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

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

Consultation Question 2

Representation ID: 29806

Received: 23/03/2021

Respondent: Addingham Parish Council

Representation Summary:

The Parish Council welcomes the clarification of a number of strategic policies in the Local Plan, and wholly supports policies for sustainable growth and development in the district which prioritise the use of brown field sites and which work towards the regeneration of key areas.
The Council is particularly pleased to note the increased emphasis on strategies designed to achieve net zero carbon emissions by means of promoting greener lifestyles and practices, and recognising the value of green infrastructure and open spaces.

Support

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

Consultation Question Q10

Representation ID: 29807

Received: 23/03/2021

Respondent: Addingham Parish Council

Representation Summary:

The Parish Council welcomes the clarification of a number of strategic policies in the Local Plan, and wholly supports policies for sustainable growth and development in the district which prioritise the use of brown field sites and which work towards the regeneration of key areas.
The Council is particularly pleased to note the increased emphasis on strategies designed to achieve net zero carbon emissions by means of promoting greener lifestyles and practices, and recognising the value of green infrastructure and open spaces.

Support

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

Consultation Question 11

Representation ID: 29808

Received: 23/03/2021

Respondent: Addingham Parish Council

Representation Summary:

The Parish Council welcomes the clarification of a number of strategic policies in the Local Plan, and wholly supports policies for sustainable growth and development in the district which prioritise the use of brown field sites and which work towards the regeneration of key areas.
The Council is particularly pleased to note the increased emphasis on strategies designed to achieve net zero carbon emissions by means of promoting greener lifestyles and practices, and recognising the value of green infrastructure and open spaces.

Comment

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

Consultation Question 116

Representation ID: 29809

Received: 23/03/2021

Respondent: Addingham Parish Council

Representation Summary:

For Addingham, the Council welcomes the Plan’s recognition of the value of the Green Belt in the area, noting particularly the sites to the east of the main settlement between Addingham and Ilkley. These policies are very much in line with the Addingham Neighbourhood Development Plan, made in 2020, and forming part of the statutory framework guiding this review of the Local Plan as far as it relates to proposed developments in the Addingham area.

Comment

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

Consultation Question 116

Representation ID: 29810

Received: 23/03/2021

Respondent: Addingham Parish Council

Representation Summary:

The Parish Council would emphasise the importance of Addingham’s environment as a material planning consideration in the development of the new Local Plan. The Council would particularly draw your attention to the high quality of the village’s surrounding landscape, as highlighted in our adopted Neighbourhood Plan, which, in this regard, is evidenced by the Landscape Survey commissioned in 2018 by the Parish Council, and also by your own statutory Conservation Area Assessments carried out in February 2004. This key issue is also fully-detailed within the Civic Society’s separate consultation response, which the Parish Council supports.
Addingham is unique and distinct in the local area, compared with nearby larger and major urban settlements, in its location within two Natural Character Areas with special significance for the habitats of wildlife, such as curlews, and their associated foraging zones (internationally designated South & North Pennine Moors Special Protection Areas/Special Areas of Conservation and their protection/foraging zones, which overlap in Addingham, and Local Wildlife Sites in the countryside to the south of the village). The relationship between the landscape and the countryside immediately around and feeding into the village, by way of its green open spaces and footpath network, gives the settlement its particular value and weights the arguments towards continued and enhanced protections for the majority of Addingham’s Green Belt.

Object

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

Consultation Question 116

Representation ID: 29811

Received: 23/03/2021

Respondent: Addingham Parish Council

Representation Summary:

The draft Plan seeks to align the Core Strategy with a settlement hierarchy “which ensures that development quantums reflect the role and function of settlements, and their accessibility to jobs, services and public transport.” (para. 3.8.32)

The Parish Council welcomes this overall aim for the Plan’s Local Area strategy for Addingham, and also supports the objectives for its key elements.

However, the Council does not recognise the presumption that this particular area should contain 8 new housing sites in order to meet these objectives. The Council notes that within the Plan’s settlement hierarchy Addingham is categorised as a local service centre, due to attract a reduced scale of growth compared with urban areas. As a local service centre, not a principal town, any development should reflect its designation.

The Parish Council would recommend a review of the Local Area strategy, to base it on properly evidenced and updated data and to bring it into line with the settlement hierarchy, with a view to reinstating the relative position of Addingham within the hierarchy, as a local service centre, attracting a lower proportion of the district-wide housing growth target provision.

Object

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

Consultation Question 9

Representation ID: 29812

Received: 23/03/2021

Respondent: Addingham Parish Council

Representation Summary:

Housing Distribution - Addingham

It is unclear how the distribution strategy set out in the draft Plan is applied, as it seems to result in a relatively high housing target for Addingham, as opposed to the targets set, proportionate to the relative size of the local populations, for nearby principal towns, such as Ilkley, and local growth centres.

In responding to the Partial Review of the Core Strategy in 2019, the Parish Council welcomed the reduction in the housing target number for Addingham from 200 new houses to 75 new houses during the Plan period, and supported policies aiming to ensure that any green belt land required for the purpose should be released only in sustainable locations. Clearly, with the higher target reintroduced, it is considerably more difficult for this objective to be achieved.

As discussed in the draft Plan, development in Addingham is heavily constrained by Green Belt (para. 5.15.23), has more limited employment opportunities which might give rise to growth requirements, and, compared with nearby towns, is a less sustainable location, where the supply of potential development land which would not lead to adverse environmental impacts is limited.

Local service centres, as defined in the Plan, are expected to take “a reduced scale of growth, compared with urban areas” (para.3.3.11) because they are less sustainable locations for new housing development. The reduction in Addingham’s housing target in the Partial Review was justified on the basis of employment led scenarios designed to align housing needs with economic growth (para. 3.8.5); on this basis, fewer new houses were required in Addingham as it is a less sustainable location with limited employment opportunities. The new draft Plan’s spatial distribution growth does not adequately explain, except by means of unsubstantiated generalised narrative statement, why this conclusion has now been reversed for this particular local service centre. The Parish Council would recommend that the scenarios used to identify forecast housing requirements need to be updated urgently if the Plan’s spatial growth strategies are to be justified and properly evidenced; data shortly to become available following the Census 2021 should be taken into account to support these updated analyses to ensure more accurate and appropriate application of the Plan’s policies.
Overall, the Parish Council is concerned that the draft Plan simply does not adequately address the overall housing needs of the Bradford City region as a whole. In particular, it ignores the needs of a relatively young city, one where there is now clearly a need for more affordable and sustainable housing sites to be developed within the main urban areas, especially to the South. Also, much of Bradford’s land is now “brownfield and post-industrial”, and thus is ideal for developing more affordable housing, as part of a wider programme of urban regeneration.

Object

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

Consultation Question 116

Representation ID: 29813

Received: 23/03/2021

Respondent: Addingham Parish Council

Representation Summary:

Furthermore, in directing a higher target for new housing than is justified to Addingham, a local service centre, the new draft Plan does not adequately take into account the lack of facilities, services and infrastructure in the settlement:

-Unlike nearby towns, such as Burley and Ilkley (whose housing targets have been reduced from the targets initially set, based on the 2014 housing needs assessment), there is no railway link into the village.
-The safe walking and cycling routes mentioned in the Plan, such as the Wharfedale Greenway, are at best a very long-term future aspiration for Addingham, given the logistical and engineering issues involved, and the scale of public funding which would be required.
-The settlement is ill-served by the local road network passing through the village, where the main through routes are severely and dangerously congested, often taking heavy vehicles along narrow residential streets.
-The settlement has few viable commercial or organised leisure facilities for the general public, and there is very little parking provision for residents and visitors alike.
-The village’s local primary school is well-regarded and serves the current population well, but the local secondary school, based in Ilkley, does not have capacity to offer places in sufficient number to meet the demands of an increased influx of new Addingham families on the outskirts of the catchment area.
-After heavy rains, the centre of the village is prone to severe groundwater flooding and Town Beck, which runs through the village, frequently overtops its banks. Developing the outer greenfield areas of the village, which help in water absorption upstream, increases these flooding risks, further exposing existing properties, especially in the Conservation Area of the village, to flooding. These risks will only increase over the period covered by the Plan, as climate change takes more effect.
-There is limited scope for commercial development in the village with only one small food store. Population growth, arising as a result of the implementation of these housing allocations, would therefore contravene policies for sustainable transport development as it would lead to a greater use of cars to access shops in Ilkley, Skipton, Silsden and Keighley.

Comment

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

Consultation Question 5

Representation ID: 29814

Received: 23/03/2021

Respondent: Addingham Parish Council

Representation Summary:

The Parish Council supports the Plan’s strategic policy SP4, which prioritises the use of previously-developed sites and sustainable green field opportunities in local service centres ahead of Green Belt sites. Our Neighbourhood Plan policy on housing development supports the use of small infill sites, particularly those which have been previously developed but only if the land is not of high environmental value. Given the general comments made above in relation to the high landscape quality of the setting, lying within two Natural Character Areas, the Green Belt sites proposed in the Local Plan are unsuitable for housing development, because the high environmental value of the land excludes them from consideration. The Local Plan’s draft policies are also not consistent with the Neighbourhood Plan’s policies as regards the proposed allocation of relatively large sites for housing.
The Parish Council has taken advice from planning consultants appointed by the local council sector, and understands that policies in an approved plan, including a Neighbourhood Plan, “trump those contained in [a] draft one (including an emerging Local Plan)”. The Neighbourhood Plan’s policies are therefore to be given full weight in the proposal of sites to be allocated in the new draft Local Plan. Since the Neighbourhood Plan’s policies clearly indicate that these particular preferred options are not appropriate, they should immediately fail.

Object

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

Consultation Question 116

Representation ID: 29815

Received: 23/03/2021

Respondent: Addingham Parish Council

Representation Summary:

The Council also notes the Plan’s recognition that Addingham is heavily constrained by Green Belt with limited deliverable brownfield and non-Green Belt growth options available or identified (para.5.15.23). The draft Plan suggests that in these circumstances, housing growth should be delivered through a mix of committed sites that are either under construction or which have planning permission but have not yet started, as well as sites to be allocated in the Local Plan. The draft Plan is only able to identify 2 small sites which have been previously developed, one of which is of high environmental value for biodiversity, and one greenfield site within the settlement.
This leaves by far the major proportion of the targeted housing allocation proposed for sites which could only be made available as a result of Green Belt releases.

Not only is this not consistent with our adopted Neighbourhood Plan, it is clearly inconsistent with the draft Plan’s strategic policy as well. To accord with the government’s planning guidance in NPPF, Green Belt should only be released if this is justified by exceptional circumstances. As the draft Plan stands, policies SP5 and SP8 do not adequately explain or quantify any exceptional circumstances, other than by subjective narrative statement, to justify these releases in this location, especially given the comments made above (Q.116) in relation to the distribution strategy.
Where evidence is provided, it would seem that the development of Green Belt sites in this settlement area is not consistent with local housing need analysis, as this seems to suggest requirements for affordable housing and housing suitable for an older demographic; the release of relatively large new-build greenfield sites will favour the provision of commercial family-sized units.

Addingham’s adopted Neighbourhood Plan reflects the views of the local electorate, with fully 94% voting in its favour in the referendum held in 2019. In terms of new housing development, the Neighbourhood Plan policies clearly recognise the importance of the village’s protected status as a Conservation Area, in which its setting, encircled by and containing its Green Belt and open spaces, contributes substantially to the quality of the local area’s landscape and views. Throughout the period of the Neighbourhood Plan’s development, residents overwhelmingly favoured the use of brownfield sites and small infill sites as opposed to the use of larger sites, especially those involving release of Green Belt.

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