Consultation Question 2

Object

Representation ID: 6754

Received: 18/03/2021

Respondent: Mrs Jean Cawkwell

The Council are not positively planning for enough housing as required by the recently adopted Core Strategy and the government’s Local Housing Need requirement.
The Council should be positively planning for minimum of at least 2,300 homes per annum.

Comment

Representation ID: 9794

Received: 12/03/2021

Respondent: Bradford District Ward Councillor (Labour)

SP1 I would particularly like to draw attention to the access to green spaces. The incorporation of open park areas is particularly poor in my part of Bradford district (Keighley). Within my ward there are no parks and the little signage to support use of the countryside. This is a marked contrast to other parts of the country where the housing developments were built with accompanying park and recreation areas, along with ribbon strips to facilitate access and cycle/footpath sections, free from motor vehicles.

I am concerned that developments in Keighley West – a very wet area – disturb the natural resilience of the land to soak up water and have so far provided poor drainage schemes. In addition, this water will eventually reaches the Worth and Aire rivers, worsening the flood risk downstream. We should only allow developments that hold the water more successfully on the land and do not facilitate rapid drainage to the rivers.

Support

Representation ID: 10937

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We support this policy but note that the Council are failing to abide by its principles by not positively planning for the number of homes that are required, that was and continues to be clearly set out in the recently adopted Core Strategy and the Local Housing Need requirement.

For the new Local Plan to be found sound, it must positively plan for a minimum 2,300 homes per annum.

Based on a 20 year plan period which we advocate under our response to Question 1, this would equate to 46,000 new homes, which is very similar to that advocated in the adopted Core Strategy bearing in mind the proposed New Local Plan will plan for a longer period of time.

There is no credible evidence available to suggest this level of development cannot be adequately planned for and met in a sustainable manner within the City Region.

Object

Representation ID: 11368

Received: 17/03/2021

Respondent: Mr Robert Felstead

Clear disconnect between housing and infrastructure delivery. Lack of coherent transport policy means Plan does not confirm to NPPF sustainability policy

Unviable brownfield land can supply a significant contribution to meeting housing needs if remedial action is taken on unviable land as can the 5,000 unoccupied dwellings in key areas. Noted that viability has been a long term issue and that regeneration is a long held aspiration – query what progress has been made and what has been delivered. Long-term failure in addressing an ongoing issue affecting delivery of homes where they are most needed, close to jobs and in areas most in need of affordable housing. Should look at practice elsewhere.

Need to address expansion of Leeds Bradford Airport. Should understand the health, welfare and air quality impacts of it on residents in Wharfedale from aviation.

Plan does not prioritise the allocation of brownfield and non-Green Belt sites first.

Support

Representation ID: 12162

Received: 19/03/2021

Respondent: Highways England (Yorkshire & North East Team)

It is considered by CH2M that Highways England should support the aspirations of Policy SP1 which looks to presume in favour of sustainable development, underpinned by three objectives.

However, in order for this policy to be effective, the Local Plan needs to be supported by a robust transport evidence base to enable sites to emerge sustainably. Additional Work Required

Comment

Representation ID: 13883

Received: 20/03/2021

Respondent: John Finnigan

Policy SP1 a. “Applies a flood risk sequential approach to direct development to areas of lowest flood risk.”

3.2.8 talks of Bradford’s history of “early detection of flood risk”.

Question 2 asks for comment on this, and I agree.

Support

Representation ID: 16259

Received: 22/03/2021

Respondent: Robbie Feather

Agent: ID Planning

We support the proposed Policy SP1 which sets out the presumption in favour of sustainable development and supports the three objectives of sustainable development.

Object

Representation ID: 16318

Received: 24/03/2021

Respondent: Newett Homes

Agent: Quod North

Newett Homes generally support the approach set out under Policy SP1. However, Part B (Supporting the Three Objectives of Sustainable Development) does not directly align with NPPF Paragraph 8.

For example, the economic objective is focused on supporting employment uses, whereas national policy more generally refers to supporting the economy, through development “of the right types… in the right places”.

Economic growth is dependent on residential (and other) development that, when planned for together (in mutually beneficial ways), deliver genuinely sustainable development and contribute to economic strength, responsiveness and competitiveness.

Policy SP1 should better align with the NPPF’s sustainable development objectives, or simply refer back to the NPPF, otherwise the DBLP will not be consistent with national policy and will be unsound (NPPF Paragraph 35(d)).

Object

Representation ID: 16714

Received: 24/03/2021

Respondent: Shipley Town Council

Wording additions and changes are proposed to address the following issues:

To ensure that SP1 does puts achieving zero carbon at the heart of the Local Plan;

Under SP1:B4 we want to see attention also given to reducing health inequalities.

The Local Plan must take into consideration the impact on the environment of any proposed new developments. This should be in regard to:
● Carbon emissions
● Air pollution
● Biodiversity
● Other environmental pollution including water, light, noise, odour, soil

Criteria are proposed to guide the selection of sites in the most sustainable locations.

Support

Representation ID: 16871

Received: 23/03/2021

Respondent: Avant Homes

Agent: ID Planning

We support the proposed Policy SP1 which sets out the presumption in favour of sustainable development and supports the three objectives of sustainable development.

Support

Representation ID: 17408

Received: 23/03/2021

Respondent: Mr & Mrs . Pyrah and Saunders

Number of people: 4

Agent: ID Planning

We support the proposed Policy SP1 which sets out the presumption in favour of sustainable development and supports the three objectives of sustainable development.

Support

Representation ID: 17494

Received: 23/03/2021

Respondent: Barratt Homes and David Wilson Homes

Agent: ID Planning

We support the proposed Policy SP1 which sets out the presumption in favour of sustainable development and supports the three objectives of sustainable development.

Support

Representation ID: 17674

Received: 23/03/2021

Respondent: Bannister Investments Limited

Agent: ID Planning

We support the proposed Policy SP1 which sets out the presumption in favour of sustainable development and supports the three objectives of sustainable development.

Object

Representation ID: 19758

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

A number of suggestions for detailed wording changes and wording additions are made focusing on:

- Putting the achievement of net zero carbon by 2030 at the heart of the Local Plan
- greater emphasis on tackling spatial inequalities across the district particularly in health and well being (additions to part B4 of the policy);
- ensuring that the impact on the environment of any proposed new developments is taken into account more fully (additions / alterations are proposed to part B5 of the policy relating to site selection principles)
- accessibility of sites by non car modes of travel

Object

Representation ID: 19804

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

A number of suggestions for detailed wording changes and wording additions are made focusing on:

- Putting the achievement of net zero carbon by 2030 at the heart of the Local Plan
- greater emphasis on tackling spatial inequalities across the district particularly in health and well being (additions to part B4 of the policy);
- ensuring that the impact on the environment of any proposed new developments is taken into account more fully (additions / alterations are proposed to part B5 of the policy relating to site selection principles)
- accessibility of sites by non car modes of travel

Object

Representation ID: 19832

Received: 01/04/2021

Respondent: Natural England

Natural England advise that item B3 of Policy SP1 could be strengthened as follows:

"It will meet the environmental objectives by the inclusion of a suite of policies designed to protect, conserve, restore and enhance the District’s environmental assets, by focusing development within its main urban areas and by investing in public transport infrastructure in the process, reducing the need to travel by car and reducing climate change emissions;"

We welcome the commitment to ensuring that a sequential approach is taken to site selection and allocation as set out within item B5 of Policy SP1, and advise that item e) could be fortified by expanding the areas for consideration within the context of adverse environmental impacts, and by referring to the mitigation hierarchy, as follows:

"Ensures that wherever possible development enables the enhancement of the built and natural environment and minimises the adverse environmental impacts of growth, in particular with regards to climate change, air quality, biodiversity, geodiversity, ancient woodlands, soils, priority habitats, ecological networks and protected species."

Object

Representation ID: 21786

Received: 23/03/2021

Respondent: Duncan Watson

A. There is a disconnect between housing and infrastructure delivery. Bradford’s lack of a coherent transport strategy indicates that the Local Plan does not conform to NPPF sustainability policy [s2 7-14].

B. Ref B3 and 3.2.11: we agree this is an important issue but would question whether any progress will be made. Other authorities e.g. Leeds, Manchester and Nottingham have faced the same issue but put in place concrete plans to address them.

Ref B4 aligns with Bradford’s January 2019 declaration of a climate emergency and is a good policy statement but question whether Bradford’s actions meet this aspiration e.g in their attitude toward Leeds Bradford Airport which shows no consideration for Wharfedale residents.

Ref 5b; 1.2.9: we agree with the statements - but do not believe that in practice the allocation of brownfield and non-green belt land is being prioritised first.

Object

Representation ID: 21878

Received: 23/03/2021

Respondent: Catherine Starling

A. There is a disconnect between housing and infrastructure delivery. Bradford’s lack of a coherent transport strategy indicates that the Local Plan does not conform to NPPF sustainability policy [s2 7-14].

B. Ref B3 and 3.2.11: we agree this is an important issue but would question whether any progress will be made. Other authorities e.g. Leeds, Manchester and Nottingham have faced the same issue but put in place concrete plans to address them.

Ref B4 aligns with Bradford’s January 2019 declaration of a climate emergency and is a good policy statement but question whether Bradford’s actions meet this aspiration e.g in their attitude toward Leeds Bradford Airport which shows no consideration for Wharfedale residents.

Ref 5b; 1.2.9: we agree with the statements - but do not believe that in practice the allocation of brownfield and non-green belt land is being prioritised first.

Object

Representation ID: 21907

Received: 23/03/2021

Respondent: Dr Samantha Cook

A. There is a disconnect between housing and infrastructure delivery. Bradford’s lack of a coherent transport strategy indicates that the Local Plan does not conform to NPPF sustainability policy [s2 7-14].

B. Ref B3 and 3.2.11: we agree this is an important issue but would question whether any progress will be made. Other authorities e.g. Leeds, Manchester and Nottingham have faced the same issue but put in place concrete plans to address them.

Ref B4 aligns with Bradford’s January 2019 declaration of a climate emergency and is a good policy statement but question whether Bradford’s actions meet this aspiration e.g in their attitude toward Leeds Bradford Airport which shows no consideration for Wharfedale residents.

Ref 5b; 1.2.9: we agree with the statements - but do not believe that in practice the allocation of brownfield and non-green belt land is being prioritised first.

Object

Representation ID: 21936

Received: 23/03/2021

Respondent: Birgit Almond

A. There is a disconnect between housing and infrastructure delivery. Bradford’s lack of a coherent transport strategy indicates that the Local Plan does not conform to NPPF sustainability policy [s2 7-14].

B. Ref B3 and 3.2.11: we agree this is an important issue but would question whether any progress will be made. Other authorities e.g. Leeds, Manchester and Nottingham have faced the same issue but put in place concrete plans to address them.

Ref B4 aligns with Bradford’s January 2019 declaration of a climate emergency and is a good policy statement but question whether Bradford’s actions meet this aspiration e.g in their attitude toward Leeds Bradford Airport which shows no consideration for Wharfedale residents.

Ref 5b; 1.2.9: we agree with the statements - but do not believe that in practice the allocation of brownfield and non-green belt land is being prioritised first.

Object

Representation ID: 21965

Received: 23/03/2021

Respondent: Mrs Corrie Hardaker

A. There is a disconnect between housing and infrastructure delivery. Bradford’s lack of a coherent transport strategy indicates that the Local Plan does not conform to NPPF sustainability policy [s2 7-14].

B. Ref B3 and 3.2.11: we agree this is an important issue but would question whether any progress will be made. Other authorities e.g. Leeds, Manchester and Nottingham have faced the same issue but put in place concrete plans to address them.

Ref B4 aligns with Bradford’s January 2019 declaration of a climate emergency and is a good policy statement but question whether Bradford’s actions meet this aspiration e.g in their attitude toward Leeds Bradford Airport which shows no consideration for Wharfedale residents.

Ref 5b; 1.2.9: we agree with the statements - but do not believe that in practice the allocation of brownfield and non-green belt land is being prioritised first.

Object

Representation ID: 21994

Received: 23/03/2021

Respondent: Carly Mitchell

A. There is a disconnect between housing and infrastructure delivery. Bradford’s lack of a coherent transport strategy indicates that the Local Plan does not conform to NPPF sustainability policy [s2 7-14].

B. Ref B3 and 3.2.11: we agree this is an important issue but would question whether any progress will be made. Other authorities e.g. Leeds, Manchester and Nottingham have faced the same issue but put in place concrete plans to address them.

Ref B4 aligns with Bradford’s January 2019 declaration of a climate emergency and is a good policy statement but question whether Bradford’s actions meet this aspiration e.g in their attitude toward Leeds Bradford Airport which shows no consideration for Wharfedale residents.

Ref 5b; 1.2.9: we agree with the statements - but do not believe that in practice the allocation of brownfield and non-green belt land is being prioritised first.

Object

Representation ID: 22023

Received: 23/03/2021

Respondent: Helen Ross

A. There is a disconnect between housing and infrastructure delivery. Bradford’s lack of a coherent transport strategy indicates that the Local Plan does not conform to NPPF sustainability policy [s2 7-14].

B. Ref B3 and 3.2.11: we agree this is an important issue but would question whether any progress will be made. Other authorities e.g. Leeds, Manchester and Nottingham have faced the same issue but put in place concrete plans to address them.

Ref B4 aligns with Bradford’s January 2019 declaration of a climate emergency and is a good policy statement but question whether Bradford’s actions meet this aspiration e.g in their attitude toward Leeds Bradford Airport which shows no consideration for Wharfedale residents.

Ref 5b; 1.2.9: we agree with the statements - but do not believe that in practice the allocation of brownfield and non-green belt land is being prioritised first.

Object

Representation ID: 22055

Received: 23/03/2021

Respondent: Rebecca Spencer

A. There is a disconnect between housing and infrastructure delivery. Bradford’s lack of a coherent transport strategy indicates that the Local Plan does not conform to NPPF sustainability policy [s2 7-14].

B. Ref B3 and 3.2.11: we agree this is an important issue but would question whether any progress will be made. Other authorities e.g. Leeds, Manchester and Nottingham have faced the same issue but put in place concrete plans to address them.

Ref B4 aligns with Bradford’s January 2019 declaration of a climate emergency and is a good policy statement but question whether Bradford’s actions meet this aspiration e.g in their attitude toward Leeds Bradford Airport which shows no consideration for Wharfedale residents.

Ref 5b; 1.2.9: we agree with the statements - but do not believe that in practice the allocation of brownfield and non-green belt land is being prioritised first.

Object

Representation ID: 22084

Received: 23/03/2021

Respondent: Lucy Ashton

A. There is a disconnect between housing and infrastructure delivery. Bradford’s lack of a coherent transport strategy indicates that the Local Plan does not conform to NPPF sustainability policy [s2 7-14].

B. Ref B3 and 3.2.11: we agree this is an important issue but would question whether any progress will be made. Other authorities e.g. Leeds, Manchester and Nottingham have faced the same issue but put in place concrete plans to address them.

Ref B4 aligns with Bradford’s January 2019 declaration of a climate emergency and is a good policy statement but question whether Bradford’s actions meet this aspiration e.g in their attitude toward Leeds Bradford Airport which shows no consideration for Wharfedale residents.

Ref 5b; 1.2.9: we agree with the statements - but do not believe that in practice the allocation of brownfield and non-green belt land is being prioritised first.

Object

Representation ID: 22113

Received: 23/03/2021

Respondent: Mr Chris Turner

A. There is a disconnect between housing and infrastructure delivery. Bradford’s lack of a coherent transport strategy indicates that the Local Plan does not conform to NPPF sustainability policy [s2 7-14].

B. Ref B3 and 3.2.11: we agree this is an important issue but would question whether any progress will be made. Other authorities e.g. Leeds, Manchester and Nottingham have faced the same issue but put in place concrete plans to address them.

Ref B4 aligns with Bradford’s January 2019 declaration of a climate emergency and is a good policy statement but question whether Bradford’s actions meet this aspiration e.g in their attitude toward Leeds Bradford Airport which shows no consideration for Wharfedale residents.

Ref 5b; 1.2.9: we agree with the statements - but do not believe that in practice the allocation of brownfield and non-green belt land is being prioritised first.

Object

Representation ID: 22142

Received: 23/03/2021

Respondent: Judy Breckett

A. There is a disconnect between housing and infrastructure delivery. Bradford’s lack of a coherent transport strategy indicates that the Local Plan does not conform to NPPF sustainability policy [s2 7-14].

B. Ref B3 and 3.2.11: we agree this is an important issue but would question whether any progress will be made. Other authorities e.g. Leeds, Manchester and Nottingham have faced the same issue but put in place concrete plans to address them.

Ref B4 aligns with Bradford’s January 2019 declaration of a climate emergency and is a good policy statement but question whether Bradford’s actions meet this aspiration e.g in their attitude toward Leeds Bradford Airport which shows no consideration for Wharfedale residents.

Ref 5b; 1.2.9: we agree with the statements - but do not believe that in practice the allocation of brownfield and non-green belt land is being prioritised first.

Object

Representation ID: 22182

Received: 23/03/2021

Respondent: Mr Paul Hardaker

A. There is a disconnect between housing and infrastructure delivery. Bradford’s lack of a coherent transport strategy indicates that the Local Plan does not conform to NPPF sustainability policy [s2 7-14].

B. Ref B3 and 3.2.11: we agree this is an important issue but would question whether any progress will be made. Other authorities e.g. Leeds, Manchester and Nottingham have faced the same issue but put in place concrete plans to address them.

Ref B4 aligns with Bradford’s January 2019 declaration of a climate emergency and is a good policy statement but question whether Bradford’s actions meet this aspiration e.g in their attitude toward Leeds Bradford Airport which shows no consideration for Wharfedale residents.

Ref 5b; 1.2.9: we agree with the statements - but do not believe that in practice the allocation of brownfield and non-green belt land is being prioritised first.

Object

Representation ID: 22211

Received: 23/03/2021

Respondent: Helen Taylor

A. There is a disconnect between housing and infrastructure delivery. Bradford’s lack of a coherent transport strategy indicates that the Local Plan does not conform to NPPF sustainability policy [s2 7-14].

B. Ref B3 and 3.2.11: we agree this is an important issue but would question whether any progress will be made. Other authorities e.g. Leeds, Manchester and Nottingham have faced the same issue but put in place concrete plans to address them.

Ref B4 aligns with Bradford’s January 2019 declaration of a climate emergency and is a good policy statement but question whether Bradford’s actions meet this aspiration e.g in their attitude toward Leeds Bradford Airport which shows no consideration for Wharfedale residents.

Ref 5b; 1.2.9: we agree with the statements - but do not believe that in practice the allocation of brownfield and non-green belt land is being prioritised first.

Object

Representation ID: 22240

Received: 23/03/2021

Respondent: Dr Ceri Pitches

A. There is a disconnect between housing and infrastructure delivery. Bradford’s lack of a coherent transport strategy indicates that the Local Plan does not conform to NPPF sustainability policy [s2 7-14].

B. Ref B3 and 3.2.11: we agree this is an important issue but would question whether any progress will be made. Other authorities e.g. Leeds, Manchester and Nottingham have faced the same issue but put in place concrete plans to address them.

Ref B4 aligns with Bradford’s January 2019 declaration of a climate emergency and is a good policy statement but question whether Bradford’s actions meet this aspiration e.g in their attitude toward Leeds Bradford Airport which shows no consideration for Wharfedale residents.

Ref 5b; 1.2.9: we agree with the statements - but do not believe that in practice the allocation of brownfield and non-green belt land is being prioritised first.