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

Object

Representation ID: 8181

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.

Object

Representation ID: 8183

Received: 24/03/2021

Respondent: CPRE West Yorkshire

The sites proposed for Shipley, like many other sites across the district, are proposed to be built within green belt land and at a density of around 26dpha, a figure much lower than the HO2 minimum of 35 dpha, and even more inconsistent with our position set out in policies SP4, SP5 and SP8.

Moreover, site SH4/H is proposed for land which is expected to be within a Proposed Clean Air Zone. Whilst this site allocation mentions there are potential for some positive effects for the area, such as improvement to the local economy, there are some concerns.

Sites SH5/H and SH6/H are also proposed to be, at least in part, within the Proposed Clean Air Zone and both have elements of woodland along their boundary. There is the risk of flooding at these sites too as sections of the land is within flood Zone 2. As the last buffer of land between Cottingley and Shipley, it is important to maintain this open landscape. Development on this land would result in the removal of a significant amount of woodland, which would be a major harmful impact.

Object

Representation ID: 8184

Received: 24/03/2021

Respondent: CPRE West Yorkshire

The sites proposed for Shipley, like many other sites across the district, are proposed to be built within green belt land and at a density of around 26dpha, a figure much lower than the HO2 minimum of 35 dpha, and even more inconsistent with our position set out in policies SP4, SP5 and SP8.

Moreover, site SH4/H is proposed for land which is expected to be within a Proposed Clean Air Zone. Whilst this site allocation mentions there are potential for some positive effects for the area, such as improvement to the local economy, there are some concerns.

Sites SH5/H and SH6/H are also proposed to be, at least in part, within the Proposed Clean Air Zone and both have elements of woodland along their boundary. There is the risk of flooding at these sites too as sections of the land is within flood Zone 2. As the last buffer of land between Cottingley and Shipley, it is important to maintain this open landscape. Development on this land would result in the removal of a significant amount of woodland, which would be a major harmful impact.

Object

Representation ID: 8185

Received: 24/03/2021

Respondent: CPRE West Yorkshire

The sites proposed for Shipley, like many other sites across the district, are proposed to be built within green belt land and at a density of around 26dpha, a figure much lower than the HO2 minimum of 35 dpha, and even more inconsistent with our position set out in policies SP4, SP5 and SP8.

Moreover, site SH4/H is proposed for land which is expected to be within a Proposed Clean Air Zone. Whilst this site allocation mentions there are potential for some positive effects for the area, such as improvement to the local economy, there are some concerns.

Sites SH5/H and SH6/H are also proposed to be, at least in part, within the Proposed Clean Air Zone and both have elements of woodland along their boundary. There is the risk of flooding at these sites too as sections of the land is within flood Zone 2. As the last buffer of land between Cottingley and Shipley, it is important to maintain this open landscape. Development on this land would result in the removal of a significant amount of woodland, which would be a major harmful impact.

Object

Representation ID: 30200

Received: 24/03/2021

Respondent: CPRE West Yorkshire

We do not accept that the economic growth proposals set out in policy SP6 robustly justify the allocation of Green Belt sites for employment, and therefore do not consider the exceptional circumstances have been adequately demonstrated for Green Belt change to supply employment land.

Object

Representation ID: 30201

Received: 24/03/2021

Respondent: CPRE West Yorkshire

SP5E describes an approach to compensatory improvements to the Green Belt. In line with our comments about net gain it is essential that the net effect of releasing land from the Green Belt is a measurable net benefit to the function of the Green Belt. We suggest a rewording of SP5 along the following lines: Where land is released from the Green Belt for development the Council will identify compensatory improvements to the environment quality and accessibility of remaining Green Belt that produce a measurable net improvement to the beneficial use of the Green Belt in the same locality as the Green Belts release. This may include inclusion of additional land in the Green Belt in those localities, and/or Local Green Space Designations to protect green spaces within settlements.

Object

Representation ID: 30206

Received: 24/03/2021

Respondent: CPRE West Yorkshire

Components of Supply

The components of supply identified in SP8D effectively describe a sequential approach to supply and the two broad locations for growth. We infer from this that land for the broad locations would be removed from the Green Belt but not allocated. It is difficult to compare this information and the information on the policies map with the list of Green Belt release sites identified in policy SP5, considering that a significant proportion have the total housing supply identified to come from Green Belt is located within the broad locations for growth. It is also unclear whether those broad locations for growth are intended to supply further housing numbers beyond the plan period.

It is of great concern that we cannot see from the draft Plan the proposed what the extent of land-take in the broad locations for growth within and beyond the plan period is likely to be.

Object

Representation ID: 30207

Received: 24/03/2021

Respondent: CPRE West Yorkshire

Spatial Distribution
We are not disputing that settlements at all levels of the hierarchy should be enabled to have a quantity and type of development that meets their needs. Furthermore, if some of those settlements are better served than others by public transport, and contain some sites that are more suited than others to implementing 15-minute neighbourhoods, then this does create a justification for adjusting the distribution between settlements to facilitate those sites being developed.

In our view the important first step towards redressing this problem is to measure housing land requirements by land area, rather than by the indicative capacities that are derived from market preference. Calculating land requirements by area in this way is an important, reasonable alternative to the approach currently taken by policy SP8.

Object

Representation ID: 30208

Received: 24/03/2021

Respondent: CPRE West Yorkshire

Neighbourhood Plans

It would be helpful to know which of the settlements in Schedule 1 have prepared or are preparing neighbourhood plans. SP8F implies that neighbourhood plans could provide for additional housing numbers above and beyond those in Schedule 1, but it appears that the distribution in Schedule 1 has been derived from the availability of known sites and their indicative capacity. In many cases we know that communities are objecting not to the numerical target itself but to specific site allocations. Therefore, it is important that SP8F is worded to empower neighbourhood plans to specify the type and density of housing, such that meeting or exceeding the numerical target but on fewer sites, or on more smaller sites, is an acceptable role for the neighbourhood plan.

Object

Representation ID: 30209

Received: 24/03/2021

Respondent: CPRE West Yorkshire

Previously Developed Land

Based on the quoted percentages within SP8H and the settlement targets, it appears that 14,607 new dwellings will be on greenfield land across the district, which is 48% of the total requirement but 53% of allocations, by number of dwellings. Due to the tightly-drawn Green Belt a high proportion of the greenfield allocations will come from the Green Belt.
Any policy compliant green belt site should be built to at last 50dph - we would expect 14,607 dwellings to require a further 365 ha of greenfield land.

We have so far looked in detail at 25 greenfield sites in the draft Plan, of which the majority are to come from Green Belt. These 25 sites have a total area of 160 ha, and a total indicative capacity of 3,640 dwellings – a gross density of 23dpha – which suggests a net density of around 29dhpa. If this pattern were to prevail across all greenfield sites, in the plan, then 14,607 homes would require 635 ha.

Consequently, if the brownfield sites achieve 50dpha, but the greenfield sites are developed at the densities which appear to be prevailing in the allocations, then by land area the Plan may only be achieving 37% of housing on brownfield land. This leads us to conclude that the Plan is not making the most effective use of land, and is not in conformity with NPPF para 137. Indeed, it suggests that the Green Belt land-take may be almost double what it would need to be if density expectations were properly applied.

Consequently, even if the district-wide brownfield rate remained at 50%, 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 other words: · roughly half of all the proposed greenfield land allocation is a product of low densities, not of meeting development need; · the majority of Green Belt housing allocations are proposed to be developed well below the densities required by the Plan’s policies relating to density.
This being the case, then the exceptional circumstances for Green Belt releases have not been demonstrated, because the resulting allocations will be profligate in their use of land and will directly fail to implement key sustainability policies in the Plan. And we cannot see how the proposed site allocations, taken as a whole, will be suitable for the implementation of key policies in the Plan, especially SP7 on sustainable travel and HO2 on density.