Consultation Question 5

Object

Representation ID: 13319

Received: 24/03/2021

Respondent: Mitre Residential LPP

Agent: DPP Planning

Whilst it is acknowledged that Policy SP4 primarily relates to transport and the related infrastructure, it is argued that ‘Locations for Development’ should not solely dictated by this. Just as important is the provision of other infrastructure such as drainage, sewage, and energy , and therefore priority to sites with this infrastructure in place should be given over those without. As drafted, we object to this policy.

Comment

Representation ID: 13810

Received: 20/03/2021

Respondent: John Finnigan

The BDLP continues to propose an unequal and disproportionate release of Green Belt land in the Tong ward comparative to the releases proposed elsewhere in the District.
This arises from the Council’s continued insistence, contrary to any objectively determined evidence of its sustainability, that an urban extension is required at Holme Wood on a scale materially larger than other urban extensions set out in the BDLP.

Support

Representation ID: 16263

Received: 22/03/2021

Respondent: Robbie Feather

Agent: ID Planning

SP4 sets out the priority that will be given to allocating sites. First priority will be given to developable previously developed land within settlements. Second priority will be given to sustainable greenfield opportunities within settlements and third priority will be given to Green Belt land.Bradford

Required Change:
In accordance with NPPF and to support sustainable development, for clarity the policy should prioritise sites that are in sustainable locations. The wording of the policy should be amended as follows;-
3. Third priority to the limited release of Green Belt land in sustainable locations, as set out under Part B of this policy (SP4)

Object

Representation ID: 16330

Received: 24/03/2021

Respondent: Newett Homes

Agent: Quod North

Policy SP4 closely reflects Policy SP3 in terms of purpose and future application (both set a hierarchy / sequential approach to allocating / delivering development).

This Policy should be incorporated into Policy SP3 and then supported by a separate policy covering spatial distribution of development requirements (e.g. housing and employment) and delivery trajectory for the plan period.

Object

Representation ID: 16717

Received: 24/03/2021

Respondent: Shipley Town Council

See comments under SP1 for sequential approach and suitability of sites.

However, as TRICS data (http://www.trics.org/system.html) demonstrate every new dwelling generates 5 -7 additional vehicle journeys a day.

To combat the climate emergency we are going to need a net reduction in car use. Therefore, we recommend the below to be added to SP4.

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:
● Makes walking, cycling and public transport the most attractive and useful travel modes for day-to-day journeys, to achieve 15-minute neighbourhoods with the creation of gold-standard segregated infrastructure and low traffic neighbourhood principles;
● Ensures that the pattern of development improves accessibility and independence for all sectors of society:
● Minimises the dependence of development on any additional road capacity that could otherwise induce additional traffic;
● Maximises the use of rail and water for uses generating large freight movements.

Support

Representation ID: 16955

Received: 23/03/2021

Respondent: Avant Homes

Agent: ID Planning

Support subject to amendment. Required Change:
- In accordance with NPPF and to support sustainable development, for clarity the policy should prioritise sites that are in sustainable locations in accordance with NPPF. The wording of the policy should be amended as follows;-
3. Third priority to the limited release of Green Belt land in sustainable locations, as set out under Part B of this policy (SP4)

Object

Representation ID: 17163

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: 17170

Received: 24/03/2021

Respondent: Jones Homes (Yorkshire) Limited

Agent: Savills (UK) Ltd

We broadly agree with the approach centred on brownfield first but which also includes greenfield and green belt land
with strong transport accessibility once deliverable and viable brownfield sites have been identified.

The Shipley Golf Course site at Cottingley is considered to be sustainable in terms of access as set out within the Accessibility Appraisal included at Appendix B, and is therefore an appropriate location for development, as per the aims of policy SP4.

Recommendation 5: In order to deliver the approach set out within Policy SP4 in a plan-led way, the overall housing requirements for the Local Authority should be reviewed urgently to enable the LPA to identify and deliver a robust supply of housing land in accordance with the accessibility orientated approach identified. This will prevent an approach to future application determinations based predominantly on the presumption in favour of sustainable development.

Object

Representation ID: 17241

Received: 24/03/2021

Respondent: Mark Wogden

We strongly support CPRE's suggested alternative wording for Policy SP4 as a clear structure for assessing proposed development against the stated aims of the plan.

Support

Representation ID: 17420

Received: 23/03/2021

Respondent: Mr & Mrs . Pyrah and Saunders

Number of people: 4

Agent: ID Planning

Support subject to amendment. Required Change:
In accordance with NPPF and to support sustainable development, for clarity the policy should prioritise sites that are in sustainable locations. The wording of the policy should be amended as follows;-
3. Third priority to the limited release of Green Belt land in sustainable locations, as set out under Part B of this policy (SP4)

Support

Representation ID: 17497

Received: 23/03/2021

Respondent: Barratt Homes and David Wilson Homes

Agent: ID Planning

Support subject to amendment
Policy SP4 sets out the priority that will be given to allocating sites. First priority will be given to developable previously developed land within settlements. Second priority will be given to sustainable greenfield opportunities within settlements and third priority will be given to Green Belt land.
The second priority would support sustainable greenfield opportunities within settlements, but does not offer support for greenfield opportunities adjoining Bradford settlements that are not in the Green Belt. The second priority should therefore be amended to support greenfield opportunities within and adjoining settlements.
Required Change:
In accordance with NPPF and to support sustainable development, for clarity the policy should prioritise sites that are in sustainable locations. The wording of the policy should be amended as follows;-
2. Second priority to sustainable Greenfield opportunities within and adjoining the settlements.
3. Third priority to the limited release of Green Belt land in sustainable locations, as set out under Part B of this policy (SP4)

Support

Representation ID: 17680

Received: 23/03/2021

Respondent: Bannister Investments Limited

Agent: ID Planning

Support subject to amendments
The second priority would support sustainable greenfield opportunities within settlements, but does not offer support for greenfield opportunities adjoining settlements that are not in the Green Belt. The second priority should therefore be amended to support greenfield opportunities within and adjoining settlements.
Required Change:
In accordance with NPPF and to support sustainable development, for clarity the policy should prioritise sites that are in sustainable locations. The wording of the policy should be amended as follows;-
2. Second priority to sustainable Greenfield opportunities within and adjoining the settlements.
3. Third priority to the limited release of Green Belt land in sustainable locations, as set out under Part B of this policy (SP4)

Object

Representation ID: 18018

Received: 24/03/2021

Respondent: Harworth Group & Nufarm UK Ltd

Agent: Johnson Mowat

The requirement of NPPF para 137 to fully examine all reasonable options to meeting identified need before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries is recognised.

However, the draft Policy should also reflect that certain development types require sites of a particular scale, type or location that is extremely unlikely to be able to be accommodated in a non-Green Belt location given the extent of the Green Belt across the district and the location of key infrastructure, in particular motorway junctions.

Plan paragraph 3.5.8 sates ‘the main demand for employment land is unlikely to have moved from the Bradford Urban Area (strongly within South East Bradford and M606 corridor) and surrounds’.

Policy SP4 should be amended to read:

‘Third priority to the release of Green Belt land where the locational requirements of particular development necessitate this, to meet identified development need in full and as set out under Policy SP5’.

Object

Representation ID: 18381

Received: 24/03/2021

Respondent: Johnson Mowat

In line with the NPPF it is correct that release of Green Belt is identified as a third priority after the allocation of land within settlements.

However, it is queried what ‘sustainable greenfield opportunities’ actually means and consideration should be given to revising this wording to remove ambiguity.

For these reasons, part A/2 of draft Policy SP4 should be amended to read: ‘Second priority to greenfield land located within and around the settlements where sustainable development can be achieved’.

To reflect NPPF paragraph 137 part A/3 of draft Policy SP4 should be amended to read:

‘Third priority to the release of Green Belt land in order to meet the remaining identified development need in full and as set out under Policy SP5’.

Support

Representation ID: 18919

Received: 23/03/2021

Respondent: Mrs WE Nichol

Agent: Carter Jonas

Q5: Policy SP4: Location of Development

We support Policy SP4 which sets out the priority that will be given to the allocation of sites. First priority will
be given to developable previously developed land, second priority will be given to sustainable greenfield
opportunities within settlements and third priority will be given to Green Belt land.

Object

Representation ID: 18920

Received: 23/03/2021

Respondent: Mrs WE Nichol

Agent: Carter Jonas

It is considered that for consistency the reference to Green Belt land in Policy SP5 (Location of Development)
should prioritise sites that are in sustainable locations to be in accordance with the NPPF:

Support

Representation ID: 18929

Received: 23/03/2021

Respondent: Mrs J Kamyar

Agent: Carter Jonas

Q5: Policy SP4: Location of Development

We support Policy SP4 which sets out the priority that will be given to the allocation of sites. First priority will
be given to developable previously developed land, second priority will be given to sustainable greenfield
opportunities within settlements and third priority will be given to Green Belt land.

Object

Representation ID: 18930

Received: 23/03/2021

Respondent: Mrs J Kamyar

Agent: Carter Jonas

It is considered that for consistency the reference to Green Belt land in Policy SP5 (Location of Development)
should prioritise sites that are in sustainable locations to be in accordance with the NPPF:

Support

Representation ID: 18939

Received: 23/03/2021

Respondent: Mrs I Wood

Agent: Carter Jonas

Q5: Policy SP4: Location of Development

We support Policy SP4 which sets out the priority that will be given to the allocation of sites. First priority will
be given to developable previously developed land, second priority will be given to sustainable greenfield
opportunities within settlements and third priority will be given to Green Belt land.

Object

Representation ID: 18940

Received: 23/03/2021

Respondent: Mrs I Wood

Agent: Carter Jonas

It is considered that for consistency the reference to Green Belt land in Policy SP5 (Location of Development)
should prioritise sites that are in sustainable locations to be in accordance with the NPPF:

Support

Representation ID: 18949

Received: 23/03/2021

Respondent: Mr GRN Jones

Agent: Carter Jonas

Q5: Policy SP4: Location of Development

We support Policy SP4 which sets out the priority that will be given to the allocation of sites. First priority will
be given to developable previously developed land, second priority will be given to sustainable greenfield
opportunities within settlements and third priority will be given to Green Belt land.

Object

Representation ID: 18950

Received: 23/03/2021

Respondent: Mr GRN Jones

Agent: Carter Jonas

It is considered that for consistency the reference to Green Belt land in Policy SP5 (Location of Development)
should prioritise sites that are in sustainable locations to be in accordance with the NPPF:

Object

Representation ID: 19834

Received: 01/04/2021

Respondent: Natural England

As per our comments above, Natural England broadly welcomes the approach taken within the Draft Local Plan to ensuring that a sequential approach is taken to site selection and allocation, which is detailed within Policy SP4.

We would ask that the Nature Recovery Network is also recognised as a consideration, through the inclusion of an appropriate item under section B of this policy, as per footnote 57 to paragraph 174a) and Annex 2 of the NPPF.

Object

Representation ID: 21607

Received: 23/03/2021

Respondent: Bradford District Ward Councillor (Conservative)

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

Strongly reject the Government’s proposal to adopt a 35% uplift in numbers!

Object

Representation ID: 21789

Received: 23/03/2021

Respondent: Duncan Watson

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: 21881

Received: 23/03/2021

Respondent: Catherine Starling

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: 21910

Received: 23/03/2021

Respondent: Dr Samantha Cook

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: 21939

Received: 23/03/2021

Respondent: Birgit Almond

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: 21968

Received: 23/03/2021

Respondent: Mrs Corrie Hardaker

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: 21997

Received: 23/03/2021

Respondent: Carly Mitchell

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.