Consultation Question 3

Object

Representation ID: 288

Received: 19/02/2021

Respondent: Ms Mel Frances

The expansion of Leeds Bradford Airport, the planned incinerator and the continuous widening of road networks for vehicles does not do anything to counter the environmental threat faced by Bradford.
Sadly, the term regeneration often amounts to building eyesores and densifying populations rather than improving the physical environment and air quality. Perhaps more could be done to improve existing areas, housing and communities that have little green space, no gardens and a strewn with litter and enveloped in pollution.

Object

Representation ID: 783

Received: 05/03/2021

Respondent: Clive Brook Planning

While various aspects of this policy are supported I and my clients have objections to certain sub policies, some of which can be overcome by extended/clarified policy statements and some which require changes across several related policies.

Support

Representation ID: 1201

Received: 10/03/2021

Respondent: Mr Paul Holmes

There needs to be development to support the future prosperity of the district. this needs to be done in an appropriate way on suitable ground that is not susceptible to flooding or subsidence. If followed appropriately this will deliver suitable industrial and social building opportunities for businesses and residents without concerns of having excessive remedial work to undertake in the future.

Object

Representation ID: 1503

Received: 14/03/2021

Respondent: Lightowler Associates

Proposed measures will put increased pressure on an already challenged traffic system. The proposed size of developments IL1/H and IL3/H would preclude high quality development in keeping with existing properties in the area. (see also representations made to these sites).

Support

Representation ID: 1874

Received: 16/03/2021

Respondent: Sir Stephen Brown

SUPPORT

Object

Representation ID: 1904

Received: 17/03/2021

Respondent: Burley Parish Council

A. BPC’s view on sustainability is expressed in Q2.
B. B8 contradicts BDMC’s support for LBA’s expansion plans.

Support

Representation ID: 2446

Received: 20/03/2021

Respondent: Mr Peter Down

In principle, I support the proposed policy SP2. However, to date City of Bradford MDC appears to have treated the outlying areas (especially Bingley) as suburbs, and extensions of Bradford. There needs to be a greater emphasis on treating the Principal Towns and Local Centres as unique with policies that are tailored to them and plays to their strengths. Treating every area in a similar manner to the City Centre is not acceptable. The COVID-19 pandemic has highlighted that there is a desire for more local services and community facilities to avoid the need to have to travel into Bradford City Centre. In addition, the green spaces between the various areas should be respected to help retain each area’s unique identity and maintain spatial separation. Having this type of approach should also benefit the proposed environmental and social policies.

Object

Representation ID: 2604

Received: 20/03/2021

Respondent: BANDAG - Keighley

This is not simple so please apply to appropirate area: The Presumption in Favour of Sustainable Development - Draft South Pennine Moors SPA/SAC Planning Framework Supplementary Planning Document

"1.2 The South Pennine Moors are designated in accordance with European legislation, in recognition of their wildlife interest of international importance. Any proposals for development around the European sites (WITHIN 7km) pose risks that need to be addressed before planning permission can be granted"
There is no way any development on the Blue Green Corridors should be permitted. (River Worth, North Beck, River Aire. )
Instead all the Green Corridors should - in line with ALL European, National, Regional and local policies be conserved / preserved and enhanced.

Object

Representation ID: 2732

Received: 21/03/2021

Respondent: Mrs Helen Owen

The policy almost says all the right things but is very vague and does not properly specify how to protect the principal town of Bingley. Clean Air Xone does not reach Bingley. The building of an incinerator at Marley, in the bottom of the valley will have a negative impact on health through the whole Aire Valley. Increased traffic to service this site will also have a detrimental effect.

Support

Representation ID: 2831

Received: 21/03/2021

Respondent: Alison Tribe

I broadly support the policy but have two concerns:
- 'Optimising the opportunities of the airport' (B4) The arguments are well-rehearsed. Air travel is one of the main contributors to carbon emissions. Bradford Authority must not support the expansion of the airport or encourage an increase in flights. Businesses should be encouraged, by the provision of first class digital resources, to carry out their work without needing to fly.
- Points 10 - 12 sound great, but will require more oversight of new developments, a more 'hardline' approach to planning applications and a more holistic, long-sighted vision for settlements. Two new, large residential developments in Silsden have completely changed the 'local character', and placing the new school on the edge of the village will lead to greater use of cars to get kids to school. It won't lead to a shift to 'sustainable and active forms of movement'.

Support

Representation ID: 3273

Received: 22/03/2021

Respondent: Wilsden Parish Council

We note the commitment to the involvement of Communities in Local Planning in para 3.2.7. We propose that Policy SP2 11 should be strengthened such that where a Neighbourhood Plan develops policies on design that these policies should be considered as the primary expression of local character, community and distinctiveness.

Support

Representation ID: 3352

Received: 22/03/2021

Respondent: Ms Julie Townsend

I largely support the spatial priorities, but recommend that greater integration is needed across these priorities and different aspects of local planning and development. Through my work I know that almost all new housing developments (nationally) are poorly sited in relation to sustainable transport, locking new residents into either car-dependency or limited mobility (see Transport for New Homes). Conversely, behavioural research shows that when people move home, it provides a crucial opportunity for influencing sustainable behaviours, such as use of public transport/active travel. If planning, transport and other areas of development were joined up, it would enable such opportunities to be seized, and the cycle of car-dependent communities to be addressed.

I additionally disagree with the references to 'sustainable growth'. Much sustainable development research shows it is an obsession with growth that has led to environmental crises and widening inequality, and recommends we become 'agnostic' about growth (see Doughnut Economics).

Support

Representation ID: 3461

Received: 22/03/2021

Respondent: NEAT

It is significant that the first point ("transform...") does not mention health, which is relegated to paragraph 12 with a reference to healthy places (not people?). Given the poor health in Bradford, assessment of health impacts (physical and mental) of every planning proposal should be front and centre of this policy.
If health inequalities are to be reduced, urban dwellers must not be saddled with the negative impacts of loss of surviving open space.

Object

Representation ID: 3670

Received: 23/03/2021

Respondent: Mr Philip Sutcliffe

The green belt was set up to stop urban expansion. In the case of Bradford, to stop it becoming part of Leeds. Bradford planning office being completely undemocratic wishes to pour cement and tarmac all over the green belt in Tong. The reason I say undemocratic is as follows. ~There has not been one survey, or opinion poll taken in Bradford, which agrees with Bradford councils views on building on green belt. In fact approx 90 % of population of Bradford totally disagree with Bradford councils housing and road plans. However, the council which claims represents the people is acting like a fascist state.

Your new road and housing plans directly effect my Grade II house and land. However, you have not had the decency to contact me over the last 10 years. I doubt you care less about me than the environment and the creatures that need it.

Support

Representation ID: 3763

Received: 23/03/2021

Respondent: Mr Andrew Lund

While I support the aims of this policy I contend that several proposals elsewhere in the draft local plan fail to comply with it. As an example, the plan to remove 16ha of high landscape open space from the Green Belt surrounding Ilkley will not "Support, enhance and protect" as mandated in section 5. It will have the opposite effect.

Support

Representation ID: 3885

Received: 23/03/2021

Respondent: Mrs Susan Burn

I agree with the policy statement.

Support

Representation ID: 4868

Received: 24/03/2021

Respondent: Banks Property

Banks Property supports Policy SP2 which seeks to achieve sustainable development in line with the National Planning Policy Framework. Like the NPPF, this theme should be central to the entire Local Plan and spatial priorities within it. Policy SP2 states that Principal Towns and Local Growth Centres (including Burley in Wharfedale) will be supported, protected and enhanced as hubs for the local economy, housing and community. We support the creation of well designed, high quality development and sustainable places where people want to live and work. The allocation of employment land alongside housing to reduce the need to travel and ensure the vitality and viability of settlements is an important element of sustainable development. The draft Plan currently has an absence of employment land allocations in Wharfedale; this should be addressed to ensure sustainable growth is achieved.

Object

Representation ID: 5111

Received: 24/03/2021

Respondent: Mr Peter Jenkins

In general, many of the priorities are individually laudable but the overriding comment must be that the hitherto traditional programme of “development first, infrastructure (maybe) later” must be consigned to history. In many proposals this is clearly not so.
For Wharfedale in particular there are no details as to where meaningful employment growth is to come from, bearing in mind that transport, education and health services are already struggling.
The avoidance of flood risk in not obtained by building on flood plains (eg Sun Lane Burley in Wharfedale), nor environmental concern demonstrated by unnecessary building on Green Belt green fields when, for example, there are 5000 unoccupied properties in Bradford, and so much alternative lower grade land is available within the district.

Object

Representation ID: 5322

Received: 24/03/2021

Respondent: Baildon & Shipley Friends of the Earth

Baildon & Shipley FOE – SP2
1. Paragraphs (2) and (8) are contradictory. Promotion of air travel is incompatible with a low-carbon future and need to minimise environmental threats.
2. Mitigation along the lines of “adaptation” and “building resilience” is nonsense in this context.
3. Concentrate on identifying more brownfield sites. Could be enabled by providing greater density of housing as suggested by our submissions under SP6, SP7 and SP8.

Support

Representation ID: 5364

Received: 24/03/2021

Respondent: Ms Alison Neave

Like points 8 - 12 and that will try to promote well balanced economic improvements for the area whilst protecting people's quality of life and the environment and air quality.

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.

Support

Representation ID: 5688

Received: 24/03/2021

Respondent: Chatsworth Settlement Trustees

Agent: Richard Wood Associates

CST supports the priorities set out in Policy SP2. In particular the emphasis on transforming the economic, environmental, physical and social conditions of the District, with a particular focus on the Regional City of Bradford and key regeneration areas including Keighley. Similarly, the emphasis on supporting, protecting and enhancing the roles of the Principal Towns of Ilkley, Keighley and Bingley is an important spatial priority.

The commentary at paragraph 3.3.7 of the preferred options document provides a helpful and supported statement on the role of principal towns in that they “fulfil a District wide significant role as service, employment and transport hubs for their surrounding areas.

Object

Representation ID: 5901

Received: 24/03/2021

Respondent: SHMS

Summary
Question the role of growth centre designation, and key spatial priorities namely post 2015 Core Strategy, no significant jobs growth in these areas to support additional housing numbers.
Climate change, the Pandemic, need to reduce commuting and likely increased internet usage. will add further load on the existing poor infrastructure, for example no employment sites identified in Silsden, and only one in Steeton.
Airedale Hospital is main employer in the region, however the site is now constrained from major expansion due to recently built homes nearby. In addition I understand it is 48th on the list to be re-built due to the method of construction being outdated.

Object

Representation ID: 5906

Received: 24/03/2021

Respondent: Baildon & Shipley Friends of the Earth

Baildon & Shipley FOE – SP2
1. Paragraphs (2) and (8) are contradictory. Promotion of air travel is incompatible with a low-carbon future and need to minimise environmental threats.
2. Mitigation along the lines of “adaptation” and “building resilience” is nonsense in this context.
3. Concentrate on identifying more brownfield sites. Could be enabled by providing greater density of housing as suggested by our submissions under SP6, SP7 and SP8.

Comment

Representation ID: 6755

Received: 18/03/2021

Respondent: Mrs Jean Cawkwell

Queensbury should be a Local Growth Centre and as identified in the adopted Core Strategy, should also be identified as a “Growth Area”.
Not testing the adopted Core Strategy “Growth Area” policy in the new proposed Local Plan Sustainability Appraisal is a serious issue for the soundness of the plan.

Comment

Representation ID: 9795

Received: 12/03/2021

Respondent: Bradford District Ward Councillor (Labour)

SP2 (page 10) Under point 7 here you talk about the environmental resources and South Pennines – were Pennine Prospects a consultee (I can answer that, as a Director – No)? The issue for us in Keighley is access to this asset. This could be achieved by facilitating footpaths and rights of way along the natural routes out of Keighley – such as North Beck, which runs through my ward. You could also address the destruction of our cultural and industrial heritage at the same time.

Object

Representation ID: 10938

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We object to these policies on the following basis:
- there is justification to plan up to 2040 rather than 2038 and this should be noted in Policy SP2;
- the Policies should make reference to ‘Growth Areas’ as presented in the adopted Core Strategy where additional/extra planned growth for housing can take place;
- We consider Queensbury should be retained as a Growth Area, as provided in the adopted Core Strategy. It is capable of accommodating more homes than currently planned for and could achieve 1,000 homes as per the adopted Core Strategy. Again, this is not tested in the SA as a reasonable alternative;

Object

Representation ID: 11370

Received: 17/03/2021

Respondent: Mr Robert Felstead

A ...achieve sustainable development in line with National Planning Policy Framework and Policy SP1a/b.
My view about sustainability is expressed in the response to Question 2.

B .Planning decisions as well as plans, strategies, programmes and investment decisions should seek to:
From 8. “Ensure a move towards a green economy and a resilient lower energy and low carbon future”. This again contradicts Bradford Council’s support for LBA’s expansion plans.

Support

Representation ID: 12163

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 SP2 which looks to deliver the spatial vision, objectives and achieve sustainable development. However, in order for this policy to be effective and deliver the spatial vision 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: 13884

Received: 20/03/2021

Respondent: John Finnigan

Policy SP2 at paragraph 9 indicates that a spatial priority is to “Avoid increasing flood risk, and manage land and river catchments for flood mitigation”
Question 3 asks for comment, and I agree