Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

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Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Consultation Question 2

Representation ID: 1064

Received: 09/03/2021

Respondent: Birkbeck, University of London

Representation Summary:

This seems a clear and positive statement of goals, with balanced consideration of competing requirements. However, I would note that there are a very large number of typographical errors in the area of the statement relating to the environment (and only this area), which gives the impression, intentionally or otherwise, that this was given less attention than other sections (typos marked in square brackets):

It will meet the environmental objectives by the inclusion of [a] suite of policies design[ed] to protect, conserve and enhance it['s] environmental assets, by focusing development [on] its main urban areas and by investing in public transport infrastructure[,] in the process reducing the need to travel by car and reducing climate change emissions; and

It is also interesting that the aim is to maximise use of brownfield sites 'wherever possible' but that no 'wherever possible' pertains to minimising green field development.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Consultation Question 5

Representation ID: 1067

Received: 09/03/2021

Respondent: Birkbeck, University of London

Representation Summary:

While some of this may be answered in the following point, this policy outline (SP4) does not give sufficient indication of the requirements that would be placed upon applications for green belt release. It also does not indicate if there would be any hard cap on green belt release for the whole district or lease within it, giving scope for potentially unlimited greenbelt release based on 'prioritisation' of factors not here presented. The wording - prioritisation of greenbelt release -, as opposed to prioritisation of greenbelt protection is very concerning. Surely priority should always be given to reducing greenbelt release as the primary consideration in any application?

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

KY7/H - Wheathead Lane

Representation ID: 1070

Received: 09/03/2021

Respondent: Birkbeck, University of London

Representation Summary:

KY7/H - Wheathead Lane, Keighley: this area has already been heavily built up and it is not clear where parking, road access ad drainage could fit.

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Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Consultation Question 8

Representation ID: 1074

Received: 09/03/2021

Respondent: Birkbeck, University of London

Representation Summary:

This is all vey positive and exciting. I would add only two comments:

- First, encouraging ride sharing, while a good-sounding idea in principle, comes with severe and under-addressed safety issues that disproportionately affect female users. This is not just an issue in this document or in this region - it is a policy that for many years has been proposed, mainly by men, as a viable solution for reducing road use.

- Second, local topography means that unless e-bike stabling (mentioned in the document) and subsidy for e-bike purchase/hire is actively promoted, cycling is going to be a non-starter, no matter how much provision is made for cycle ways. There are just too few places in the district that can be connected by bike that do ot include hills too steep and long to put off all but the most committed cyclists.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Consultation Question 9

Representation ID: 1086

Received: 09/03/2021

Respondent: Birkbeck, University of London

Representation Summary:

Housing Need and Requirement

The core information missing from this discussion is the basis upon which future housing needs have been calculated, by whom and based on what assumptions in approaching the data. The discussion above already indicates that the projected 1704 houses per annum, of which only just over half will be built on brownfield sites (and a truly abysmal proportion in some areas) 'will ensure that the housing requirement will meet (and exceed) demographic housing need in terms of projected household growth'. What possible justification is there for exceeding demographic housing need? With global population projected to plateau over the next 30-60 years and to decline in the industrially developed world, what is the basis for assuming the housing need outlined in this document?

Support

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Consultation Question 26

Representation ID: 1092

Received: 09/03/2021

Respondent: Birkbeck, University of London

Representation Summary:

In general, I strongly support enhancement of public transport and reduction of car use, however, in suggesting that the council might use parking provision as a 'lever' (let's be honest, and call it a stick), no consideration seems to be given to the fact that the choice is often not between 'Drive to location A and park or go to location A by public transport'. It is more often 'Go to location where the reason for travelling makes journey by car most sensible or go to another location to achieve the same ends'. I have on several occasions chosen to travel to Leeds, Halifax or Wakefield to accomplish tasks that could have been achieved in Bradford precisely because of lack of available parking, and because public transport did not provide an adequate solution. In short, provision of effective public transport needs to precede reduction in parking.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Consultation Question 57

Representation ID: 1093

Received: 09/03/2021

Respondent: Birkbeck, University of London

Representation Summary:

Site EN19.2: Aire Valley Road, Keighley: this is not an objection to a waste management site, per se, but to an incineration site about which serious concerns have been raised regarding air quality.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

KY10/H - Exley Road/Oakworth Road, Keighley Road

Representation ID: 1095

Received: 09/03/2021

Respondent: Birkbeck, University of London

Representation Summary:

There is only one shop within walking distance of this site. All other amenities would require use of Oakworth Road into town, which is already clogged on busy days. The drainage system is already overloaded (exacerbated by building residue from the construction site on Occupation Lane). There is also currently no sensible road access to this site.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

KY13/H - Keighley Road, Exley Head

Representation ID: 1096

Received: 09/03/2021

Respondent: Birkbeck, University of London

Representation Summary:

Current developments slightly to the east of this proposed site, and at a similar elevation, on Occupation Lane, have proved of long-term detriment to the Exley Head area, with building run-off blocking drains along the Keighley Road and Exley Road and causing damage to road surfaces. There is also a serious shortage of access to amenities from this site, especially in walking distance. Any additional traffic pressure on Oakworth village would be a significant hardship to the residents there.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

OA1/H - Pasture Avenue

Representation ID: 1098

Received: 09/03/2021

Respondent: Birkbeck, University of London

Representation Summary:

I would like to object to this proposed site for residential development in the strongest possible terms. The idea of 'sustainable greenbelt development is', in any case oxymoronic. Greenbelt is a finite resource so there is no such thing as sustainable building on it. You can either sustain it or build on it. These are mutually exclusive options. With respect to this specific instance, however, the cases made for positive impact are weak and do not consider the specific circumstances of the site (or do so in very odd ways). There is limited road access, onto a busy thoroughfare (the Keighley Road) or into the already over-crowded streets of Oakworth. There is only one accessible shop. The proposed dwellings would add considerable strain to Oakworth's existing resources.

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