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

Object

Representation ID: 5483

Received: 24/03/2021

Respondent: CPRE West Yorkshire

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

BU1/H
BU2/H

The site BU1/H now has permission following the Secretary of State’s recent decision. In line with our strategic comments, development at low density will negate the claimed sustainability benefits of building in an accessible location.

Object

Representation ID: 5484

Received: 24/03/2021

Respondent: CPRE West Yorkshire

We’ve not been able to visit this site (ST1/H) ourselves but it has been brought to our attention based on the concerns from local groups. In addition to our comments on SP5, we would object to this site allocation. The gross density of the dwellings at ST1/H is much lower than we advocate, and is likely to achieve well below the HO2 minimum of 35 dpha net. As stated in the council’s report, 19% of the site is in 3b flood zones which causes concern for proposed development on this land.

In line with our comments on policy SP5, we also object to the site allocation, ST4/H.

Object

Representation ID: 5485

Received: 24/03/2021

Respondent: CPRE West Yorkshire

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

KY2/H
KY7/H
KY15/H
KY35/H
KY36/H
KY40/H

Object

Representation ID: 5487

Received: 24/03/2021

Respondent: CPRE West Yorkshire

In line with our comments on policy SP5, we object to the following site allocation:

EM1/H

Object

Representation ID: 5488

Received: 24/03/2021

Respondent: CPRE West Yorkshire

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

BI3/H
BI4/H
BI8/H

Object

Representation ID: 5489

Received: 24/03/2021

Respondent: CPRE West Yorkshire

We’ve not been able to visit this site (BA5/H) ourselves but it has been brought to our attention based on the concerns from local groups. In addition to our comments on SP5, we would object to this site allocation. The site BA5/H has been identified to be highly accessible to services and within sustainable transport modes, specifically Baildon train station at 800m walk away. However, the site is located adjacent to a TPO tree and an area of TPO woodland. Removing this part of the green belt which has a large potential for landscape impact, is of concern, and developing low density housing on it would be a very unsustainable outcome for the site.

In line with our comments on policy SP5, we also object to the following site allocations:

BA2/H
BA6/H

Object

Representation ID: 5490

Received: 24/03/2021

Respondent: CPRE West Yorkshire

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

SW5/H
SW6/H
SW10/H
SW18/H
SW22/H
SW33/H

In particular, site SW33/H appears to be proposed for extremely low development density, which is unsustainable in any location and not compatible with the strategy. Our position is that sites that are not suitable for policy-compliant densities should not be allocated, irrespective of whether they are brownfield, greenfield or Green Belt.

Object

Representation ID: 5491

Received: 24/03/2021

Respondent: CPRE West Yorkshire

In line with our comments on policy SP5, we object to this site allocation.

Object

Representation ID: 5492

Received: 24/03/2021

Respondent: CPRE West Yorkshire

The overall strategic outcomes of any local plan should be:
1. net reductions in greenhouse gas emissions
2. net reductions in car traffic
3. net reductions in pollution
4. net enhancement of biodiversity
5. net increase in access to green space
6. net reduction in flood risk
7. and the benefits of these outcomes should be socially and spatially equitable.

SP1A is a reiteration of NPPF’s presumption in favour of sustainable development and we see no need to comment on that.

Part B is expressing Bradford's local interpretation and
application of the presumption. Referring to our headline aspirations for all local plans, we consider that SP1B needs to be much clearer and more specific about the need to achieve high-level, net enhancements to social, environmental and economic well-being.

NPPF in fact describes a net gain approach to several considerations.

Support

Representation ID: 5493

Received: 24/03/2021

Respondent: CPRE West Yorkshire

Housing Requirement

CPRE believes in meeting genuine housing need by building the right types of homes in the right places.

In that context we are content with the proposed numerical housing requirement. We strongly support the council's proposed approach to dealing with the 35% uplift for urban centres because, for this if the uplift were added to the general requirement it could easily result in allocation of peripheral, Green Belt sites that would be poorly targeted for regeneration. The uplift is a policy intervention to boost urban centres, so it would be counterintuitive and counterproductive for it to result in more peripheral development.