Consultation Question 3

Comment

Representation ID: 15818

Received: 24/03/2021

Respondent: West Yorkshire Combined Authority (WYCA)

Spatial Priority Areas (SPA's) were first established in the 2014 SEP and have been amended several times since including summer 2020 with new areas to reflect wider policy priorities including regeneration and urban renewal, Towns Fund locations, and economic and environmental resilience.

The SPA's within Bradford District are currently:

Main Urban Centre - Bradford City Centre
Investment Locations - Mixed use - Canal Rd Corridor
- Regeneration - Shipley & Keighley
Future Growth Location - Apperley Bridge / Esholt & Holme Wood Urban Extension

Through the Leeds City Region SoCG Bradford have committed to the importance of SPAs, including Matters 7, 13 and 21 in the Statement which relate to 'Inclusive Growth', 'Housing' and 'Transport' respectively. While the plans proposals support these SPA's it would benefit from making greater reference to SPAs and their relevance to numerous policy areas.

Support

Representation ID: 16260

Received: 22/03/2021

Respondent: Robbie Feather

Agent: ID Planning

Whilst part A of the policy refers to the vision, objectives and Policy SP1, Part B of the policy does not include a specific reference to the delivery of housing in the District. Given this is such a key part of the plan and the spatial vision for Bradford, the policy should be amended to reflect this.

Required Change:
An additional criterion should be included under Part B of Policy SP2 which supports the delivery of housing to ensure that identified needs will be met over the plan period.

Part 6 of the policy supports the Local Service Centres in providing for homes and local services. Baildon is identified as a Local Service Centre, we support part 6 of the policy in supporting new homes in this and other local service centres

Support

Representation ID: 16319

Received: 24/03/2021

Respondent: Newett Homes

Agent: Quod North

Newett Homes support BCC’s commitment to supporting Local Service Centres (see Policy SP3 below) by providing for homes and local services. They are keen to work with BCC to achieve this and deliver sustainable development benefits through the delivery of their sites in Wilsden.

Object

Representation ID: 16715

Received: 24/03/2021

Respondent: Shipley Town Council

Concerned by the wording of part 4 relating to optimising opportunities provided by close proximity of Leeds International Airport.

This locks in a degree of economic dependence upon a very high-carbon activity, and influences land-use by providing a supposed justification for greenfield, road-based development between the city and the airport, including the use of Green Belt land.

Encouraging the increased use of Leeds Bradford International Airport is not compatible with Bradford Council’s zero carbon ambition as low carbon aviation cannot be achieved in this plan period and in fact to reach zero carbon it is highly probable that a contraction of air travel is in fact needed to prevent catastrophic climate change.

It is vital that Bradford develops an alternative strategy that is not reliant on the airport.

Support

Representation ID: 16953

Received: 23/03/2021

Respondent: Avant Homes

Agent: ID Planning

Support subject to amendment. Required Change:
An additional criterion should be included under Part B of Policy SP2 which supports the delivery of housing to ensure that identified needs will be met over the plan period.

Part 5 of the policy supports and enhances the roles of Principal Towns as hubs for the economy, housing, community and infrastructure. Ilkley is a Principal Town, we support part 5 of the policy in supporting new homes in this and other local service centres.

Object

Representation ID: 17162

Received: 24/03/2021

Respondent: The Norris & Holmes Families

Agent: Savills

In broad terms the NPPF indicates priority should be given to PDL. However there needs to be an appreciation of the risks involved in relying on complex city centre brownfield sites.

Over reliance on potentially constrained, contaminated or unviable PDL sites would result in the authority failing to identify sufficient deliverable and developable’ land for development.

With Bradford a lower value city when compared nationally it is unlikely to be attractive for large scale city/
district centre investment in historic buildings, such as mills, which represent higher build costs and increased
technical difficulties.

We also question whether high-density development in town and city centre locations will meet the requirements of the wider Bradford housing market given 80% of the schemes within the city centre are for flats (majority 1 and 2 bedroom).

Green Belt land which performs poorly against the 5 purposes and which scores well against regeneration credentials should be considered as suitable sites to help deliver the necessary housing mix across the district.

Comment

Representation ID: 17168

Received: 24/03/2021

Respondent: Jones Homes (Yorkshire) Limited

Agent: Savills (UK) Ltd

We support the broad principles of Policy SP2 as drafted, and the role of Cottingley as a Local Service Centre.

We however have significant concern over the draft Local Plan’s soundness in reference to the identified need to “meet the needs of the district. It is not considered that significant deviation from the Standard Methodology is likely to result in a Local Plan which will identify and allocate sufficient land to meet local need.

We do not propose amendments to Draft Policy SP2, however have made recommendation in relation to the local housing need and other policies below, to ensure their compliance with the Spatial Priorities.

Support

Representation ID: 17409

Received: 23/03/2021

Respondent: Mr & Mrs . Pyrah and Saunders

Number of people: 4

Agent: ID Planning

Support subject to amendment.
Whilst part A of the policy refers to the vision, objectives and Policy SP1, Part B of the policy does not include a specific reference to the delivery of housing in the District. Given this is such a key part of the plan and the spatial vision for Bradford, the policy should be amended to reflect this.

Required Change:
An additional criterion should be included under Part B of Policy SP2 which supports the delivery of housing to ensure that identified needs will be met over the plan period.

Support

Representation ID: 17495

Received: 23/03/2021

Respondent: Barratt Homes and David Wilson Homes

Agent: ID Planning

Support subject to amendment.
Part A of the policy refers to the vision, objectives and Policy SP1, however, Part B of the policy does not include a specific reference to the delivery of housing in the District. Given this is such a key part of the plan and the spatial vision for Bradford, the policy should be amended to reflect this.
Required Change:
An additional criterion should be included under Part B of Policy SP2 which supports the delivery of housing to ensure that identified needs will be met over the plan period.
Part 5 of the policy supports and enhances the roles of Local Growth Centres as hubs for the economy, housing, community and infrastructure. Steeton is a Local Growth Centre, we support part 5 of the policy in supporting new homes in this and other local service centres.

Support

Representation ID: 17675

Received: 23/03/2021

Respondent: Bannister Investments Limited

Agent: ID Planning

Support subject to amendments
Part B of the policy does not include a specific reference to the delivery of housing in the District. Given this is such a key part of the plan and the spatial vision for Bradford, the policy should be amended to reflect this.
Required Change:
An additional criterion should be included under Part B of Policy SP2 which supports the delivery of housing to ensure that identified needs will be met over the plan period.
Part 5 of the policy supports and enhances the roles of Local Growth Centres as hubs for the economy, housing, community and infrastructure. Burley in Wharfedale is a Local Growth Centre, and we support part 5 of the policy in supporting new homes in this and other local service centres.

Support

Representation ID: 18917

Received: 23/03/2021

Respondent: Mrs WE Nichol

Agent: Carter Jonas

Spatial Vision
We generally support the vision that sets out that the growth of the City of Bradford through the significant
increase in the delivery of new homes.

Q3: Policy SP2: Spatial Priorities
We support the spatial priorities set out in Policy SP2, in particular in relation to point 1 which supports the key
regeneration areas within the Regional City of Bradford including Allerton in West Bradford.

Support

Representation ID: 18927

Received: 23/03/2021

Respondent: Mrs J Kamyar

Agent: Carter Jonas

Spatial Vision
We generally support the vision that sets out that the growth of the City of Bradford through the significant
increase in the delivery of new homes.

Q3: Policy SP2: Spatial Priorities
We support the spatial priorities set out in Policy SP2, in particular in relation to point 1 which supports the key
regeneration areas within the Regional City of Bradford including Allerton in West Bradford.

Support

Representation ID: 18937

Received: 23/03/2021

Respondent: Mrs I Wood

Agent: Carter Jonas

Spatial Vision
We generally support the vision that sets out that the growth of the City of Bradford through the significant
increase in the delivery of new homes.

Q3: Policy SP2: Spatial Priorities
We support the spatial priorities set out in Policy SP2, in particular in relation to point 1 which supports the key
regeneration areas within the Regional City of Bradford including Allerton in West Bradford.

Support

Representation ID: 18947

Received: 23/03/2021

Respondent: Mr GRN Jones

Agent: Carter Jonas

Spatial Vision
We generally support the vision that sets out that the growth of the City of Bradford through the significant
increase in the delivery of new homes.

Q3: Policy SP2: Spatial Priorities
We support the spatial priorities set out in Policy SP2, in particular in relation to point 1 which supports the key
regeneration areas within the Regional City of Bradford including Allerton in West Bradford.

Object

Representation ID: 19759

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

We fundamentally disagree with the wording of SP2 B4 (“Optimise the opportunities provided by the close proximity of Leeds Bradford International Airport as an international business gateway for the District and the region and build upon sectoral expertise, worldwide connectivity and tourism.”).

Aviation expansion is simply incompatible with our region’s transition to a net-zero carbon future. This section of the Local Plan should therefore make it clear that the expansion of LBA will not be permitted and, indeed, that flights via this airport will be gradually reduced in line with the requirements of national legislation and related international climate agreements.

Object

Representation ID: 19805

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

We fundamentally disagree with the wording of SP2 B4 (“Optimise the opportunities provided by the close proximity of Leeds Bradford International Airport as an international business gateway for the District and the region and build upon sectoral expertise, worldwide connectivity and tourism.”).

Aviation expansion is simply incompatible with our region’s transition to a net-zero carbon future. This section of the Local Plan should therefore make it clear that the expansion of LBA will not be permitted and, indeed, that flights via this airport will be gradually reduced in line with the requirements of national legislation and related international climate agreements.

Object

Representation ID: 19833

Received: 01/04/2021

Respondent: Natural England

Natural England welcome the acknowledgement throughout the Draft Local Plan of the internationally important status of the South Pennine Moors as a Special Protection Area (SPA), and the inclusion of item 7 within Policy SP2, and advise that the wording could be made more robust, as follows:

"Protect, restore and enhance the District’s environmental resources for all including areas of international and national importance, such as the South Pennine Moors, the character and qualities of the Districts heritage, landscape and countryside and maximise the contribution they can make to the delivery of wider economic and social objectives."

We also welcome the inclusion of items 8 and 9 of Policy SP2, in that they relate to minimising and mitigating environmental threats, building resilience to climate change, and to enhancing biodiversity in the Metropolitan District.

Object

Representation ID: 21787

Received: 23/03/2021

Respondent: Duncan Watson

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

Object

Representation ID: 21879

Received: 23/03/2021

Respondent: Catherine Starling

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

Object

Representation ID: 21908

Received: 23/03/2021

Respondent: Dr Samantha Cook

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

Object

Representation ID: 21937

Received: 23/03/2021

Respondent: Birgit Almond

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

Object

Representation ID: 21966

Received: 23/03/2021

Respondent: Mrs Corrie Hardaker

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

Object

Representation ID: 21995

Received: 23/03/2021

Respondent: Carly Mitchell

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

Object

Representation ID: 22024

Received: 23/03/2021

Respondent: Helen Ross

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

Object

Representation ID: 22056

Received: 23/03/2021

Respondent: Rebecca Spencer

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

Object

Representation ID: 22085

Received: 23/03/2021

Respondent: Lucy Ashton

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

Object

Representation ID: 22114

Received: 23/03/2021

Respondent: Mr Chris Turner

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

Object

Representation ID: 22143

Received: 23/03/2021

Respondent: Judy Breckett

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

Object

Representation ID: 22183

Received: 23/03/2021

Respondent: Mr Paul Hardaker

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

Object

Representation ID: 22212

Received: 23/03/2021

Respondent: Helen Taylor

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