Consultation Question 6

Object

Representation ID: 27351

Received: 24/03/2021

Respondent: Paul Cryer

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: 27380

Received: 24/03/2021

Respondent: Wendy Barton

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: 27409

Received: 24/03/2021

Respondent: Mr Richard Bardsley

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: 27438

Received: 24/03/2021

Respondent: Paul Warren

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: 27544

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

Notwithstanding comments on the Plan period and the housing requirement, it is welcomed that the Council recognises that exceptional circumstances exist such that land should be released from the Green Belt to meet the future housing and economic development needs of the District, and to provide sufficient land for safeguarding such that Green Belt boundaries endure beyond the Plan period.

An amendment is requested such that the following is added to the list of sites at SP5 Part B

EM12/H – Land at Carr Lane, East Morton

The rationale for this is set out in Section 5 of these representations below.

Object

Representation ID: 27560

Received: 24/03/2021

Respondent: Danny Thompson

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: 27685

Received: 24/03/2021

Respondent: Peter Cartwright

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: 27719

Received: 24/03/2021

Respondent: Mrs Ann Todd

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: 27792

Received: 24/03/2021

Respondent: Richard Briggs

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: 27823

Received: 24/03/2021

Respondent: Claire Shouler

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

Comment

Representation ID: 27858

Received: 24/03/2021

Respondent: North Yorkshire County Council

It is noted that in order to meet the local housing need in the Bradford areas it is necessary to release Green Belt land for development. It will be important to ensure that any release of Green Belt does not compromise its purpose “to prevent urban sprawl or large built up areas; to prevent neighbouring towns merging into one another; to assist in safeguarding the countryside from encroachment; to preserve the setting and special character of historic towns, and…”. This would include considering the affect upon the setting of the landscape character and character of settlements across the border within North Yorkshire. It is further noted that the current approach is to not safeguard further Green Belt land. We would highlight Paragraph 136 of the National Planning Policy Framework which states that “once established, Green Belt boundaries should only be altered in exceptional circumstances….”. Releasing Green Belt for safeguarding would ensure that Bradford District can continue to provide for appropriate level of new growth beyond the plan period, providing certainty to communities as to where planed growth would take place. If sufficient land isn’t safeguarded this may lead to identified needs and pressure being placed on areas outside of the Bradford District.

Object

Representation ID: 27887

Received: 23/03/2021

Respondent: Samantha Armitage

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

Support

Representation ID: 27958

Received: 24/03/2021

Respondent: Bellway Homes Limited

Agent: Barton Wilmore

Our Client supports the Council’s conclusions that exceptional circumstances exist to release land from the Green Belt in order to meet their housing requirements, as outlined in the supporting text for the proposals.

In addition, they fully support the Council’s proposals to allocate site NW10/H for residential development of circa 160 dwellings, and specifically the 7.17 acres of land (see Appendix 1, below) that forms our Client’s interest in the northern section of the site. This has the potential to accommodate 75-80 new homes.

The site would lead to minimal encroachment into the countryside and minimise sprawl. Also, it would not lead to the coalescence of settlements. In summary, it would represent a sound and logical rounding-off of the settlement and its release from the Green Belt would be acceptable as it no longer serves the five Green Belt purposes.

Comment

Representation ID: 28036

Received: 24/08/2021

Respondent: Aimee Rawson

My main concern relates to the fact that protected sites and green belt sites are being considered for development. Once green belt becomes negotiable space for development there is no limit to the expansion of built-up areas as the expense of important green space (for both well-being, leisure/outdoor activities and wildlife habitat).
Should these green belt spaces and protected sites (including woodland and trees with TPO status) be made available for development, the developments must be forward-thinking eco-homes with an absolute focus on environmentally-friendly buildings and eco-friendly elements (eg. solar heated homes, wildlife corridors, maintaining of some wild areas including hedgerows and trees with TPO status, green energy technologies). As your plan clearly states, the climate crisis we are facing needs to be fore-front in our minds as we decide how to develop these sites, and how we change our approach to housing development to ensure a sustainable future for all.

Support

Representation ID: 28126

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

It is considered there are exceptional circumstances to justify the removal of green belt land on the eastern urban edge of Holme Wood, to facilitate the delivery of an urban extension, which will include a mix of residential, commercial and green infrastructure and associated new road infrastructure.

Support

Representation ID: 28127

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

HLM agree with the Council that there is an acute and intense need for employment land and there is a shortage of suitable sites such that exceptional circumstances exist for the release of sites from the Green Belt.

HLM agree with the Council that the demand for new employment land is on the southern edge of the City with strong links to the motorway network. Site SE37/E is well located to serve the strategic road network, it being well located for access to the M62 and M621. The scale of this employment area is appropriate and suitable for a variety of uses.

Object

Representation ID: 28186

Received: 24/03/2021

Respondent: Sarah Lucas

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

Support

Representation ID: 28237

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

Given the acute and intense need for housing, exceptional circumstances exist in order to deliver the housing requirement, including Green Belt releases.

NW9/H is a logical site for Green Belt release.

Object

Representation ID: 28276

Received: 24/03/2021

Respondent: Stephen Mould

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

Support

Representation ID: 28300

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

It is considered that with appropriate design and landscaping, that the exceptional circumstances of the need to meet the District’s housing requirement justify the release of site NW10/H and the wider parcel NW/024.

Object

Representation ID: 28361

Received: 21/03/2021

Respondent: Mr Cengiz Philcox

Consultation period is not long enough to comment on a massively complex, detailed plan. It is tokenistic. Undertaking take into the middle of a pandemic is cynical.

Plant faces several serious crises (biodiversity/ecosystem collapse, climate chaos, flooding, global health crisis). Plan will smother areas of Green Belt, nature reserves and agricultural land in development. It is part of the problem, not the solution.

Building on Green Belt land contravenes Government policy. Boundaries can only be changed in exceptional circumstances and inappropriate development approved only in very special circumstances. What the very special circumstances for releasing sites from the Green Belt.

Area has ex-industrial past. It full of brownfield/potential brownfield sites. Keighley College building has pulled down with proposed use for the site. Marley incinerator site provides no communities benefit. Would have been a perfect housing site, providing a benefit.

No concern for welfare of citizens or natural heritage and character.

Object

Representation ID: 28499

Received: 25/02/2021

Respondent: Dr Ros Brown

-Regarding cross-boundary approaches it is noted in the Local Plan para 3.5.7 & 3.5.13...
-Development proposals on/close to other LA boundaries should be considered/born in mind when considering Ilkley's Infrastructure capacity and funding. (E.g. Proposed 47 houses, 28,405 sq. ft. of rural office space and 90 parking spaces on the site of the old Middleton Hospital on the boundary between Ilkley and Harrogate BC. If there is no SCG then no recognition of the impact on Ilkley’s infrastructure should this development go ahead or any CIL or Section 106 agreement money. Even though the Harrogate BC SHELAA 2016 (Site Reference OC6) says this site is undeliverable for sustainability reasons and not part of their Local Plan.
-Economic impact of the pandemic - It would appear appropriate to revisit the ENALR in the light of the significant changes in working patterns and the increase of home-working to see whether more land identified for employment in Urban areas could now be used for housing to remove the pressure to release Green Belt sites.

Object

Representation ID: 28502

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

Our Client supports the Council’s conclusions that exceptional circumstances exist to release land from the Green Belt in order to meet their housing requirements, as outlined in the supporting text for the proposals.

However, they object to the inclusion of site SH4/H which is situated on land off Glenview Drive and is proposed to deliver 164 dwellings. They suggest that this site is not deliverable and suffers from steep topography and access problems.

This site should be replaced by a new combined site comprising SLA sites SH/044 SH/048 (see separate objection).

Object

Representation ID: 28521

Received: 26/03/2021

Respondent: Member of Parliament (Labour)

Housing requirement altered significantly from the Core Strategy (CS) (41,000+), Core Strategy Partial Review (CSPR) (26,100) and draft Local Plan (dLP) (30,672). Change not reflected across the District with Regional City taking significantly increased share.

CSPR requirement was opportunity to safeguard Green Belt - has not happened as dLP requires 5,267 dwellings in it.

Bradford South will suffer disproportionate burden of additional housing and Green Belt loss. 3,500+ dwellings proposed (11% of District requirement), 57% of which are Green Belt (1/3 of district’s total), with the majority (1,500) in one area. Neither equitable/sustainable.

Given Green Belt’s importance/sensitivity, its use should be minimised and development density towards the higher end. Green Belt sites average density (24/Ha) is below that of non-Green Belt sites outside main city/town centres, except Bradford South (28/Ha).

Area highly urbanised with overstretched infrastructure. Will add disproportionate burden on communities by removing more accessible Green Belt and intensifying urbanisation. Will give rise to health/wellbeing concerns.

Does not accommodate additional Government target (10,500 dwellings). Will have to come from Regional City. Concern it can only be met from Green Belt loss/further urban density in Bradford South.

Object

Representation ID: 28742

Received: 25/02/2021

Respondent: Dr Ros Brown

We do not accept that exceptional circumstances have been demonstrated for green belt change to accommodate housing or employment – for example:

• The plan indicates that the Government intends that the 35% uplift is targeted at large urban areas which must be taken to mean that the urban areas do in fact contain sites that the Council anticipate could be brought forward to meet that uplift.

• We do not accept that the housing density requirements set out in HO2 correspond with the site capacity assessment assessments for the sites in the plan

• We do not accept that the economic growth proposals set out in policy SP6 robustly justify the allocation of Green Belt sites for employment

A case for exceptional circumstances is in our view contingent on the Local Plan being confident that the resulting pattern of settlement both for housing and employment will actively address high-level challenges – the need to address climate action, the need to achieve significant environmental net gains through development as required by NPPF, and the scale of car traffic reduction needed, as confirmed by the West Yorkshire Emissions Reduction Pathways report.

SP5E describes an approach to compensatory improvements to the Green Belt. In line with our comments about net gain we suggest a rewording of SP5 :
“Where land is released from the Green Belt for development the Council will identify compensatory improvements to the environment quality and accessibility of remaining Green Belt that produce a measurable net improvement to the beneficial use of the Green Belt in the same locality as the Green Belts release. This may include inclusion of additional land in the Green Belt in those localities, and/or Local Green Space Designations to protect green spaces within settlements.”

The alternatives considered at 3.5.30, as with other aspects of the Plan, do not in fact present the consideration of reasonable alternatives. They describe a different approach to how the policy is laid out, but no alternative approach is offered either for increasing the proportion of new development directed towards urban brownfield sites; or for further increases in residential and employment density as a way to reduce the amount of Green Belt land required.

Object

Representation ID: 28992

Received: 23/04/2021

Respondent: Abi Lafbery

I fully disagree with the intended plans for housing on Green Belt land. In a time of climate emergency, and where there are available brown belt areas, the proposals are disgraceful. There will be inevitable issues such as the destruction of natural land and habitats, leaching, noise and light pollution will cause the removal and localised extinctions of many species.

Support

Representation ID: 28993

Received: 24/03/2021

Respondent: National Trust

We support part A of policy SP5 which states that “the extent of Green Belt within the District is identified on the Policies Map and has a valuable role in supporting urban regeneration and transformation, keeping settlement separate, concentrating development and conserving the countryside.”

We note that the Green Belt boundary surrounding East Riddlesden Hall has been maintained and we strongly support the retention of Green Belt within this area which assists in keeping settlements separate, conserves the countryside and in keeping land permanently open.

Comment

Representation ID: 28994

Received: 24/03/2021

Respondent: National Trust

As an observation we consider Part E could helpfully be subdivided to make a distinction between new development sites which would be required to provide compensatory improvements in the green belt and other proposals for use of land within green belt which would be supported only where it is consistent with national policy, so that it is not muddled.

As a general principle, we consider compensatory improvements should be identified for the development sites identified to be released in order to demonstrate that the impact of removing land from green belt can be offset. Planning Practice Guidance makes clear there may be scope for a range of measures informed by supporting evidence of landscape, biodiversity or recreational needs and opportunities including those set out in local strategies. We consider that the Plan should identify specific measures that will be delivered.

Object

Representation ID: 29034

Received: 23/03/2021

Respondent: Anne & H Graham Peacock

Number of people: 2

We have been repeatedly reassured that Green Belt areas are safeguarded against development by government ministers in person, through the national press and on television reports.

No account has been paid in the draft LP to the Planning White Paper which specifically protects green belt and conservation areas.

You now propose piecemeal changes across the District without this fundamental change first being tested by an Inspector.

The controversial decision recently confirmed to develop 500 houses at Sun Lane, Burley in Wharfedale, depleting the green belt, should be taken into account in any decision to develop any further green belt land between Burley and Ben Rhydding.

This is of prime importance to maintain a separation between the townships and prevent ribbon development along the A65.

Object

Representation ID: 29055

Received: 29/03/2021

Respondent: Historic England

NPPF paragraph 134d identifies that one of the five purposes of the Green Belt is to preserve the setting and special character of historic towns. The Green Belt Selective Review Part One Methodology Paper: Green Belt Parcels and Purposes (2019) sets out how the Council has considered this purpose when reviewing Green Belt boundaries, and identifies those settlements which are defined as historic towns for the purpose of the review. The first part of Policy SP5 should be amended to acknowledge the importance of this Green Belt purpose.

Criterion A, amend to read:
“A. The extent of Green Belt within the District is identified on the Policies Map and has a valuable role in supporting urban regeneration and transformation, keeping settlements separate, concentrating development, conserving the countryside, and preserving the setting and special character of historic towns.”