Consultation Question 2

Object

Representation ID: 27957

Received: 24/03/2021

Respondent: Bellway Homes Limited

Agent: Barton Wilmore

Whilst our Client supports the Council’s commitment to the presumption in favour of sustainable development, national guidance is clear that local plans should avoid unnecessary repetition of national policy. As such, part A of the policy should be deleted as it is unnecessary and repeats paragraph 11 of the National Planning Policy Framework. We recently appeared at the Doncaster Council Local Plan Examination and the Inspector requested that the Council delete their presumption in favour of sustainable development policy, which they have subsequently proposed through Main Modifications.

We would also question whether part B of the policy is necessary as the detailed development management policies effectively demonstrate how the authority will encourage developments which meet the three elements of sustainable development.

Object

Representation ID: 28182

Received: 24/03/2021

Respondent: Sarah Lucas

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: 28272

Received: 24/03/2021

Respondent: Stephen Mould

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: 28360

Received: 21/03/2021

Respondent: Mr Cengiz Philcox

Consultation period is not long enough to comment on a massively complex, detailed plan. It is tokenistic. Undertaking take into the middle of a pandemic is cynical.

Plant faces several serious crises (biodiversity/ecosystem collapse, climate chaos, flooding, global health crisis). Plan will smother areas of Green Belt, nature reserves and agricultural land in development. It is part of the problem, not the solution.

Building on Green Belt land contravenes Government policy. Boundaries can only be changed in exceptional circumstances and inappropriate development approved only in very special circumstances. What the very special circumstances for releasing sites from the Green Belt.

Area has ex-industrial past. It full of brownfield/potential brownfield sites. Keighley College building has pulled down with proposed use for the site. Marley incinerator site provides no communities benefit. Would have been a perfect housing site, providing a benefit.

No concern for welfare of citizens or natural heritage and character.

Object

Representation ID: 28500

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

Whilst our Client supports the Council’s commitment to the presumption in favour of sustainable development, national guidance is clear that local plans should avoid unnecessary repetition of national policy. As such, part A of the policy should be deleted as it is unnecessary and repeats paragraph 11 of the National Planning Policy Framework. We recently appeared at the Doncaster Council Local Plan Examination and the Inspector requested that the Council delete their presumption in favour of sustainable development policy, which they have subsequently proposed through Main Modifications.

We would also question whether part B of the policy is necessary as the detailed development management policies effectively demonstrate how the authority will encourage developments which meet the three elements of sustainable development.

Object

Representation ID: 28501

Received: 25/02/2021

Respondent: Dr Ros Brown

The overall strategic outcomes of any local plan should be:
1. net reductions in greenhouse gas emissions
2. net reductions in car traffic
3. net reductions in pollution
4. net enhancement of biodiversity
5. net increase in access to green space
6. net reduction in flood risk
7. and the benefits of these outcomes should be socially and spatially equitable.

SP1A is a reiteration of NPPF’s presumption in favour of sustainable development and we see no need to comment on that.

Part B is expressing Bradford’s local interpretation and application the presumption. Referring to our headline aspirations for all local plans, we consider that SP1B needs to be much more clear and specific about the need to achieve high-level, net enhancements to social, environmental and economic well-being.

The Plan should adopt this net gain approach at the top level, by expressing these clearly at the beginning of the plan in SP1.

Support

Representation ID: 28664

Received: 24/03/2021

Respondent: Chatsworth Settlement Trustees

CST supports the overall emphasis on achieving sustainable development and recognition of its economic, environmental and social dimensions.

Object

Representation ID: 29048

Received: 29/03/2021

Respondent: Historic England

B3 - the environmental objectives of sustainable development, a minor amendment is necessary to closely reflect the definition of the environment used in NPPF paragraph 8c. We welcome the intention that the Council’s approach to site selection under Criterion B5e will, wherever possible, enable the enhancement of the built and natural environment and minimises the adverse environmental impacts of growth, we request that a specific reference to heritage assets is added to the second half of the sentence where particular considerations are highlighted.
B.2, amend to read:
“It will meet the environmental objectives by the inclusion of a suite of policies designed to protect, conserve and enhance the natural, built and historic environment. By focussing development in 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;
and” B.5.e, amend to read:
“e. 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, habitats and heritage assets.”

Object

Representation ID: 29131

Received: 24/03/2021

Respondent: Environment Agency

We support the promotion of sustainable development – which applies to economic, social and environmental aspects. However when it comes to new development we do not necessarily fully agree with the approach of site selection that, “wherever possible maximises the use of previously developed land”.

There are circumstances where this may not be the environmentally optimal solution. Previously developed land in an urban area can (or perhaps should) support a diversity of wildlife, (sometimes) more so than intensely managed countryside sites.

For example, a brownfield site can also be important stepping stone within an existing wildlife corridor, and therefore can be valuable in providing connectivity within ecological networks. This is particularly relevant where previously developed land lies next to rivers and streams – as these are the only location where the river environment can be improved to provide the blue infrastructure that is valuable (for health, wellbeing, biodiversity and climate change mitigation etc.).

As such, we recommend that where brownfield sites exist alongside watercourses, there should be a presumption for new development to be set-back, to include an undeveloped buffer zone or, in some cases, for the site to not be developed. This is to allow for natural recovery of green-blue infrastructure, the provision and enhancement of ecological networks and to increase climate change resilience.

Object

Representation ID: 29132

Received: 24/03/2021

Respondent: Environment Agency

We also recommend the inclusion of additional wording / wording changes (underlined) to bullet point e in order to strengthen the policy – so that it reads: “ensures that wherever possible development enables the enhancement of the built and natural environment and avoids, minimises and, where necessary, mitigates for the adverse environmental impacts of growth, in particular with regards to climate change, air quality, biodiversity and habitats”.

This wording change proposal is to ensure that the high level strategic policy is well aligned with thematic polices references later within the local plan (e.g. Policy EN2).

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.

Object

Representation ID: 29205

Received: 23/03/2021

Respondent: Rachel Wood

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: 29558

Received: 23/03/2021

Respondent: Harvey Bosomworth

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: 29598

Received: 17/03/2021

Respondent: Mr Mark Summerson

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.

Comment

Representation ID: 29631

Received: 24/03/2021

Respondent: Kirklees Metropolitan Council

• Greater reference to cross-boundary working within policies – the council believes that there could be greater reference to cross-boundary working including within policies relating to the highway network (Policy SP1, SP3), White Rose Forest (Policy EN3), Mass Transit (Policy SP6) and strategic green infrastructure (Policy SP10).

Object

Representation ID: 29702

Received: 24/03/2021

Respondent: Keyland Developments Ltd

Agent: Barton Wilmore

Whilst our Client supports the Council’s commitment to the presumption in favour of sustainable development, national guidance is clear that local plans should avoid unnecessary repetition of national policy.

As such, part A of the policy should be deleted as it is unnecessary and repeats paragraph 11 of the National Planning Policy Framework.

We recently appeared at the Doncaster Council Local Plan Examination and the Inspector requested that the Council delete their presumption in favour of sustainable development policy, which they have subsequently proposed through Main Modifications.

We would also question whether part B of the policy is necessary as the detailed development management policies effectively demonstrate how the authority will encourage developments which meet the three elements of sustainable development.

Support

Representation ID: 29806

Received: 23/03/2021

Respondent: Addingham Parish Council

The Parish Council welcomes the clarification of a number of strategic policies in the Local Plan, and wholly supports policies for sustainable growth and development in the district which prioritise the use of brown field sites and which work towards the regeneration of key areas.
The Council is particularly pleased to note the increased emphasis on strategies designed to achieve net zero carbon emissions by means of promoting greener lifestyles and practices, and recognising the value of green infrastructure and open spaces.

Object

Representation ID: 29997

Received: 23/03/2021

Respondent: Daniel 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: 30078

Received: 23/03/2021

Respondent: Mrs Savia Lorain Hughes

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: 30161

Received: 23/03/2021

Respondent: Catherine Terry

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.