Object

Representation ID: 29152

Received: 25/03/2021

Respondent: Ilkley Town Council

-Agree with CPRE comments:
• Support lower housing target at 1,700 per/annum
• Government approach is to target housing within major urban centres
• We consider that additional homes should go to the Bradford City itself
• The ENALR should be revisited in light of significant changes in working patterns post pandemic - to see whether more land identified for employment in Urban areas could now be used for housing to remove the pressure to release Green Belt sites.

- The reasonable alternative is therefore to plan for that shift in spatial distribution anyway, in order to maximize the use of brownfield land across the district, and thereby to more properly meet the expectations of NPPF para 137.

-If exceptional circumstances for Green Belt release are demonstrated, then only sites that are able to be served by high frequency public transport, contribute to 15-minute neighbourhoods and are suitable for development at at least 50dpha should be released from the Green Belt.

-Sequential requirements of NPPF para 137 not fulfilled as settlement hierarchy has been applied before the para 137 tests, rather than after

-Reasonable alternative is to measure housing land requirement by land area, rather than number of dwellings, and to allocate only enough land to meet the housing requirement at 50dpha net

-Climate Emergency and road traffic reduction – target setting not enough.

-Adopt the WY 21% absolute reduction in car mileage over the period as a reasonable alternative to ensure that all policies integrate to achieve it.