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

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.

Object

Representation ID: 5918

Received: 24/03/2021

Respondent: Baildon & Shipley Friends of the Earth

Baildon FOE -SP7
1. New housing development generates more vehicle movements. The Climate Emergency means that private car use needs to be driven down; not allowed to increase.
2. The phrase “support the shift” (to sustainable transport) does not mean anything much. It is a weak phrase. There needs to be a concerted effort, unwavering determination and change in culture to bring about the transformational change.
3. Bring the Bradford Cycle Strategy (‘Keeping the Wheels Spinning’) into the mainstream, embrace it properly, and let that inform the Local Plan. This is about “making Bradford District a place where is cycling is naturally a part of everyone’s daily life.”
4. Short pedestrian journeys can be made easier and safer by many of the guiding principles associated with School Streets and LTNs. Again, this ties in with the 15-minute neighbourhood concept.
5. See also our reference to Vauban, Germany, under SP4.

Object

Representation ID: 5921

Received: 24/03/2021

Respondent: Baildon & Shipley Friends of the Earth

Previously Developed Land / Efficient Use of Land

1. The underlying principles of housing growth should be Social Equity, Sustainable Development, Sustainable Location, Urban Capacity, Participative Processes, and Zero Carbon Design
2. See also under SP9 and EN10 concerning zero carbon design.
3. Vauban, Germany, is an example of what can be achieved in terms of neighbourhood passivhaus standards.
4. It appears that the proposed greenfield land take in the Plan is approaching double what it would need to be if all greenfield development were built to the policy-compliant 50dhpa net. In particular, most of the Green Belt housing allocations are proposed to be developed well below the densities required by the Plan’s policies relating to density.
5. With the climate emergency, there can be no place for any more development involving large detached houses with driveways and garages.
6. ‘Design and Beauty’ and “working with the landscape” are good concepts.

Object

Representation ID: 5924

Received: 24/03/2021

Respondent: Baildon & Shipley Friends of the Earth

Baildon & Shipley FOE – SP9
1. Targets seem reasonable, but this policy needs to be strengthened by calling for modelling by developers for all new developments to demonstrate that the proposed development is carbon-neutral or carbon negative, in terms of emissions from construction, building energy use and travel resulting from the development.
2. This requires construction and heating standards to be very high; to or approaching Passivhaus standard.
3. There should be no space for car parking. New neighbourhoods must be ’15-minute’ neighbourhoods.
4. Minimisation of surface water run-off is vital, as is provision of some green space. The use of trees and other planting, where appropriate, should form part of a landscape scheme to provide shading of amenity areas, buildings and streets and to help to connect habitat, designed with native plants that are carefully selected, managed and adaptable to meet the predicted changed climatic conditions.

Object

Representation ID: 5932

Received: 24/03/2021

Respondent: Baildon & Shipley Friends of the Earth

Baildon & Shipley FOE – TR1
1. LTNs should be widespread.
2. ‘Efficiency’ in highway engineering terms has a tendency to be very motor vehicle-centric. The approach and mentality here needs to change fundamentally so that the most vulnerable road users (pedestrians and cyclists) are considered first. This also fits in with the concept of the 15-minute neighbourhood and motor vehicle-free neighbourhoods.
3. There is concern about the impact of Bradford-Shipley Route Improvement Scheme on Shipley. This road scheme is designed to increase road carrying capacity and, as a result, will lead to an increase in the volume of traffic. Induced demand is a well-known and well-researched consequence of more road-building.
4. It is also concerning that the new housing development associated with the Canal Roadwidening, has no school provision attached to it. How can that work properly, especially bearing in mind the need for the 15-minute neighbourhood?

Object

Representation ID: 5935

Received: 24/03/2021

Respondent: Baildon & Shipley Friends of the Earth

Baildon & Shipley FOE – TR2
1. See also our submission under TR1
2. The Bradford-Shipley road scheme is in direct contradiction to the climate emergency declaration.
3. Modelling needs to be carried out to assess what the likely increase of carbon emission will be from any new transport infrastructure projects to ensure they are compatible with Bradford Councils aim to get to net-zero carbon emissions by 2038.

Object

Representation ID: 5936

Received: 24/03/2021

Respondent: Baildon & Shipley Friends of the Earth

We support the idea of a hierarchy of development favouring ‘zero-car’ developments and welcome the designation of developments which barely reduce vehicle use as ‘unsustainable’. However, in Policy TR3 there is no reference to this hierarchy. For example, would developments classified as ‘unsustainable’ automatically be refused? TR3 B states that ‘development should support and contribute to appropriate levels of enhancement of all transport’ and then lists priorities.
This appears to be very open-ended: ‘contribute to’ and ‘appropriate levels’ for cycling versus public transport and highways will, in practice, be impossible to evaluate and rank.
Instead, developers should be required to demonstrate how they have chosen to prioritise cycling/walking and public transport over car-use in their transport statements.
LTN principles should be the default expectation in major developments so that, for example, it is easier, more convenient or quicker to move around on foot or by cycle than by car.

Object

Representation ID: 5938

Received: 24/03/2021

Respondent: Baildon & Shipley Friends of the Earth

A policy of a housing density of 50 dpha for all sites, needs to be adopted. This will lead to more affordable homes being built and homes built in more sustainable locations.

Object

Representation ID: 5944

Received: 24/03/2021

Respondent: Baildon & Shipley Friends of the Earth

1. Development proposals are required to evidence a thorough understanding of context through the preparation of a proportionate assessment of existing and planned green infrastructure, biodiversity and ecological features and networks both on the site and in the locality.
2. Such development proposals must demonstrate how: (a) through physical alterations and a management plan for the lifetime of the development, certain aspects are maximised and there are net gains in biodiversity; and (b) the mitigation hierarchy has been applied systematically to avoid harm to biodiversity. If significant harm cannot be avoided in this way, development should not be permitted.

Object

Representation ID: 5945

Received: 24/03/2021

Respondent: Baildon & Shipley Friends of the Earth

1. Refer to the Merton Local Plan, which requires the highest standards of sustainable design and construction.
2. A sustainable construction checklist SPD is required for many developments.
3. EN 10 states that the Council and its partners will “maximise” improvements in energy conservation and so on; yet then states that zero carbon standards will only need to be met for developments of fifty plus houses. This is a striking contradiction and should be amended so that all new developments (including single dwellings), residential and non-residential, should achieve zero carbon standards.
4. Certain stringent requirements concerning heating, need to be met, with a hierarchy dictating the source for the communal heating system.