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

Object

Representation ID: 5462

Received: 24/03/2021

Respondent: CPRE West Yorkshire

In line with our comments on policy SP5, we object to these site allocations:
NW7/H
NW8/H
NW9/H
NW10/H
NW13/H
NW19/H - Considering the recognition of the site’s parkland setting, in our view the site is unsuitable for development at sufficient density to constitute sustainable development, and it should not therefore be allocated.

Support

Representation ID: 5463

Received: 24/03/2021

Respondent: CPRE West Yorkshire

We support this policy, subject to our objections to policies SP6 and SP8 being addressed.

Support

Representation ID: 5464

Received: 24/03/2021

Respondent: CPRE West Yorkshire

We support this policy as drafted.

Object

Representation ID: 5465

Received: 24/03/2021

Respondent: CPRE West Yorkshire

We have not had the capacity to analyse this policy and will reserve comment; other than to emphasise that minerals policy must be compatible with the Council’s climate targets; and we recommend that this should be incorporated into SP12(4) along the following lines:
Seek to ensure that the provision of new minerals development (including hydrocarbons) meets key environmental criteria, protects human and natural resources, and is compatible with the aim of achieving net-zero greenhouse gas emissions by 2038.

Support

Representation ID: 5466

Received: 24/03/2021

Respondent: CPRE West Yorkshire

We fully support and welcome this policy.

Support

Representation ID: 5467

Received: 24/03/2021

Respondent: CPRE West Yorkshire

We fully support and welcome this policy.

Support

Representation ID: 5468

Received: 24/03/2021

Respondent: CPRE West Yorkshire

CPRE welcomes and supports policy SP9 as a bold and clear policy for climate action. We especially welcome the inclusion of the high-level target of net-zero 2038 within the policy, which shows Bradford taking a lead where some local authorities are still lagging behind.

We recommend that SP9(A3) is amended to make clear that achieving the headline target is dependent on all developments making a net contribution to carbon emissions reduction.
Suggested wording:
Development proposals will be supported where they can demonstrate that their total net impact will be to reduce the greenhouse gas emissions arising from the combination of their construction, use and associated transportation of people and goods. They will be required to incorporate mitigation and adaptation measures to address the impacts of climate change, appropriate to their scale, use and location.

We recommend that SP9(B1) is amended to take account of the need for increased development
densities to reduce road traffic and increase use of walking and cycling.
Suggested wording:
Following the settlement hierarchy and be:
a. Located in areas which are close to services and facilities and are accessible by public
transport;
b. Developed at sufficient density to support local amenities and make walking, cycling and public transport viable and attractive travel choices for the majority of journeys;
c. Designed to prioritise and enhance sustainable transport choices within the development and connecting to it from adjacent neighbourhoods.

Object

Representation ID: 5469

Received: 24/03/2021

Respondent: CPRE West Yorkshire

We’ve not been able to visit the site ourselves but concerns have been brought to our attention by local groups in Addingham. In addition to the strategic level, we have noted these specific concerns which point to unsustainable outcomes from these allocations:

AD1/H - distance of the site from the village centre which is a deterrent to walking or cycling
AD3/H - not located near public transport
AD6/H - Only part of site within 400m of a bus stop with two services every hour; distance from the village centre will be a deterrent for walking and cycling

The sites proposed for Addingham, like many other sites across the district, are proposed to be built within green belt land and at a gross density as low as 16dpha on one site (AD7/H).

Object

Representation ID: 5470

Received: 24/03/2021

Respondent: CPRE West Yorkshire

In line with our comments on policy SP5, we object to these site allocations:

QB1/H
QB4/H
QB5/H
QB6/H
QB8/H
QB9/H

Our recommended approach to density would mean that it should not be necessary for all of these sites to be allocated in order to meet the settlements development needs.

Object

Representation ID: 5471

Received: 24/03/2021

Respondent: CPRE West Yorkshire

We’ve not been able to visit the site ourselves, but concerns have been brought to our
attention by local groups in Ilkley. In addition to the strategic level, we have identified the
following sites which we believe to have an impact on the local area:
▪ IL1/H
▪ IL2/H
▪ IL3/H
As stated in our objection comments on policy SP5, proposed development within the
Green Belt across the district shows a net density averaging around 26 dpha, well below the
HO2 minimum of 35 dpha. These sites identified in Ilkley are lower still, with gross densities
of 18.11, 16.95 and 20.92.
We also note that IL4/H, while not in the Green Belt, is also the subject of significant local
concerns especially about flood risk. We would suggest that the development needs of Ilkley
need to be re-examined from the perspective of producing more compact development at
significantly increased density, thereby improving walkability, having much-reduced landtake and allowing for real enhancements to green infrastructure and flood management