS): This document is a three-year rolling work programme that sets out the details, timescales and arrangements for producing the Local Plan for the District. It also highlights stages in the process when community involvement on a particular document is likely to take place. The LDS will be reviewed on a regular basis and linked with the Annual Monitoring Report. It is adopted by the Executive.
Annual Monitoring Report (AMR): This report sets out the progress being made in producing Local Plan documents that are detailed in the LDS. It will also examine the effectiveness of policies contained in the Development Plan Documents recommending alterations and review of policies and proposals as and where necessary. The AMR findings will inform the review of the LDS. It is usually published following informal consultation with lead Members.
General technical notes and guidance – produced from time to time to support or guide planning applications with technical considerations. These publications do not go through a statutory process.

3.3 Key Stages in Preparing Development Plan Documents (DPD)

3.3.1 The key stages involved in plan-making which are followed by the Council are set out in the Town and Country Planning (Local Planning) (England) Regulations 2012 (TCP Regulations 2012) and subsequent amendments. The Council, wherever possible, seeks to 'frontload' consultation on DPDs to ensure that key issues are identified and any outstanding matters are resolved as early as possible in the process.

3.3.2 The LDS sets out the Council's programme for Local Plan preparation including DPD's and Supplementary Planning documents (SPDs). Table 1 below summarises the main Local Plan preparation stages and how and when key stakeholders and local communities can get involved in the process. The Council may supplement these consultation features with additional activities as set out in the consultation toolkit.

Table 1: Development Plan Documents – Preparation Stages

Stages	Consultation Features
Stage 1 – Research and evidence gathering to inform preparation and development of the document.	Where appropriate involve consultation with relevant stakeholders, duty to co-operate partners, specific and general consultation bodies and local communities. No formal consultation period. Identifying priorities and key issues. May also be some limited targeted consultation on elements of technical evidence.
Stage 2 – Draft Plan (Regulation 18) – formal consultation on emerging local plan.	Formally notify each of the bodies and persons specified in the regulations of the subject of the local plan and invite representations to be made to the Council. The Council will consider representations received when further drafting the plan. This stage may involve more than one stage of consultation depending on the document and the nature and scale of the issues involved, which is not prescribed in the regulations. Undertake a minimum 6-week formal public consultation. Getting involved at this stage allows you to have influence over the content of the plan at an early stage.
Stage 3 – Pre-submission Plan -Regulation 19 consultation	Make a copy of the local plan and other documents as set out in the regulations available at set deposit locations and available on the Council's website. Ensure the local plan and other documents as set out in the regulations are sent to specific and general consultation bodies. Undertake a minimum 6-week formal consultation prior to submitting the local plan and relevant documentation as set out in the regulations to the Secretary of State for public examination. This stage may involve more than one Regulation 19 consultation. Getting involved at this stage is primarily focused upon legal, procedural and test of soundness considerations as set out in national policy and relevant guidance.
Stage 4 - Submission to the Secretary of State for Public Examination (Regulations 20 and 22)	The Council will receive and collate the representations made at the Regulation 19 stage to submit to the Secretary of State. Submit documents and information to the Secretary of State in compliance with regulatory requirements. As soon as reasonably practicable after the local plan and associated documents have been submitted make a copy of the documents as set out in the regulations available at set deposit locations and available on the Council's website. Notify specific and general consultation bodies as required by the regulations that the submitted documents are available for inspection Give notice to those persons who requested to be notified of the submission of the local plan to the Secretary of State.
Stage 5 – Independent Public Examination (Regulation 24)	At least six weeks prior to the opening of the independent examination the Council will provide information through the set deposit points and Council's website and notify people who made representations of the date, time and place of the hearing and name of the appointed inspector. The examination will usually involve public hearing sessions and the Planning Inspector will consider the comments received on the 'submission' version of the Plan. Those who responded may be invited to attend an examination hearing by the Inspector. The examination may result in the Inspector posing additional questions for the Council and other bodies making representations. This information / correspondence will be made publicly available on either Council's website or examination website. Additional consultation will be carried out if any major modifications to the plan are needed – usually for 6 weeks.
Stage 6 - Inspector's Report with publication of representations (Regulation 25)	As soon as practical after the receipt of the inspector's report (or if the Secretary of State has provided a direction) make the report recommendations and reasons available through the deposit locations and on the Council's website together with notification to people who requested report information at this stage in the process.
Stage 7 – Adoption of the Plan (Regulation 26)	The Council will formally adopt the Local Plan, subject to outcomes of the Inspector's report and as soon as reasonably practical make the local plan, adoption statement, sustainability appraisal and deposit locations and time it is available for inspection. Send a copy of the adoption statement to those persons who requested to be notified of the adoption of the local plan plus the Secretary of State.

3.4 Key Stages in Preparing Neighbourhood Development Plans

3.4.1 The neighbourhood planning system was introduced by the Localism Act 2011 and in terms of neighbourhood development plans is enabled through the secondary legislation of The Neighbourhood Planning (General) Regulations 2012 (as amended) (NPGR 2012).

3.4.2 Communities are in the driving seat with neighbourhood planning. In parished areas, Town and Parish Councils will lead on the work. In areas that are not parished, communities can form a Neighbourhood Forum, subject to specified procedures, to take the lead. It is a community decision to prepare a Neighbourhood Plan given the issues, resources and timescales available.

3.4.3 The Council has a statutory duty to provide advice and support to communities undertaking neighbourhood planning. It is committed to working with communities to guide them through the process of producing a neighbourhood plan. A neighbourhood plan has the same legal status as a local plan and other documents that form part of the statutory development plan once it comes into force.

3.4.4 Bradford Council's policy with regards to the duty to support qualifying bodies is set out in Box 1 below. This is an extract from the Local Council's Charter (2015) which sets out the Council's governance and duty to support arrangements.

Box 1: Bradford Council's Duty to Support Statement for Neighbourhood Planning Bodies

The Council will, subject to resources and work priorities, provide the following in kind support and assistance to qualifying bodies undertaking Neighbourhood

Planning functions within the Bradford District:

Make available, wherever possible, Bradford Council's planning data and information for the qualifying body to use in the preparation of their Neighbourhood Development Plan or Order, as part of their evidence base.
Subject to officer availability, attendance at Local Council meetings to facilitate an on-going dialogue with the qualifying body and to provide advice (e.g. consultation and engagement).
Help with engagement and consultation events and where possible attend consultation events.
Provide advice on assessments and evidence.
Provide advice on conformity with national and local plan policies with which they will need to fit.
Helping communities communicate with external partners where this is required.
Provide advice on the legal requirements of neighbourhood planning under the Localism Act.
Provide professional advice and support prior to formal submission of a Plan to Bradford Council for examination.
Publish relevant details on the Council's Neighbourhood Planning webpage.Provide a single point of contact for the qualifying body.

Extract adapted from Appendix 7 of the Bradford Council's - Local Council's Charter (2015)

3.4.5 As set out in planning guidance there are 3 types of modification which can be made to a neighbourhood plan or order. The process will depend on the degree of change which the modification involves:

Minor (non-material) modifications to a neighbourhood plan or order are those which would not materially affect the policies in the plan or permission granted by the order. These may include correcting errors, such as a reference to a supporting document, and would not require examination or a referendum.

Material modifications which do not change the nature of the plan or order would require examination but not a referendum. This might, for example, entail the addition of a design code that builds on a pre-existing design policy, or the addition of a site or sites which, subject to the decision of the independent examiner, are not so significant or substantial as to change the nature of the plan.

Material modifications which do change the nature of the plan or order would require examination and a referendum. This might, for example, involve allocating significant new sites for development.

3.4.6 The table below sets out the stages to progressing a neighbourhood development plan and material modifications to plans within the Bradford context. It provides information on the opportunities for involvement at each stage and the advice and assistance available from the Council. The table covers parish led plans with specific legislative processes in place for forums.

Table 2: Neighbourhood Development Plans – Preparation Stages

Preparation Stages	Consultation Features
Stage 1 – Application for designation of a neighbourhood area (NPGR 2012 Regulations 5, 5A, 6, 6A and 7)	Submitted fully Parished areas are automatically designated as a Neighbourhood Area however the Parish Council must register an interest with the LPA to become a qualifying body to produce a Neighbourhood Plan. For other application areas, as soon as possible after receiving an area application from a relevant body the Council will publish details, including the closing date for representations and how to submit comments on its website and through other media channels to inform the local community. The closing date for representations will be a minimum of 6 weeks from the date it is advertised. The Council will determine the application within the established regulatory period(s) and as a soon as possible after designation publish details on its website and through other media channels to inform the local community.
Stage 2 – Early-stage work – the designated neighbourhood body (parish council or forum) prepares the neighbourhood plan	The neighbourhood body leads on this early-stage work including undertaking resource planning, research, analysis of the area, commissioning technical evidence and surveys. The Council will provide subject to resources and work priorities tailored support at this stage in line with the duty to support neighbourhood planning statement. Subject to resources at the time of request and work priorities the Council will also undertake a first stage Strategic Environmental Assessment (SEA) screening exercise of neighbourhood plans to: Determine whether the neighbourhood plan is likely to have significant environmental effects. Consult the environmental assessment consultation bodies. Collate and produce a screening opinion on likelihood of significant effects on the environment. Subject to the outcome of the screening exercise, general advice to the Neighbourhood Body on SEA scoping should this be required.
Stage 3 – Pre-submission consultation and publicity (NPGR 2012 Regulation 14) (led by the Neighbourhood Body)	This stage of the process is led by the Neighbourhood Body. Undertaking consultation on an early stage / emerging plan or modification proposals in compliance with the regulation. The Council will review the documentation and subject to resources and work priorities provide feedback on the emerging neighbourhood development plan or modifications proposals.
Stage 4 – Submission to Council of Neighbourhood Plan proposals and modifications (NPGR 2012 Regulation 15) (led by the Neighbourhood Body)	This stage of the process is led by the Neighbourhood Body. Submission to the LPA a regulatory compliant neighbourhood plan or modifications proposals. To include: A copy of the Neighbourhood Plan A statement explaining how the plan meets the basic conditions A Strategic Environmental Assessment report or a statement explaining why one is not needed A consultation report outlining all of the engagement undertaken throughout the plan process. Statement regarding modifications proposals. The Council will publicise and consult on the plan for a further 6 weeks.
Stage 5 – Independent Examination – submission to examiner and examination (NPGR 2012 Regulation 17, 17A, 18 and 19)	Although it is up to the Council to appoint an examiner, the decision will be taken jointly with the Neighbourhood Body. The Council will submit the plan with supporting documents to the examiner. The purpose of the examination is to test whether the draft neighbourhood plan meets basic conditions and other standards. Following examination, the examiner will recommend one of the following: that the plan proceeds to referendum, requires modifications (to be made by the Council) in advance of a referendum, or to not proceed to referendum. The Council will publicise information in compliance with the regulations.
Stage 6 – Referendum on the Neighbourhood Plan (The Neighbourhood Planning (Referendums) Regulations 2012))	The Council is responsible for administrating the referendum, but the Neighbourhood Body must publicise it and campaign for a yes vote. The Council must remain impartial. For the plan to be adopted, more than 50% of the votes cast must be in support of the plan. The Council will publish information about the outcome of the referendum in compliance with the regulations.
Stage 7 – adoption and made Neighbourhood Plan (NPGR 2012 Regulation 20)	The Council will formally adopt the neighbourhood plan after a successful referendum and will form part of the development plan.

3.5 Key Stages in Preparing Supplementary Planning Document (SPD)

3.5.1 The purpose of a Supplementary Planning Document (SPD) is to provide addition information and guidance on planning policies in a development plan. They can cover a wide range of issues and are used to expand on information to support planning policies but must be in conformity with the Council's Local Plan and consistent with national policy and guidance.

3.5.2 The formal process for the production and preparation of Supplementary Planning Documents is set out in the Town and Country Planning (Local Planning) (England) Regulations 2012, as amended. The preparation and production of an SPD is a slightly different process to a DPD and often an SPD can be completed much quicker.

3.5.3 Table 3 below outlines what happens at each stage in the preparation of a SPD and how and when key stakeholders and the local community can get involved in the SPD preparation process. While Local Plan Documents must be adopted by Full Council, SPDs can be adopted by the Cabinet Member with responsibility for planning.

Table 3: Supplementary Planning Documents – Preparation Stages

Preparation Stages	Consultation Features
Stage 1 – SPD Pre-production	This may involve a range of different consultation and engagement activities depending on the topics and coverage of the SPD. This stage will involve the Council gathering and developing a range of evidence to support the preparation and development of the document. This information will ensure that the Council has a good understanding of the planning issues at an early stage. At this stage there is no formal consultation period, however the Council may informally consult any stakeholders or bodies it considers appropriate in order to prepare the SPD.
Stage 2 – Public consultation on the draft supplementary planning document (TCP LP Regulations 2012 Regulations 12 & 13)	Any person may make representations about a SPD and consultation will be undertaken for a minimum of 4 weeks from the date that the document is made available for inspection, at the Council's principal office and at such other places within their area as the authority considers appropriate, during normal office hours, and published on the Council's website. This is the key stage to shape the content of document and the Council will consider the representations received and amend the SPD as considered appropriate. The Council will also consult with the duty to co-operate, specific and general consultation bodies.
Stage 3: Review of representations and complete final draft (TCP LP Regulations 2012 Regulation 12)	Following the consultation, the Council will produce a Statement of Consultation document which will set out the main issues raised during the consultation on the Draft SPD and also explaining how the representations received have been dealt with and considered.
Stage 4: Adoption of the SPD by the Council	A finalised version of the SPD, with consultation statement and covering report is then put forward for formal adoption by the Council. The Council is required to inform anyone who asked to be notified and will also inform those on its planning policy contact database.
Stage 5: Post adoption (TCP LP Regulations 2012 Regulations 11 and 14)	As soon as reasonably practicable after the Council adopt the SPD it will: make available in accordance with regulation 35, the SPD and adoption statement, and send a copy of the adoption statement to any person who asked to be notified of its adoption. The adoption statement is specifically detailed in the regulations as meaning a statement specifying: the date on which a supplementary planning document was adopted, if applicable, any modifications made pursuant to section 23(1) of the Act, that any person with sufficient interest in the decision to adopt the supplementary planning document may apply to the High Court for permission to apply for judicial review of that decision, and that any such application must be made promptly and in any event not later than 3 months after the date on which the supplementary planning document was adopted; and "consultation statement" means the statement prepared under regulation 12(a).

3.6 Reporting Back

3.6.1 The Council is committed to providing the community with feedback on the results of consultation. It will summarise any comments received and provide details of any amendments that have been made, or why an amendment has not been made.

3.6.2 Any person making representations during an informal or formal consultation period for a planning document will receive acknowledgement of the receipt of their comments.

3.6.3 Formal statements of consultation will be made available alongside relevant planning documents.

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