Consultation Question 60

Support

Representation ID: 318

Received: 19/02/2021

Respondent: Ms Mel Frances

Support on the whole but building on green spaces, such as Wycliffe gardens, only to replace them somewhere else is madness.
Sports and recreation needs to go beyond hard surface sports facilities, we need green spaces for fresh air and walking.

Object

Representation ID: 2152

Received: 18/03/2021

Respondent: Mrs Janet Vekaria

We need our green spaces. They are vital for mental and physical wellbeing. Climate change and pollution are real problems that need tackling and maintaining green space in urban areas will help to offset the effects of pollution. New housing needs to be built on existing sites and should never be built on green belts or green spaces. Communities and children need space to exercise and breathe

Support

Representation ID: 2533

Received: 20/03/2021

Respondent: Mr Peter Down

I support the proposed Policy CO1. No further comment.

Support

Representation ID: 3296

Received: 22/03/2021

Respondent: Wilsden Parish Council

We support the overall objectives of Policy CO1 to both maintain and enhance the provision of Open Space, Sport and Recreation facilities. The policy gives comprehensive details of how the Local Plan can audit and record existing provision but doesn’t give as much detail of how to ensure that this provision of Open Space, Sport and Recreation can evolve to meet the developing needs of their local communities. Policy SP16 refers to working with town and parish councils and for parts of the district where these are in place they are ideally positioned to effectively engage with all sectors of the community.

Object

Representation ID: 3717

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: 3867

Received: 23/03/2021

Respondent: Jenny Woodward

Every resident in Bradford should have access to open, natural space within a reasonable distance of their house. Standards need to apply to ALL houses, not just new developments.

Support

Representation ID: 5654

Received: 24/03/2021

Respondent: Mrs Jane Callaghan

broadly support. The best use of current recreation grounds should be priority as these are often key green open spaces within settlements and, where needed, works to make them better drained and therefore less prone to surface damage is important to keep them within easy walking distance of residents of all ages

Object

Representation ID: 9821

Received: 12/03/2021

Respondent: Bradford District Ward Councillor (Labour)

CO 1 I have been concerned that some areas of Bradford are overpromoted e.g. Ilkley Moor where there are many others that should be promoted and developed. Baildon moor would be an example. We also need to develop areas for off-road use by bicycles, motor bikes and potentially quad bikes. This would help prevent improper and damaging use elsewhere. Also, my ward – Keighley West - has inadequate park/recreational areas, which are simply not provided by developers.

Object

Representation ID: 10967

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

The policy states that all areas of designated open space will be protected, and this applies to outdoor sporting facilities. As illustrated on the proposed Policies Plan and within the Queensbury section of the proposed Draft New Local Plan, this would include Queensbury Golf Course.
However, as illustrated by the adopted UDP Proposals Map this designation is not currently afforded to the Golf Course and is therefore a new proposal.

We repeat our points also made towards Policy SP10 in this regard.

Comment

Representation ID: 19690

Received: 24/03/2021

Respondent: Sport England

Welcomes the principle of this policy in respect of the protection of open spaces that reflects paragraph 97 of the NPPF.

We are also pleased that it cites the Council’s Playing Pitch Strategy that is currently being reviewed and will provide an up to date evidence base.

In respect of the part of the policy that states: ‘Where open space is to be provided, development proposals should ensure that…’

This part of the policy refers to standards. However, there is a move away from a standards approach.

The provision of new sport facilities should be identified by the sports evidence base and this could be either through new provision or enhancements to existing provisions in order to meet the new demand.

We would advise incorporating Sport England’s Sports Facility Calculator into the policy.

Comment

Representation ID: 19720

Received: 24/03/2021

Respondent: Sport England

Sport England does not have resource to check every site allocation.

Any site allocation that may contains a sport facility such as a playing field or swimming pool, etc. where these facilities will be lost, the allocation needs to be consistent with paragraph 97 of the NPPF.

Simply allocating a site for a non sporting use does not override the requirement to evidence whether any sport facility is surplus or needs to be replaced.

Bradford Council are completing a Playing Pitch Strategy, and this should be used as the evidence base to determine the impact of any allocation on playing fields.

Re built sport facilities, an Indoor Sport Facility Needs Assessment will be required to determine any impact that an allocation may have on a built sport facility.

Impact that allocations may have adjacent to existing sport facilities:

Any allocation that is directly adjacent to a sports ground such as cricket club needs to consider any issues in relation to ball strike. Various case law examples are provided.

Ball stop mitigation needs to be provided as part of an allocation.

This principle also applies to issues such as noise being generated by an existing sports facility whereby the allocation needs to provide suitable noise attenuation mitigation.

Object

Representation ID: 19827

Received: 24/03/2021

Respondent: Airedale NHS Foundation Trust

Agent: WSP UK Ltd

It is requested that the areas designated for Amenity Space and Green Infrastructure on the southern part of the hospital site are omitted. If a second access / egress point is proposed, the Trust would not want these designations preventing the highway improvements progressing.

Support

Representation ID: 19874

Received: 01/04/2021

Respondent: Natural England

Natural England considers that the approach set out in CO1 to open space provision is robust and based on up-to-date evidence. We welcome the inclusion of item D which sets out the requirement for the mitigation of recreational pressure on the South Pennine Moors SPA and SAC arising from residential development which is defined as Use Class C3, and advise that this could be strengthened by the case-by-case consideration of all major proposals for C1, C2, and C4 development, and for sui generis uses such as caravan and camp sites.

Furthermore, we note also that there is still disparity around the Use Classification of student accommodation, with local authorities adopting different elements of the Use Class Order including C1, C2, C3 or sui generis uses. Major proposals for Purpose-Built Student
Accommodation should also be included within this policy in relation to the potential for increased recreational pressure on designated sites arising from this type of development, to be assessed on a case-by-case basis.

Comment

Representation ID: 23778

Received: 23/03/2021

Respondent: Fields in Trust

To comment briefly again in relation to the Open Spaces standards as per my notes on these from the Open Spaces Audit (Appendix 11 of the Plan).

Main policy related to open space is Policy CO1, which protects land identified as open space, as defined on the Policies Map, from development. It also states that the Council will work with neighbourhood forums to designate sites as Local Green Space. Fields in Trust (FiT) believes the protection used by the Council on numerous green spaces since 2010 would guarantee these spaces are protected far beyond the Local Plan`s remit.

Beyond “ad-hoc” protections, FiT`s strategic need-based mapping work with Liverpool City Council is being viewed with interest. Our research illustrates that Bradford would benefit from the same approach and would welcome the opportunity to discuss our research, green space index and mapping capabilities further in addition to our input into your consultation.

Comment

Representation ID: 27782

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

It is noted that Policy CO1 contains reference at Point D to residential developments which contribute to recreational pressure upon the South Pennine Moors SPA and SAC being required to mitigate these effects in line with the requirements of Policy SP11 and the South Pennine Moors SPA/SAC Planning Framework SPD, which could include the provision of new recreational natural greenspaces or improvement to existing open spaces.

Suggested amendments to Policy SP11 set out above and in Appendix 2 will ensure that reference to the provision of new, or improved, open space as having the potential to mitigate recreational pressure on the SPA/SAC is consistent with the provision of Policy SP11 and the accompanying SPD.

Comment

Representation ID: 27911

Received: 24/03/2021

Respondent: CEG Land Promotions Ltd

Agent: Lichfields

CO1 PART D
The proposed amendments to Policy SP11 that are described (in separate representation) will ensure that reference to the provision of new recreational greenspace, or improved open space as having the potential to mitigate recreational pressure on the SPA/SAC is consistent with the provision of Policy SP11 and the accompanying SPD.

Support

Representation ID: 27931

Received: 24/03/2021

Respondent: Jason Harden

Continue to protect important areas of open space

Object

Representation ID: 28530

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

The policy requires new residential developments to provide new open space on-site where possible or make a payment in-lieu of on-site provision.

In order to calculate the extent of on-site provision, the Council have included an Open Space Standard at Appendix 11, which sets out the expected level of existing provision per 1,000 of the population and the required maximum distance from residential property to each type of open space. It is then for the applicant to decipher the extent of open space that is required on each development factoring in local deficiencies and surpluses.

We would suggest it is incumbent on the Council to inform the applicant as to the type and level of open space that is required rather than it being the applicant’s responsibility.

A more suitable approach would be to require a set level of open space per dwelling as this gives clarity to applicants when considering development proposals.

Object

Representation ID: 29001

Received: 24/03/2021

Respondent: National Trust

Within NT ownership, it is noted that the majority of the central part of the East Riddlesden Hall estate is designated as open space, sport and recreation (parks & gardens), excluding land adjacent to the car park. The two cricket grounds within wider NT ownership are also designated as such.

Whilst we have no objection in principle to the open space and recreation designation we are concerned that the totality of the existing buildings East Riddlesden Hall and its car park are included as ’open space’ and we are not convinced this designation is entirely appropriate across the whole National Trust property. Whilst there is open space and gardens within it, the function of this important historic place is as a national trust visitor property, which includes the Hall itself and the established weddings venue within the barn and its car park. We believe the designation should be amended to remove ‘open space sport and recreation’ across the core of visitor facilities here.

Support

Representation ID: 29002

Received: 24/03/2021

Respondent: National Trust

We generally support point A of this policy which states that “land identified as open space, as defined on the Policies Map, will be protected from development.” However, as described above, we are keen to ensure that only specific areas of open space are designated to ensure that this policy is appropriate.

Support

Representation ID: 29090

Received: 29/03/2021

Respondent: Historic England

We support this Policy. We particularly welcome:
 Criterion B.3 - Where there are open spaces in the vicinity of development sites, then, instead of automatically requiring the provision of open space on the development itself, there may well be wider public benefits through the enhancement/restoration of existing open spaces. This is particularly the case where there is clear evidence that an existing open space is likely to be regularly used by the occupants of a new development.
 Criterion E - Where the Council will work with local communities to identify areas of Local Green Space and the protection that this Criterion provides for these spaces. The protection and enhancement of these areas will contribute to the delivery of that aspect of the Vision which relates to the creation of an attractive District and the protection and enhancement of its environmental assets.

Object

Representation ID: 29091

Received: 29/03/2021

Respondent: Historic England

Several of the District’s open spaces are either designated as heritage assets in their own right or contribute to the character or setting of Bradford’s historic buildings, structures or areas.
The second part of Criterion A, setting out the exceptional circumstances under which the loss of open space may be permitted, does not provide sufficient protection to the those spaces which contribute to the setting of heritage assets or to local character and distinctiveness.
Criterion A, add the following additional provision following on from point 3. ‘and,
4. In all cases, the loss will not result in harm
to a heritage asset, including its setting.’

Object

Representation ID: 29712

Received: 24/03/2021

Respondent: Keyland Developments Ltd

Agent: Barton Wilmore

The policy requires new residential developments to provide new open space on-site where possible or make a payment in-lieu of on-site provision.

To calculate the extent of on-site provision, the Council have included an Open Space Standard at Appendix 11, which sets out the expected level of existing provision per 1,000 of the population and the required maximum distance from residential property to each type of open space. It is then for the applicant to decipher the extent of open space that is required on each development factoring in local deficiencies and surpluses.

We would suggest it is incumbent on the Council to inform the applicant as to the type and level of open space that is required rather than it being the applicant’s responsibility.

A more suitable approach would be to set a set level of open space per dwelling as this gives clarity to applicants when considering development proposals.

As such, our Client objects to the proposals as currently drafted.

Comment

Representation ID: 30126

Received: 06/10/2021

Respondent: Wycliffe Neighbourhood Association

Local Green Space Designation to Land at Wycliffe Road, Thompson Street and Moor View Avenue, Shipley

Object

Representation ID: 30127

Received: 06/03/2021

Respondent: Mrs Gillian Barton

I want to keep our green spaces green. It’s a heavily populated area as it is, so our green belt is really important for the environment and for our collective mental health! I don’t mind if brown belt land is used, and there seems to be plenty of that about doing nothing, so please leave our green spaces alone!