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

Support

Representation ID: 5494

Received: 24/03/2021

Respondent: CPRE West Yorkshire

We warmly welcome and support many aspects of this policy, which is truly forward-looking in its intent for a 21st century, sustainable pattern of transport.

In SP7A and B, we are unclear as to the plan’s role in supporting these rail and mass transit improvements. Conversely it is unclear to what extent the locational sustainability of the plan’s spatial strategy is contingent on the measures in A and B which may or may not be
forthcoming within the plan period.

Given the need for Bradford to achieve net-zero carbon by the end of the plan period, any measures that are to contribute to carbon reduction must be able to take effect during the plan period. If they will not take effect until towards the end of or beyond the planned period, then they are legitimate measures to ensure that development post 2038 is zero carbon; but development that takes place before 2038 must measurably contribute to zero
carbon in the absence of these measures. This needs to be clarified.

The four principles of sustainable transport set out in SP7C are very important and we give them our full support. It is very encouraging to see a local plan policy taking a robust and ambitious approach to demand reduction through the location of development, and to
transforming travel choices and patterns through reallocation of road space and reengineering of streets.
The supporting text for this chapter (3.71 to 3.7 28) is in fact much clearer than the policy itself in explaining what the plan aims to achieve and how to implement it. Indeed, we would suggest these components be moved into the policy itself.

Object

Representation ID: 5495

Received: 24/03/2021

Respondent: CPRE West Yorkshire

Please see attached document with comments.

Object

Representation ID: 5496

Received: 24/03/2021

Respondent: CPRE West Yorkshire

Para 3.5.27 comments that the government intends the 35% uplift for large urban areas to be targeted at urban centres and regeneration, not at generalized housing supply. This is a logical approach which we would support. However, this must be taken to mean that urban centre areas do in fact contain sites that the council anticipate could be brought forward for development to meet the 35% uplift; and if this is the case then the correct application of the locational policy described in SP4 would prioritise this urban land first. So it is unclear how the proposed scale of Green Belt change is needed to support the proposed housing requirement if a further 35% (10,000 dwellings) could be subsequently found within urban central areas. We infer from this that there are sufficient inner urban sites to accommodate the uplift, but that adding in the uplift would constitute a significant change to the distribution of new development such that a much larger share of the total goes into urban Bradford.

Furthermore, paragraph 3.5.6 states that the assessment of non-Green Belt land capacity takes into consideration density levels compliant with policy H02. However, our own analysis of proposed Green Belt sites indicates net densities averaging around 26 dpha – well below the HO2 minimum of 35 dpha, and even further below the 50 dpha that we consider all site allocations should be required to achieve. There is no sound rationale for releasing Green Belt land if the result will be 5,000 homes developed at non-policy compliant densities.

Since we do not accept that the strategic case for exceptional circumstances to allocate land from the Green Belt has been properly justified, then we must object to all the proposed site allocations listed in the policy.

In relation to sites NE22/E and NE23/E, we would refer you to our response to planning application 19/02504 for the Esholt site which sets out our concerns about the current proposals but recognises the need to re-use the previously developed site.

The alternatives considered at 3.5.30, as with other aspects of the Plan, do not in fact present the consideration of reasonable alternatives. They describe a different approach to how the policy is laid out, in particular by excluding sites from the policy listing, but no alternative approach is offered either for increasing the proportion of new development directed towards urban brownfield sites; or for further increases in residential and employment density as a way to reduce the amount of Green Belt land required.

Object

Representation ID: 5497

Received: 24/03/2021

Respondent: CPRE West Yorkshire

We strongly support paras 3.4.7 and 3.4.8, which point to 15 minute neighbourhoods and an aspiration not to eliminate the car, but to reduce its use.

It is essential that the Local Plan does everything it possibly can to facilitate reductions in car mileage. It should do so principally through the location of new development, the development expectations in each of those locations, and the transport investments proposed.

New development must be located and planned in such a way as to facilitate net reduction in car use in the host settlement. This is likely to depend on significantly greater concentration of new development within areas that are capable of being 15 minute neighbourhoods, and significantly more mixed-use rather than single-use site allocations.

SP4(A) is essentially a reiteration of government policy and the settlement hierarchy. We are concerned that the phrase ‘not have high environmental value’ is too subjective. This is because there may be sites which are currently not of high environmental value, but which have strong potential to become so, for example through being beneficiaries of biodiversity net gain measures or significant urban tree planting.

Similarly, we would expect more specific requirements for examining the sustainability of greenfield sites within settlements.

We are concerned that the phrase ‘subject to the above’ implies that the application of the sequence identified in part A of the policy takes precedence over the outcomes identified in part B of the policy

We are also concerned that the intended outcomes in SP4B - whilst referring to an accessibility orientated approach - do not clearly consider the accessibility needs of different people for example, by age, gender or ability as required in NPPF para 108.

We have provided below a suggested alternative wording for policy SP4 to address the concerns we have raised here.

Policy SP4: Location of Development
A. The Local Plan will adopt a car-free accessibility approach to ensure that new development contributes to the strategic target of reducing car use over the plan period. It will do this by locating new development such that it:
1. Makes walking, cycling and public transport the most attractive and useful travel modes for day-to-day journeys, to achieve 15-minute neighbourhoods;
2. Ensures that the pattern of development improves accessibility and independence for all sectors of society;
3. Takes every possible opportunity to create and enhance green corridors for nature, climate response and active travel;
4. Minimises the dependence of development on any additional road capacity that could otherwise induce additional traffic;
5. Maximises the use of rail and water for uses generating large freight movements.
B. Having identified how to maximize car-free accessibility, the Local Plan will then maximize the efficient use of land, by allocating sites that:
1. are compatible with the settlement hierarchy;
2. give first priority to the re-use of brownfield and under-utilised land within settlements, and second priority to greenfield sites within settlements, while ensuring that development of those does not harm environmental assets or public space;
3. are suitable for development at a minimum of 50 dwellings per hectare net.
C. Where there are insufficient sites within settlements, land will be identified for release from the Green Belt adjacent to settlement boundaries, as set out in policy SP5, so long as those sites fulfil the three criteria in SP4 A and B above.

Object

Representation ID: 5498

Received: 24/03/2021

Respondent: CPRE West Yorkshire

The hierarchy of settlements proposed here appears to be logical insofar as it is principally informed by the size, level of services and relative accessibility and connectivity of each tier of settlements.

The text for each tier of settlement is broadly similar, and this leads to the problem that it is difficult to discern how the policy might lead to different decisions about land allocations or the development expectations for that land in different tiers.

SP3 could be greatly simplified by identifying the levels of the hierarchy, but then saying that in each level of the hierarchy the allocation and development of land and buildings would seek to enhance the following considerations: · the capacity of the settlement to accommodate development; · the character of the place and neighbourhoods within it; · high standards of design of buildings and the public realm; · connectivity and maximising opportunities for take-up of sustainable and active travel modes; enhancing the quantity and quality of green infrastructure; · and enhancing the vitality of the place as a whole, and neighbourhoods within it. There is also a lack of a vision for the future of Bradford's rural areas. Currently the only concession to rural areas in the settlement hierarchy is through supporting broadband and live work and home working - neither of which are exclusively rural considerations.

Object

Representation ID: 5499

Received: 24/03/2021

Respondent: CPRE West Yorkshire

The policy contains a significant internal contradiction: (4) makes the airport a spatial priority, but dependence on the airport as an economic driver is very likely to undermine moves towards a green economy and the low carbon future, as envisaged by (8). Further, there is the risk that identifying the airport as a spatial priority locks in further road based economic development at relatively low employment densities.
The only alternatives to the spatial strategy presented are whether the policies should be more or less comprehensive and more or less specific in their scope, but there is no consideration of an alternative strategy. In our view an alternative that should be fully considered is for the airport not to be a spatial priority and to consider the extent to which that would enable the other objectives of the plan to be better implemented.
Despite the increased proportion of housing growth within the Regional City compared to the adopted Core Strategy the proportion of new development being directed to brownfield sites remains at 50%. Considering the significantly increased emphasis given to making effective use of land in NPPF2019 compared to NPPF2012 (against which the adopted Cost Strategy was assessed), it would be reasonable to expect the percentage of development on brownfield land to have increased, and it is unclear why this is not the case.
It is important to consider whether the achievement of the development expectations set out in SP2B (7) to (12) would be more effectively achieved with a greater focus on brownfield sites, and this has not been adequately evidenced. We would therefore contend that an alternative strategy of pursuing a significantly higher concentration of development onto brownfield sites has not been fully tested.

Object

Representation ID: 8137

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

Object

Representation ID: 8138

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

Object

Representation ID: 8139

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

Object

Representation ID: 8140

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