Consultation Question 5

Support

Representation ID: 289

Received: 19/02/2021

Respondent: Ms Mel Frances

I support the reuse of urban land but green belt land needs to be protected and celebrated in all cases.

Object

Representation ID: 793

Received: 05/03/2021

Respondent: Clive Brook Planning

POLICY SC4:- LOCATION OF DEVELOPMENT
The policy should on balance be deleted as it serves very little if any purpose. It is far from clear in the written justification why a system of sequential selection or prioritisation of sites for allocation is necessary. In certain settlements there are few if any previously developed sites likely to come forward except on an unpredictable 'windfall' basis. Given past high rates of development of brownfield it has to be recognised that the opportunities for the future identification of potential brownfield allocations is severely restricted in at least one of the three principal towns and in other settlements in the lower tiers of the hierarchy. Similarly the opportunities for developing greenfield sites are greatly restricted in all tiers of the hierarchy as a result of existing greenfield uses or designations or the need for these to become publicly accessible open spaces in the future.

Object

Representation ID: 1067

Received: 09/03/2021

Respondent: Birkbeck, University of London

While some of this may be answered in the following point, this policy outline (SP4) does not give sufficient indication of the requirements that would be placed upon applications for green belt release. It also does not indicate if there would be any hard cap on green belt release for the whole district or lease within it, giving scope for potentially unlimited greenbelt release based on 'prioritisation' of factors not here presented. The wording - prioritisation of greenbelt release -, as opposed to prioritisation of greenbelt protection is very concerning. Surely priority should always be given to reducing greenbelt release as the primary consideration in any application?

Support

Representation ID: 1875

Received: 16/03/2021

Respondent: Sir Stephen Brown

SUPPORT

Object

Representation ID: 1906

Received: 17/03/2021

Respondent: Burley Parish Council

3.4.1; 3.4.2 - Please see Q2 for BPC’s comment on brownfield delivery. BPC strongly supports BDMC’s decision not to adopt the 35% urban centre uplift proposed by government as this is most likely to be delivered from Green Belt due to the stated non-viability of brownfield land.

Object

Representation ID: 2465

Received: 20/03/2021

Respondent: Mr Peter Down

Whilst I generally support the proposed policy SP4 in principle, I have to object on the basis of the potential impact to the current Green Belt (as also objected to for Policy SP5). Whilst the hierarchy of proposed development, with greater emphasis on brownfield development, is accepted, the potential to impact on Green Belt areas is opposed. The proposed adjustment of Green Belt areas appears to be a cynical attempt by City of Bradford MDC to permit development of numerous sites and increase urban sprawl whilst claiming there is no impact to Green Belt. This is not acceptable and appears to contravene the aim to respect and maintain Green Belt areas as indicated elsewhere in the Local Plan.

Object

Representation ID: 2739

Received: 21/03/2021

Respondent: Mrs Helen Owen

Proposed land allocation in Bingley and Cottingley are mainly Green Belt areas. This is just plain wrong.

Object

Representation ID: 2763

Received: 21/03/2021

Respondent: Mr Ian Beardmore

We support CPRE's suggested alternative wording for Policy SP4, please see below:

Policy SP4: Location of Development
A. The Local Plan will adopt a car-free accessibility approach to ensure that new development contributes to the strategic target of significantly reducing car use over the plan period. It will do this by locating new development such that it:
1. Makes walking, cycling and public transport the most attractive and useful travel modes for day-to-day journeys, to achieve 15-minute neighbourhoods;
2. Ensures that the pattern of development improves accessibility and independence for all sectors of society;
3. Takes every possible opportunity to create and enhance green corridors for nature, climate response and active travel;
4. Minimises the dependence of development on any additional road capacity that would otherwise induce additional traffic;
5. Maximises the use of rail and water for uses generating large freight movements.

B. Having identified how to maximize car-free accessibility, the Local Plan will then maximize the efficient use of land, by allocating sites that:
1. are compatible with the settlement hierarchy;
2. give first priority to the re-use of brownfield and under-utilised land within settlements, and second priority to greenfield sites within settlements, while ensuring that development of those does not harm environmental assets or public space;
3. are suitable for development at a minimum of 50 dwellings per hectare net.

C. Where there are insufficient sites within settlements, land will be identified for release from the Green Belt adjacent to settlement boundaries, as set out in policy SP5, so long as those sites fulfil the three criteria in SP4 A and B above.

Support

Representation ID: 2869

Received: 21/03/2021

Respondent: Alison Tribe

I agree with the priorities set out for site allocation but I think it is dishonest to pretend that the use of Greenfield sites is 'sustainable'. In 1987 the Bruntland Commission defined 'sustainability' as “development that meets the needs of the present without compromising the ability of future generations to meet their own needs.” It is preferable to build on Greenfield sites rather than on Green Belt, but you should be honest about the fact that the sites will not be ‘greenfield’ for future generations.
In order to minimise the building on Greenfield and Green Belt, the Council should insist on higher density housing eg fewer detached properties and double garages. If the Council is to live up to its' good intentions, it must stand firm in its' dealings with developers.

Support

Representation ID: 3243

Received: 22/03/2021

Respondent: Wilsden Parish Council

We strongly support the first priority of SP4 of the development of previously developed land. The current wording however excludes PDL outside existing developed areas. While we accept that PDL inside existing developed areas has a higher priority PDL in the Green Belt should not be excluded.

Object

Representation ID: 3483

Received: 22/03/2021

Respondent: NEAT

There should be no question of using "green belt" or "greenfield" sites for more building, especially within the city of Bradford.
Open space has vale for health, both physical and mental.
Open space encourages biodiversity, often in modest, unseen ways, such as encouraging insects and other invertebrates, which in turn support other wildlife.
Open space reduces flood risk by allowing areas for rainwater to soak into the earth.
This question and answer needs to be seen in the context of the inequality encased in SP3/Question 4, whereby the population of Bradford city is targeted for most of the building development.
The only priority for development sites should be the vast number of disused/under-used/derelict buildings in the city. Travellers arriving at Forster Square station used to get off the train to be welcomed by a burnt-out warehouse. That particular eyesore has gone but many more remain (Listerhills Road, Wapping School).

Object

Representation ID: 3672

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.

Object

Representation ID: 3773

Received: 23/03/2021

Respondent: Mr Andrew Lund

The policy as drafted infers that the prioritised approach will be applied separately to each named settlement. The result would be that in a settlement where neither PDL or greenfield are available there would be an automatic GB release. However, other settlements have a surplus of lower priority sustainable sites and a district wide approach would lead to less GB release overall. Such would be more compliant with Policy SP1.B.5.d

Support

Representation ID: 3908

Received: 23/03/2021

Respondent: Mrs Susan Burn

Seems sensible.

Support

Representation ID: 4153

Received: 23/03/2021

Respondent: Residents of Moor Lane, Turner Lane, Moor View and Moor Croft, Addingham

Agent: Airedon Planning and Design

Strategic Policy SP4 puts forward a very logical approach to allocating development and this is supported. However, in relation to Addingham it has not been followed through as the sites on the western side are Green Belt sites that are not in a sustainable location as they are distant from services within the centre of the village and whilst some are within 400m of the bus, this does not offer a service that is likely to encourage journeys to work.

Object

Representation ID: 4276

Received: 23/03/2021

Respondent: Mr John Fox

The Campaign to Protect Rural England recently stated that there is space to build 1.1M affordable homes on reclaimed ‘brownfield’ sites across the country. Bradford is no different and could meets its set minimum annual target through developing such sites. It will also have the opportunity to access a new £100m fund launched in January 2021 by the government, giving councils across England the chance to pitch for money to support developments on public land and regeneration of council estates. The councils limited planning resources should be focused here and not even be looking at greenfield (even if of supposed low environmental value) or greenbelt to meet its needs. I would also suggest that the pandemic has changed the housing supply equation for Bradford. Our struggling High Streets and business zones should be repurposed as residential neighbourhoods. Finally, houses to facilitate downsizing is crucial to tackling the skewed housing market.

Support

Representation ID: 4443

Received: 23/03/2021

Respondent: Ms Julie Townsend

I strongly support the move towards greater consideration of sustainable transport access in relation to both the siting and design of housing/other developments, but suggest that the wording in this policy could be strengthened further. The vast majority of new housing (nationally) is poorly sited in relation to public transport and active travel infrastructure, and suffers from car-orientated design and assumptions (see Transport for New Homes report) - and there is significant evidence of this happening in Bradford District. This locks new residents into car dependency (or limited mobility) and means that nearby/existing communities must suffer the ill effects of increasing congestion, noise, air pollution and road danger. Given the pressing need to reduce private car use, BMDC should strengthen this proposed policy further by ensuring that all housing and other developments are sited and designed so that all residents/users can access them conveniently via non-car based means.

Support

Representation ID: 4657

Received: 23/03/2021

Respondent: Menston Parish Council

The third (and last) priority is the release of Green Belt land as set out under Policy SP5.

Object

Representation ID: 5029

Received: 24/03/2021

Respondent: Mr Nick Jones

The Government’s policy on protection for the Green Belt (Chapter 13 of the National Planning Policy Framework - NPPF), clearly states the importance of Green Belt land and emphasises that when protecting the Green Belt, local authorities should maximise the use of suitable brownfield sites before considering changes to Green Belt boundaries. The NPPF states that there should be “exceptional circumstances” before Green Belt boundaries can be changed and states that inappropriate development is harmful to the Green Belt and should be approved only in “very special circumstances”. 
1. BMDC is not maximising the use of brownfield sites & provides insufficient evidence that all options have been explored.
2. BMDC has not provided within their consultation documents sufficient justification which provides “exceptional circumstances” for why these green belt sites should be considered or detailed what the “very special circumstances” are for releasing these sites from Green Belt protection.

Support

Representation ID: 5116

Received: 24/03/2021

Respondent: Mr Peter Jenkins

If the execution of the plan is really in accordance with the adoption of an “accessibility orientated approach to ... development” then few would argue.

Support

Representation ID: 5439

Received: 24/03/2021

Respondent: Mrs Jane Callaghan

Supported on the whole, but a new second priority should be inserted between Priority 1 and (current) 2 for PDL in the green belt to be used before green field in the settlement boundary

Object

Representation ID: 5497

Received: 24/03/2021

Respondent: CPRE West Yorkshire

We strongly support paras 3.4.7 and 3.4.8, which point to 15 minute neighbourhoods and an aspiration not to eliminate the car, but to reduce its use.

It is essential that the Local Plan does everything it possibly can to facilitate reductions in car mileage. It should do so principally through the location of new development, the development expectations in each of those locations, and the transport investments proposed.

New development must be located and planned in such a way as to facilitate net reduction in car use in the host settlement. This is likely to depend on significantly greater concentration of new development within areas that are capable of being 15 minute neighbourhoods, and significantly more mixed-use rather than single-use site allocations.

SP4(A) is essentially a reiteration of government policy and the settlement hierarchy. We are concerned that the phrase ‘not have high environmental value’ is too subjective. This is because there may be sites which are currently not of high environmental value, but which have strong potential to become so, for example through being beneficiaries of biodiversity net gain measures or significant urban tree planting.

Similarly, we would expect more specific requirements for examining the sustainability of greenfield sites within settlements.

We are concerned that the phrase ‘subject to the above’ implies that the application of the sequence identified in part A of the policy takes precedence over the outcomes identified in part B of the policy

We are also concerned that the intended outcomes in SP4B - whilst referring to an accessibility orientated approach - do not clearly consider the accessibility needs of different people for example, by age, gender or ability as required in NPPF para 108.

We have provided below a suggested alternative wording for policy SP4 to address the concerns we have raised here.

Policy SP4: Location of Development
A. The Local Plan will adopt a car-free accessibility approach to ensure that new development contributes to the strategic target of reducing car use over the plan period. It will do this by locating new development such that it:
1. Makes walking, cycling and public transport the most attractive and useful travel modes for day-to-day journeys, to achieve 15-minute neighbourhoods;
2. Ensures that the pattern of development improves accessibility and independence for all sectors of society;
3. Takes every possible opportunity to create and enhance green corridors for nature, climate response and active travel;
4. Minimises the dependence of development on any additional road capacity that could otherwise induce additional traffic;
5. Maximises the use of rail and water for uses generating large freight movements.
B. Having identified how to maximize car-free accessibility, the Local Plan will then maximize the efficient use of land, by allocating sites that:
1. are compatible with the settlement hierarchy;
2. give first priority to the re-use of brownfield and under-utilised land within settlements, and second priority to greenfield sites within settlements, while ensuring that development of those does not harm environmental assets or public space;
3. are suitable for development at a minimum of 50 dwellings per hectare net.
C. Where there are insufficient sites within settlements, land will be identified for release from the Green Belt adjacent to settlement boundaries, as set out in policy SP5, so long as those sites fulfil the three criteria in SP4 A and B above.

Object

Representation ID: 5909

Received: 24/03/2021

Respondent: Baildon & Shipley Friends of the Earth

Baildon & Shipley – SP4
1. In order to address the climate emergency successfully, there is going to have to be a significant reduction in private car use.
2. This requires radical thinking and a different mindset.
3. All neighbourhoods should be planned to encourage walking, cycling and use of public transport as the preferred mode of transport, in preference to the private motor car.
4. Vauban (Freiburg, Germany) shows what can be achieved when pedestrians and cyclists are placed at the heart of neighbourhood planning.
5. Most everyday local facilities should be located within 15 minutes of any given home, by any means other than private car.

Support

Representation ID: 5946

Received: 24/03/2021

Respondent: SHMS

Additional comment, prioritise brownfield pdl first in the central areas of Bradford and Keighley to support retail, higher education and minimise commuting

Object

Representation ID: 6089

Received: 05/03/2021

Respondent: Mary Tretton

Development on green sites is irreversible- urban sprawl, increases traffic into urban areas

Comment

Representation ID: 6760

Received: 18/03/2021

Respondent: Mrs Jean Cawkwell

Part 3 of this policy should refer to Green Belt release around the Regional Centre, Principal Towns and Local Growth Centres, as this is where the majority of housing need will be accommodated.

Comment

Representation ID: 9797

Received: 12/03/2021

Respondent: Bradford District Ward Councillor (Labour)

SP 4 page 24 seems unarguable. I am taken with the aspect of enhancing water transport. Why not some more commercial development?

Object

Representation ID: 10942

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

Part 3 of this policy should refer to Green Belt release around the Regional Centre, Principal Towns and Local Growth Centres in particular as this is clearly where the majority of housing need is going to be derived from.

Comment

Representation ID: 11372

Received: 17/03/2021

Respondent: Mr Robert Felstead

This section emphasises the need to redevelop previously developed land (PDL), which is also referred to as Brownfield (BF) in the Local Plan. Using both terms make matters even more challenging to an uninitiated reader.

I have already stated my thoughts about Brownfield delivery in Question 2.

A clear plan of action needs to be taken to remedy existing challenges, otherwise we’re not delivering the Local Plan’s promise as emphasised above and in the following policy statement. “3.2.11 There is a clear thread running through the Local Plan of supporting the renewal and regeneration of our urban areas and brownfield sites.”

Support

Representation ID: 12165

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 SP4 which seeks to allocate sites by giving first priority to previously developed land and buildings, within the City of Bradford, the Principal Towns of Ilkley, Keighley and Bingley, the Local Growth Centres and the Local Service Centres.

However, these aspirations should be supported by a robust transport evidence base