Consultation Question 5

Object

Representation ID: 27202

Received: 24/03/2021

Respondent: Julie Sunderland

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: 27231

Received: 24/03/2021

Respondent: Gary Scott

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: 27263

Received: 24/03/2021

Respondent: Ms Jane Schofield

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: 27292

Received: 24/03/2021

Respondent: Mr Alan Lovell

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: 27321

Received: 24/03/2021

Respondent: Marjorie Rogan

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: 27350

Received: 24/03/2021

Respondent: Paul Cryer

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: 27379

Received: 24/03/2021

Respondent: Wendy Barton

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: 27408

Received: 24/03/2021

Respondent: Mr Richard Bardsley

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: 27437

Received: 24/03/2021

Respondent: Paul Warren

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.

Comment

Representation ID: 27543

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

Changes to the Core Strategy Policy introduce a clear rationale for prioritising Green Belt release. These are generally welcomed but assume that building on greenfield land within a settlement is more sustainable (desirable) than releasing Green Belt land, which is an urban containment policy, not an indication of environmental/ecological value.

It is noted elsewhere that the Local Plan justification appears to conflate Green Belt, which is an urban containment policy tool, with environmental, ecological and cultural heritage values. This is not considered a valid approach.

Object

Representation ID: 27559

Received: 24/03/2021

Respondent: Danny Thompson

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: 27684

Received: 24/03/2021

Respondent: Peter Cartwright

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: 27718

Received: 24/03/2021

Respondent: Mrs Ann Todd

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: 27791

Received: 24/03/2021

Respondent: Richard Briggs

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: 27822

Received: 24/03/2021

Respondent: Claire Shouler

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: 27886

Received: 23/03/2021

Respondent: Samantha Armitage

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: 28185

Received: 24/03/2021

Respondent: Sarah Lucas

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: 28275

Received: 24/03/2021

Respondent: Stephen Mould

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: 28532

Received: 25/02/2021

Respondent: Dr Ros Brown

We strongly support paras 3.4.7 and 3.4.8, which point to 15 minute neighbourhoods - we would encourage them to be adopted as a policy in the plan for all but the smallest and the most remote settlements.

If there is any prospect of achieving the W Yorkshire target of a 21% reduction in car mileage by 2038 the Local Plan needs to facilitate this by its policies on location of development, by focusing on development in 15 minute neighbourhoods and by promoting mixed use rather than single use developments and by ensuring non car modes are safe, attractive reliable choices.

Extension of PD rights could undermine mixed use areas – Article 4 Directions should be used to prevent this.

We have a number of concerns regarding the wording of Policy SP4 and suggest an alternative more appropriate policy.

Object

Representation ID: 29054

Received: 29/03/2021

Respondent: Historic England

Subject to recommended change, we support priority given to the re-use of previously developed land/ building.
Many of these buildings make a significant contribution to the character and distinctiveness of settlements and to the District as a whole. We fully support priority being given to those sites which would reuse previous buildings. Given the embodied energy within existing buildings (in terms of the materials used for their construction, the energy that was involved in moving those materials to the site etc) coupled with the energy which would be expended in the demolition of those buildings and the removal of the waste materials, we welcome the intention to encourage the reuse of existing buildings. However, as written it could potentially be interpreted as implying that the reuse of buildings of “high environmental value” is not something which the plan would encourage. As a result, this would mean the Plan would not be encouraging the reuse or adaptation of the District’s Listed Buildings (because they are of “high environmental value”). Such an approach would not accord with the principles set out in the NPPF.
amend Criterion A.1to read:
“1. First priority to the efficient and effective re-use of deliverable and developable previously developed land and buildings, provided that it is not of high environmental value and that any heritage assets are appropriately conserved, and more efficient and effective use of existing developed areas within the City of Bradford,
the Principal Towns of Ilkley, Keighley and Bingley, the Local Growth Centres and the Local Service Centres.”

Object

Representation ID: 29158

Received: 25/03/2021

Respondent: Ilkley Town Council

We support CPRE's suggested alternative wording for Policy SP4

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.

Comment

Representation ID: 29175

Received: 24/03/2021

Respondent: Environment Agency

In principle we support the effective and efficient re-use of previously developed land. As above, we feel that in some instances previously developed land may hold (or have the potential to hold) significant environmental / ecological value. Based on this, we support the inclusion of the qualifying statement “that is not of high environmental value” within bullet point A, 1 of Policy SP4. However, the policy wording does not explain how the environmental value of prospective, previously developed sites, will be determined. For example, previously developed land immediately adjacent to river corridors, even if currently in a poor state, has a high environmental value.

Equally, rather than solely focussing on current environmental value, we feel the policy needs to consider the future / potential environmental value when determining which previously developed site are most suitable for future re-development. For example, the potential to unlock previously lost environmental value through de-culverting rivers and streams should be given weight when determining site selection.

Object

Representation ID: 29208

Received: 23/03/2021

Respondent: Rachel Wood

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: 29561

Received: 23/03/2021

Respondent: Harvey Bosomworth

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: 29601

Received: 17/03/2021

Respondent: Mr Mark Summerson

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.

Comment

Representation ID: 29814

Received: 23/03/2021

Respondent: Addingham Parish Council

The Parish Council supports the Plan’s strategic policy SP4, which prioritises the use of previously-developed sites and sustainable green field opportunities in local service centres ahead of Green Belt sites. Our Neighbourhood Plan policy on housing development supports the use of small infill sites, particularly those which have been previously developed but only if the land is not of high environmental value. Given the general comments made above in relation to the high landscape quality of the setting, lying within two Natural Character Areas, the Green Belt sites proposed in the Local Plan are unsuitable for housing development, because the high environmental value of the land excludes them from consideration. The Local Plan’s draft policies are also not consistent with the Neighbourhood Plan’s policies as regards the proposed allocation of relatively large sites for housing.
The Parish Council has taken advice from planning consultants appointed by the local council sector, and understands that policies in an approved plan, including a Neighbourhood Plan, “trump those contained in [a] draft one (including an emerging Local Plan)”. The Neighbourhood Plan’s policies are therefore to be given full weight in the proposal of sites to be allocated in the new draft Local Plan. Since the Neighbourhood Plan’s policies clearly indicate that these particular preferred options are not appropriate, they should immediately fail.

Object

Representation ID: 30000

Received: 23/03/2021

Respondent: Daniel Spencer

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: 30081

Received: 23/03/2021

Respondent: Mrs Savia Lorain Hughes

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: 30164

Received: 23/03/2021

Respondent: Catherine Terry

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.

Support

Representation ID: 30285

Received: 23/03/2021

Respondent: Barry Hopkinson

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.