Object

Representation ID: 5497

Received: 24/03/2021

Respondent: CPRE West Yorkshire

We strongly support paras 3.4.7 and 3.4.8, which point to 15 minute neighbourhoods and an aspiration not to eliminate the car, but to reduce its use.

It is essential that the Local Plan does everything it possibly can to facilitate reductions in car mileage. It should do so principally through the location of new development, the development expectations in each of those locations, and the transport investments proposed.

New development must be located and planned in such a way as to facilitate net reduction in car use in the host settlement. This is likely to depend on significantly greater concentration of new development within areas that are capable of being 15 minute neighbourhoods, and significantly more mixed-use rather than single-use site allocations.

SP4(A) is essentially a reiteration of government policy and the settlement hierarchy. We are concerned that the phrase ‘not have high environmental value’ is too subjective. This is because there may be sites which are currently not of high environmental value, but which have strong potential to become so, for example through being beneficiaries of biodiversity net gain measures or significant urban tree planting.

Similarly, we would expect more specific requirements for examining the sustainability of greenfield sites within settlements.

We are concerned that the phrase ‘subject to the above’ implies that the application of the sequence identified in part A of the policy takes precedence over the outcomes identified in part B of the policy

We are also concerned that the intended outcomes in SP4B - whilst referring to an accessibility orientated approach - do not clearly consider the accessibility needs of different people for example, by age, gender or ability as required in NPPF para 108.

We have provided below a suggested alternative wording for policy SP4 to address the concerns we have raised here.

Policy SP4: Location of Development
A. The Local Plan will adopt a car-free accessibility approach to ensure that new development contributes to the strategic target of reducing car use over the plan period. It will do this by locating new development such that it:
1. Makes walking, cycling and public transport the most attractive and useful travel modes for day-to-day journeys, to achieve 15-minute neighbourhoods;
2. Ensures that the pattern of development improves accessibility and independence for all sectors of society;
3. Takes every possible opportunity to create and enhance green corridors for nature, climate response and active travel;
4. Minimises the dependence of development on any additional road capacity that could otherwise induce additional traffic;
5. Maximises the use of rail and water for uses generating large freight movements.
B. Having identified how to maximize car-free accessibility, the Local Plan will then maximize the efficient use of land, by allocating sites that:
1. are compatible with the settlement hierarchy;
2. give first priority to the re-use of brownfield and under-utilised land within settlements, and second priority to greenfield sites within settlements, while ensuring that development of those does not harm environmental assets or public space;
3. are suitable for development at a minimum of 50 dwellings per hectare net.
C. Where there are insufficient sites within settlements, land will be identified for release from the Green Belt adjacent to settlement boundaries, as set out in policy SP5, so long as those sites fulfil the three criteria in SP4 A and B above.