Consultation Question 6

Object

Representation ID: 18232

Received: 22/03/2021

Respondent: Bradford District Ward Councillor (Conservative)

Green Belt
In general, the green belt should not be included for development. Its purpose is to prevent urban sprawl by keeping land open. Green Belt should only be developed under “exceptional circumstances” and this plan does not demonstrate exceptional circumstances. Brownfield sites should be exhausted first and empty homes brought back into use.

Object

Representation ID: 18382

Received: 24/03/2021

Respondent: Johnson Mowat

Johnson Mowat agrees that there is an ‘acute and intense need for housing (market and affordable)’ and a ‘shortage of alternative sites’ (i.e. insufficient capacity within non-Green Belt sites to meet the identified housing need).

Johnson Mowat supports the Council’s assessment that exception circumstances exist (as required by national policy) to allow the release of Green Belt land and the allocation of this for development.

In accordance with our comments made in relation to meeting identified need in full (see draft Policy SP8 below)) Johnson Mowat objects to the list of sites set out within parts B of draft Policy SP5 as the development achievable from these is either insufficient in total or inappropriate in other regards (as applicable) such that a revision to the lists is required. This is likely to require the addition of further sites to the lists and the removal of certain sites already listed.

Object

Representation ID: 18562

Received: 23/03/2021

Respondent: Oliver Cattley

There isn’t much greenbelt to enjoy locally except Tong Valley.

Walking there is great for stress levels, we get clean air and exercise. The views are lovely.

Having previously worked in Bradford, I am aware that a lot of it is.. well.... derelict.

These buildings already have the infrastructure in place, why is the priority for new housing to build in to the greenbelt when there are so many of these sites that could easily be renovated without destroying a beautiful area?

Many of the buildings in Bradford are used by squatters and injecting drug users. Regeneration would not only be cheaper than new builds but would address some of the issue here also.

Support

Representation ID: 18921

Received: 23/03/2021

Respondent: Mrs WE Nichol

Agent: Carter Jonas

Q6: Policy SP5: Green Belt

We support Policy SP5 which sets out the sites identified for Green Belt release.

In particular we support the identification of site NW10/H - Allerton Road, Prune Park Lane. The 5-year housing land supply published in January 2021 identifies that the Council have a 2.03 year supply of housing land. This is reconfirmed within the recent appeal decision for land to the west of Burley-in-Wharfedale at Sun Lane and Ilkley Road Ref: APP/W4705/V/18/3208020 in which the Inspector considered the Council’s land supply to be very low, less than 2.06 years. There is therefore a clear and exceptional need for Green Belt release for housing to meet the identified housing need.

Support

Representation ID: 18931

Received: 23/03/2021

Respondent: Mrs J Kamyar

Agent: Carter Jonas

Q6: Policy SP5: Green Belt

We support Policy SP5 which sets out the sites identified for Green Belt release.

In particular we support the identification of site NW10/H - Allerton Road, Prune Park Lane. The 5-year housing land supply published in January 2021 identifies that the Council have a 2.03 year supply of housing land. This is reconfirmed within the recent appeal decision for land to the west of Burley-in-Wharfedale at Sun Lane and Ilkley Road Ref: APP/W4705/V/18/3208020 in which the Inspector considered the Council’s land supply to be very low, less than 2.06 years. There is therefore a clear and exceptional need for Green Belt release for housing to meet the identified housing need.

Support

Representation ID: 18941

Received: 23/03/2021

Respondent: Mrs I Wood

Agent: Carter Jonas

Q6: Policy SP5: Green Belt

We support Policy SP5 which sets out the sites identified for Green Belt release.

In particular we support the identification of site NW10/H - Allerton Road, Prune Park Lane. The 5-year housing land supply published in January 2021 identifies that the Council have a 2.03 year supply of housing land. This is reconfirmed within the recent appeal decision for land to the west of Burley-in-Wharfedale at Sun Lane and Ilkley Road Ref: APP/W4705/V/18/3208020 in which the Inspector considered the Council’s land supply to be very low, less than 2.06 years. There is therefore a clear and exceptional need for Green Belt release for housing to meet the identified housing need.

Support

Representation ID: 18951

Received: 23/03/2021

Respondent: Mr GRN Jones

Agent: Carter Jonas

Q6: Policy SP5: Green Belt

We support Policy SP5 which sets out the sites identified for Green Belt release.

In particular we support the identification of site NW10/H - Allerton Road, Prune Park Lane. The 5-year housing land supply published in January 2021 identifies that the Council have a 2.03 year supply of housing land. This is reconfirmed within the recent appeal decision for land to the west of Burley-in-Wharfedale at Sun Lane and Ilkley Road Ref: APP/W4705/V/18/3208020 in which the Inspector considered the Council’s land supply to be very low, less than 2.06 years. There is therefore a clear and exceptional need for Green Belt release for housing to meet the identified housing need.

Object

Representation ID: 19734

Received: 23/03/2021

Respondent: Bradford District Ward Councillor (Conservative)

The whole report is littered with reference to the SPS Policy saying it is "necessary to make changes to adopted green belt". The frequency of its use points to the reality that this plan is about 'Saving Bradford Brownfield and Concreting Rural Greenbelt'.

Object

Representation ID: 19761

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

We do not accept that the proposed release of tracts of Green Belt in the draft local plan is consistent with the NPPF. Nor do we accept that development on Green Belt and Greenfield land will lead to the necessary biodiversity net gain referenced in Policy EN2: Biodiversity.

Bradford Council has NOT justified the exceptional circumstances for building on the Green Belt on the edge of Shipley. There is under-utilised land nearer Shipley Town Centre that could and should be used for development, and higher housing densities should also be incorporated into the brownfield site allocations in line, for example, with those being achieved elsewhere in places like London.

Object

Representation ID: 19807

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

We do not accept that the proposed release of tracts of Green Belt in the draft local plan is consistent with the NPPF. Nor do we accept that development on Green Belt and Greenfield land will lead to the necessary biodiversity net gain referenced in Policy EN2: Biodiversity.

Bradford Council has NOT justified the exceptional circumstances for building on the Green Belt on the edge of Shipley. There is under-utilised land nearer Shipley Town Centre that could and should be used for development, and higher housing densities should also be incorporated into the brownfield site allocations in line, for example, with those being achieved elsewhere in places like London.

Object

Representation ID: 19825

Received: 24/03/2021

Respondent: Airedale NHS Foundation Trust

Agent: WSP UK Ltd

It is requested that Strategic Policies SP5 (Green Belt), SP15 (Creating Healthy Places) and the relevant supporting text and evidence base documents (eg The Green Belt Review) acknowledge the ‘exceptional circumstances’ to release some land from the Green Belt to facilitate the hospital’s operations. This will be necessary to comply with paragraph 136 of the National Planning Policy Framework.

Object

Representation ID: 19835

Received: 01/04/2021

Respondent: Natural England

We advise that the wording of item E of Policy SP5 could be strengthened by including opportunities for enhancement as well as development requirements for particular sites, as follows:

"All sites identified as being released from the Green Belt will be required to offset the impact of removing land from the Green Belt by
a) identifying opportunities for on-site environmental enhancement and the delivery of environmental net gain through new development
Proposals which increase the beneficial use of the Green Belt, by enhancing green infrastructure, biodiversity, visual amenity and landscapes or improving derelict land and opportunities for access, outdoor sport and recreation, will be supported where this does not conflict with Green Belt or other policy objectives."

Object

Representation ID: 20003

Received: 24/03/2021

Respondent: Avant Homes

Agent: Tetra Tech (Leeds)

we agree with the Council’s contention under paragraph B of Policy SP5, with regard to exceptional circumstances.

However we do not consider the policy goes far enough and does not plan positively for a sufficient amount, and variety, of housing land to come forward where it is needed, to address the diverse market needs that exist across the district.

It is important that the development strategy is not overly reliant on brownfield sites. Policy SP5 as drafted leaves no headroom for shortfalls in delivery that may develop, particularly in some of the more central areas. Further allocations are required, and Policy SP5 should be amended to redress the concerns on undersupply and the balance of supply across the district in line with the sustainable settlement hierarchy. The Council need to be able to demonstrate that Green Belt boundaries will not need to be altered at the end of the plan period.

We consider that there is capacity for further housing to be accommodated on sustainable sites on the edge of Menston which are well served by public transport and do not compromise the purposes of Green Belt.

Object

Representation ID: 21610

Received: 23/03/2021

Respondent: Bradford District Ward Councillor (Conservative)

Although allocation of Site ME1/H takes no regard of the topography whatsoever and it lies within the green belt and consists of a north-facing steep hillside. It is within 2.5km of the South Pennine Moors, currently being used for sheep farming, overlooking the village. It’s development would overshadow the existing settlements lower down the hillside particularly in Hargrave Crescent and Derry Lane as well as impacting on the SSSI and SPA. It conflicts with Policy SP9 Climate Change, Environmental Sustainability and Resource Use.

Greater effort must be made to develop Brownfield Sites first, with appropriate incentives and support to prevent developers cherry picking Green Belt.

Object

Representation ID: 21764

Received: 23/03/2021

Respondent: Mr J.H. Cove

Plan unsound in relation to Green Belt release in Wharfedale (1,045 dwellings).

Plan not justified and does not meet local infrastructure requirements. Wharfedale does not require this number of homes to meet demand for local employment.

Would make more sense to protect Green belt, revitalising empty homes and make better use of brownfield sites.

Concern over sites AD3/H, AD4/H, IL1/H, IL3/H & BU1/H resulting in virtual ribbon development between Guiseley and Addingham. Creeping urbanisation is a major threat to the environment and damage those qualities that attract visitors and prosperity.

Maintaining open spaces and wildlife is fundamental to environmentally sound and sustainable development. Plan deviates from this.

Plan is disingenuous in promises to improve infrastructure and conflates Green Belt release with them when policies could be implemented independently. No guarantee that these improvements/mitigation will be delivered due to current climate.

Plan offers destruction of the Wharfedale environment with no clear benefit.

Object

Representation ID: 21790

Received: 23/03/2021

Respondent: Duncan Watson

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 21882

Received: 23/03/2021

Respondent: Catherine Starling

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 21911

Received: 23/03/2021

Respondent: Dr Samantha Cook

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 21940

Received: 23/03/2021

Respondent: Birgit Almond

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 21969

Received: 23/03/2021

Respondent: Mrs Corrie Hardaker

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 21998

Received: 23/03/2021

Respondent: Carly Mitchell

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 22027

Received: 23/03/2021

Respondent: Helen Ross

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 22059

Received: 23/03/2021

Respondent: Rebecca Spencer

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 22088

Received: 23/03/2021

Respondent: Lucy Ashton

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 22117

Received: 23/03/2021

Respondent: Mr Chris Turner

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 22146

Received: 23/03/2021

Respondent: Judy Breckett

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 22186

Received: 23/03/2021

Respondent: Mr Paul Hardaker

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 22215

Received: 23/03/2021

Respondent: Helen Taylor

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 22244

Received: 23/03/2021

Respondent: Dr Ceri Pitches

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 22273

Received: 23/03/2021

Respondent: Mrs Sonya Hampton

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31