Consultation Question 7

Object

Representation ID: 993

Received: 08/03/2021

Respondent: Clive Brook Planning

This objection to the policy is based on the wholly inadequate proposals for job creation and employment land provision and their lack of alignment with the Council's own economic strategy and the much more positive approach being taken by a number of the West yorkshire planning authorities.

Support

Representation ID: 1877

Received: 16/03/2021

Respondent: Sir Stephen Brown

I ASSUME YOU WILL CHECK THIS ADMIRABLE POLICY AGAINST THE LIKELY NEW NORMAL POST COVID?

Object

Representation ID: 1908

Received: 17/03/2021

Respondent: Burley Parish Council

3.6.1 Statistics in SNPP clearly shows that across the plan period, the number of people in lower age groups is a shrinking not a growing proportion of the population.

3.6.4; 3.6.8: there is a need to ensure that through a strategy for inward investment, employment needs align with the District’s strengths by re-deploying and retraining workers so the they can contribute to the demands of the green economy.

3.6.9 The release of green belt for housing away from these areas is contrary to the need for homes to be localised close to centre of employment to reduce the reliance on the car.

3.6.12; 3.6.13: Future employment growth should be calculated using outcomes supported by data rather than to simply adopt an approach that factors none of these issues into account.

Support

Representation ID: 2467

Received: 20/03/2021

Respondent: Mr Peter Down

Whilst in principle, I support the proposed policy SP6, there needs to be greater emphasis on support and promotion of small businesses. At present, the policy appears to be aimed at large corporations, retail chains and similar. However, the promotion of smaller, individual businesses will provide much more diversity and will offer a unique selling point for Bradford. It can also provide greater employment opportunities for local people and more focussed support to the communities these businesses serve, especially in Local Centres. These businesses re also likely to require support from other local businesses, thus, providing an overall benefit to the local economy. Promoting small, local businesses in Local Centres means that local communities have the employment and facilities they require close at hand and reduce the need to travel. This will have social and environmental benefits.

Object

Representation ID: 2746

Received: 21/03/2021

Respondent: Mrs Helen Owen

Please explain how this can be achieved without a massive improvement in school buildings, new schools being built to serve all these new houses.

Support

Representation ID: 2873

Received: 21/03/2021

Respondent: Alison Tribe

I support the policy's intention to develop the skills and potential of Bradford's workforce, particularly its' young people, but I am very disappointed that there is little mention of 'Green' jobs. The opportunities are almost endless in terms of skills development, apprenticeships, new enterprise and sustainable jobs provided by, for example, the need to bring the area's old housing stock up to high levels of insulation and energy conservation, ‘greening’ home energy by fitting solar panels, heat pumps etc, tree-planting, the management of habitat for flood protection and biodiversity – the list could go on.

Object

Representation ID: 3304

Received: 22/03/2021

Respondent: Mr David Wilmshurst

Para 3.6.15 states that for Employment Land Need and Jobs “This analysis was produced prior to the Covid-19 pandemic.” Account has not therefore been taken of the reduced demand for office and retail space following from increased working from home and online shopping resulting from the pandemic. The shortfall of 5,000 units is therefore excessive and the Green Belt land to be built on should be reduced accordingly. The Plan is therefore not in line with the National Planning Policy Framework para 11a which states that “plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change;” as with changes in land use resulting from the pandemic. It also contravenes paragraphs 3.8.42 and 43 which require Councils to maximise use of previously developed and under-utilised land and buildings, which could be used for housing.

Support

Representation ID: 3530

Received: 22/03/2021

Respondent: NEAT

Good as far as it goes - but where is any mention of freelance work?
The pandemic has highighted the precarious nature of freelance work, which was already a high-risk option.
Many people who are not in work have skills that could be put to use, but reliance on other people/firms creating a job does not always work.
For example, a deaf young adult has a real talent for making greetings cards, but she cannot start trading without insurance, and looking after tax affairs is a step too far for many people, not least those whose first language is not English (hers is BSL).
Another young adult, with an anxiety disorder, wanted to start in business but faced losing all benefits if ilness struck.
Bradford could be a national leader in enabling people to earn from heir skills whilst still having a safety net.

Object

Representation ID: 3674

Received: 23/03/2021

Respondent: Mr Philip Sutcliffe

he 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.

Support

Representation ID: 3776

Received: 23/03/2021

Respondent: Mr Andrew Lund

No comment required

Support

Representation ID: 3924

Received: 23/03/2021

Respondent: Mrs Susan Burn

I welcome and support this optimistic, ambitious and inspiring policy.

Support

Representation ID: 4874

Received: 24/03/2021

Respondent: Banks Property

Banks Property broadly supports the objectives of Policy SP6. It is vital that investment is supported and encouraged to enable economic recovery; policies should aim to maximise Bradford’s potential for growth and to attract and retain economically active people. Policy SP6 defines priority business sectors and clusters that will be supported through the provision of appropriately located sites and premises by area, and identifies Health, Digital and Professional Services as priority sectors for Wharfedale. No employment allocations are included in Wharfedale however to achieve this. The Local Plan must ensure that employment land allocations are distributed across all areas of the District alongside housing allocations to achieve sustainable development. Site BU/015 Land off Burley Bypass provides a suitable option for new employment land in Wharfedale, located directly on the A65. Banks Property has submitted further information on Site BU/015 in response to the Council’s Site Assessment Update Report (Feb 2021).

Object

Representation ID: 4894

Received: 24/03/2021

Respondent: Mrs Hazel Wilmshurst

Para 3.6.15 states that for Employment Land Need and Jobs “This was produced before the advent of the Covid-19 pandemic.” Consequently there has been a reduced demand for office and retail space due to increased working from home and online shopping resulting from the pandemic. The shortfall of 5,000 units is excessive and the Green Belt land to be built on should be reduced accordingly. The Plan does not tally with the National Planning Policy Framework para 11a which states that “plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change;” as with changes in land use resulting from the pandemic. It also contravenes paragraphs 3.8.42 and 43 which require Councils to maximise use of previously developed and under-utilised land and buildings, which could be used for housing.

Object

Representation ID: 4927

Received: 24/03/2021

Respondent: Bradford Shipley Travel Alliance

There must be mention of what kinds of jobs contribute to reducing net carbon emissions best, and which do not, with measures to encourage investment in the former and not in the latter. This should be remedied in the next draft.

Object

Representation ID: 5142

Received: 24/03/2021

Respondent: Mr Peter Jenkins

Again the vaguer altruistic principles are to be supported but infrastrucyure must come before development.

Exceptional circumstances must first be defined before this can be supported, certainly considering the brown field, unviable etc areas available else which MUST be frst in then queue for development in accordance with stated policy.

How this strategy supports local jobs and growth needs is not quantified.

Object

Representation ID: 5495

Received: 24/03/2021

Respondent: CPRE West Yorkshire

Please see attached document with comments.

Object

Representation ID: 5818

Received: 24/03/2021

Respondent: Mr John McKee

As stated in 3.6.4 skill levels are below the regional average with no definition of region. One of the key elements to raising the skill levels is education including the provision of buildings. There appears to be a lack of joined up thinking between the objective to increase skill levels, and the provision of education capacity. The Coronavirus pandemic may lead to a deterioration in this respect.

Object

Representation ID: 5914

Received: 24/03/2021

Respondent: Baildon & Shipley Friends of the Earth

Baildon & Shipley FOE – SP6
1. Bradford’s economic growth needs to be sustainable. Any aim to develop the “fastest growing economy” is at odds with tackling the Climate Emergency.
2. Bradford needs to move away from carbon- intensive jobs and sectors to low carbon sectors.
3. Sustainable development is about ensuring an economy that meets the needs of people now, within environmental limits, and allows future generations to meet their needs.
4. Embrace Doughnut Economics, and evaluate what is happening in Preston.
5. Bradford needs to play to its strengths when establishing a Plan, for instance with respect to the arts and creative industries. The Preston model can be used as a blueprint.

Support

Representation ID: 5968

Received: 24/03/2021

Respondent: SHMS

Given the research and track record within the district on health care, (e.g. critical health care) and production of health care equipment, suggest this sector is encouraged and developed. New hospitals would create jobs growth in construction in both central Bradford and the Aire Valley.
This would also support growth of the higher education sector, nursing training, tele medicine, cancer research etc

Comment

Representation ID: 9799

Received: 12/03/2021

Respondent: Bradford District Ward Councillor (Labour)

SP 6 I was surprised not to see mention of digital connectivity, which is going to be essential for growth. The mention of our heritage and history was welcome, it would be nice to see it having meaning. The dilapidated state of, for example, North Street in Keighley rather gives a true indication as to what this means. I tend to ask “Why come to Keighley?” and it is difficult to answer. It could be a more positive response if we improved our cultural offer (arts etc.) made the countryside more accessible and improved our town centre experience – more variety on a new retail and entertainment sector.

Object

Representation ID: 10949

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We very much support part A1 of Policy SP6 and the specific reference in Part C1 to support the delivery of at least 1,600 jobs per annum up to 2038.

However specific reference to housing development and its ability to significantly contribute to the local economy is not featured in this policy or the supporting text to Policy SP6. Housing development would assist in helping the local community that new housing development does not just bring new houses. It brings new jobs directly through the planning, design and construction process and also thereafter through increased household expenditure and taxation jobs, affordable housing and other opportunities.

As such, it would be helpful if Policy SP6 cited a direct relationship between economic growth and housing growth, either in the policy itself or failing that, at least within the supporting text.

Object

Representation ID: 11025

Received: 17/03/2021

Respondent: The Strategic Land Group

Agent: Walsingham Planning

Core Strategy (CS) Policy EC2 confirms that the Council will support the delivery of at least 1,600 new jobs annually up to 2030, a target maintained in the Draft Local Plan. The CS evidence base makes clear, to achieve that target requires the delivery of 2,476 new homes per year, in excess of the proposed Draft Local Plan target.

To ensure that the Council’s economic aims can be achieved, it is essential that a housing strategy is put in place that seeks to deliver minimum annual local housing need figure f, derived from the correct and complete adoption of the standard method - a minimum of 2,300 dwellings per annum for the plan period.

Delivery of sufficient housing is fundamentally key to the Council’s ability to meet its economic target. As such, it is essential that a higher scale of housing delivery is proposed via the Draft Local Plan Strategy.

Object

Representation ID: 11392

Received: 17/03/2021

Respondent: Mr Robert Felstead

Policy approach has not changed from previous plans, which have not been delivered. Outcomes will not change. Attracting knowledge based industries has not occurred. Approach should be to ensure that employment needs align with District’s strengths. Should be play to them and redeploy and retrain the existing workforce to contribute towards the demands of delivering the green economy.

Query why Green Belt employment sites, away from existing employment areas, are being considered. Housing needs be located close to employment centres, aligning with the transport strategies need to reduce car use and mirrors the ambition to deliver a ‘greener economy.’

Use of REM model is questioned when other models (Cambridge; Experian) point to different outcomes. Also need to look at commuting flows as well as population forecasts (SNPP). Would be prudent to look at the outcomes of these models and data when calculating future employment growth.

Council needs to change approach.

Comment

Representation ID: 13823

Received: 20/03/2021

Respondent: John Finnigan

The Bradford District’s Economic Recovery Plan, stress testing the Economic Strategy on which the BDLP is based. There is nothing in the strategy. So how does Bradford recover faster than the others / make itself “a Learning District” / “Inspire, Reskill and Upskill. In what timescale?

The BDLP, be it the need for housing, or the need for employment land, or the “exceptional circumstances” justifying Green Belt release, is predicated upon aspirational and unpragmatic assessments of the future.

The Plan clearly requires regular review and update, but a road map for recovery with key performance indicators at each stage to see how it is happening, and if it is not happening what needs to be done to make it happen should be set out.

With Green Belt release, every five years the whole strategy should be reviewed/revised in the light of progress, and housing and employment land released as and when needed in the light of KPI performance.

Comment

Representation ID: 15770

Received: 24/03/2021

Respondent: West Yorkshire Combined Authority (WYCA)

The policy seeks to meet the employment land requirement in full through the allocation of a mixed portfolio of new employment land’ focusing most development within the urban areas - this is consistent with the SEP aspiration to attract inward investment into the City Region and WY Transport Strategy objectives to promote sustainable accessible development. However, emerging WYCA research has identified a lack of strategic industrial/warehouse employment sites in the west of the Sub-region including the district of Bradford.

Part 6 of the policy, which is directed towards the delivery of digital infrastructure, would benefit from being expanded to highlight some of Bradford’s particular strengths and opportunities in this area.

The Plan would benefit from greater consideration of the impacts arising from the Covid-19 Pandemic, and the potential policy repercussions including - future patterns of development, the flexibility of transport options and increased reliance upon broadband/digital infrastructure. This should be informed by the WY Economic Recovery Plan and Transport Recovery Plan.

Object

Representation ID: 16719

Received: 24/03/2021

Respondent: Shipley Town Council

Bradford will not meet its target to reach zero carbon by 2038 if it does not focus on supporting the move away from carbon intensive jobs and sectors to low carbon sectors.

The phrase “fastest growing economy” is totally at odds with the stated aim of the Council to deliver sustainable development - which is about delivering an economy that meets the needs of people now within environmental limits, and allows future generations to meet their needs.

This policy should be reworded to say:
● Bradford aims to be at the forefront of the UK's LOW CARBON economy, which will also support the social well-being of the people of Bradford

This section should also include a policy on how Bradford will use its own investments and assets to support the development of a low carbon economy – such as building socially rented houses to Passivhaus standards and supporting a huge roll out of retrofitting to improve the energy efficiency of the current housing stock and create skilled jobs.

Support

Representation ID: 17114

Received: 24/03/2021

Respondent: Caddick Developments Ltd

Agent: DPP Planning

We support Policy SP7 and the aims within it as outlined in Section 4.0

Object

Representation ID: 18067

Received: 24/03/2021

Respondent: Harworth Group & Nufarm UK Ltd

Agent: Johnson Mowat

Harworth and Nufarm support the aim stated at part A/1 of draft Policy SP6 for Bradford to be ‘the UK’s fastest growing economy getting more people into work and improving skills’. However, they have concerns that this aim is not matched / achieved, by the strategy of land allocation for employment development.

Part A/1d of draft Policy SP6 should be revised as follows:
‘Our globally connected district – making best use of and improving our transport infrastructure and digital connectivity to strengthen our global trading links and access new markets’.

Re B/2 of the policy - 72ha of land is inadequate provision to meet the stated aims to support business expansion, retain local jobs and attract new investment.

In order to ensure a correct range of sites / locations the following words should be added ti the policy:
‘For modern manufacturing and distribution, sites able to deliver large format development will be allocated in locations close to the motorway network, primarily in Bradford South’.

Object

Representation ID: 19772

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

The policy makes repeated references to growth with only a passing reference to “a move towards a greener economy”.

In our view, this will derail Bradford’s stated commitments to making the transition to both a net-zero carbon economy and a circular economy.

Instead, our Local Plan should focus on supporting the move away from carbon-intensive jobs and sectors to low carbon sectors. The policy should therefore be re-worded to say: Bradford aims to be at the forefront of the UK's net-zero carbon economy, as part of our drive to build circular economy principles and practice into our development strategies and to support the social well-being of the people of Bradford.

This section should also include a policy on how Bradford will use its own economic resources and assets to support the development of a low carbon economy - such as building socially-rented houses to Passivhaus standards and supporting retrofitting to improve the energy efficiency of our current housing stock.

Object

Representation ID: 19808

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

The policy makes repeated references to growth with only a passing reference to “a move towards a greener economy”.

In our view, this will derail Bradford’s stated commitments to making the transition to both a net-zero carbon economy and a circular economy.

Instead, our Local Plan should focus on supporting the move away from carbon-intensive jobs and sectors to low carbon sectors. The policy should therefore be re-worded to say: Bradford aims to be at the forefront of the UK's net-zero carbon economy, as part of our drive to build circular economy principles and practice into our development strategies and to support the social well-being of the people of Bradford.

This section should also include a policy on how Bradford will use its own economic resources and assets to support the development of a low carbon economy - such as building socially-rented houses to Passivhaus standards and supporting retrofitting to improve the energy efficiency of our current housing stock.