Object

Representation ID: 5499

Received: 24/03/2021

Respondent: CPRE West Yorkshire

The policy contains a significant internal contradiction: (4) makes the airport a spatial priority, but dependence on the airport as an economic driver is very likely to undermine moves towards a green economy and the low carbon future, as envisaged by (8). Further, there is the risk that identifying the airport as a spatial priority locks in further road based economic development at relatively low employment densities.
The only alternatives to the spatial strategy presented are whether the policies should be more or less comprehensive and more or less specific in their scope, but there is no consideration of an alternative strategy. In our view an alternative that should be fully considered is for the airport not to be a spatial priority and to consider the extent to which that would enable the other objectives of the plan to be better implemented.
Despite the increased proportion of housing growth within the Regional City compared to the adopted Core Strategy the proportion of new development being directed to brownfield sites remains at 50%. Considering the significantly increased emphasis given to making effective use of land in NPPF2019 compared to NPPF2012 (against which the adopted Cost Strategy was assessed), it would be reasonable to expect the percentage of development on brownfield land to have increased, and it is unclear why this is not the case.
It is important to consider whether the achievement of the development expectations set out in SP2B (7) to (12) would be more effectively achieved with a greater focus on brownfield sites, and this has not been adequately evidenced. We would therefore contend that an alternative strategy of pursuing a significantly higher concentration of development onto brownfield sites has not been fully tested.