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

Object

Representation ID: 1902

Received: 17/03/2021

Respondent: Burley Parish Council

The preferred plan period runs for 17 years (2020-2038) as opposed to the normal 15 year plan, extending forecast methods used to inform the plan by an extra 5 years. We would therefore suggest that the Local Plan’s progress is scheduled for review no later than 5 years before the plan period ends.

BPC also believe that it is important to review the Local Plan after the 2021 census data is released in 2022. The census will contain the latest demographic profiles, commute data etc. which may reveal something significant about housing and jobs throughout the District.

Object

Representation ID: 1903

Received: 17/03/2021

Respondent: Burley Parish Council

A. There is a disconnect between housing and infrastructure delivery. Bradford’s lack of a coherent transport strategy indicates that the Local Plan does not conform to NPPF sustainability policy [s2 7-14].

B. Ref B3 and 3.2.11: we agree this is an important issue but would question whether any progress will be made. Other authorities e.g. Leeds, Manchester and Nottingham have faced the same issue but put in place concrete plans to address them.

Ref B4 aligns with Bradford’s January 2019 declaration of a climate emergency and is a good policy statement but question whether Bradford’s actions meet this aspiration e.g in their attitude toward Leeds Bradford Airport which shows no consideration for Wharfedale residents.

Ref 5b; 1.2.9: we agree with the statements - but do not believe that in practice the allocation of brownfield and non-green belt land is being prioritised first.

Object

Representation ID: 1904

Received: 17/03/2021

Respondent: Burley Parish Council

A. BPC’s view on sustainability is expressed in Q2.
B. B8 contradicts BDMC’s support for LBA’s expansion plans.

Object

Representation ID: 1905

Received: 17/03/2021

Respondent: Burley Parish Council

3.3.9 We are aware that the demographics of each of the Local Growth centres are different and with respect to affordable housing each area has a very different affordability ratio. Burley-in-Wharfedale has the highest affordability ratio of all and we are concerned that little truly affordable housing has been delivered locally. We are concerned that developers can make affordable home payment contributions in lieu of delivery of affordable housing provision on site which undermines the purpose of Core Strategy HO5 and 3.3.9. Why is this mitigation required at any site across the District and will you commit to ending this practice?

We would also like to understand what employment opportunities BDMC believe exist within Burley-in-Wharfedale that would support the employment assertion in 3.3.9?

Object

Representation ID: 1906

Received: 17/03/2021

Respondent: Burley Parish Council

3.4.1; 3.4.2 - Please see Q2 for BPC’s comment on brownfield delivery. BPC strongly supports BDMC’s decision not to adopt the 35% urban centre uplift proposed by government as this is most likely to be delivered from Green Belt due to the stated non-viability of brownfield land.

Object

Representation ID: 1907

Received: 17/03/2021

Respondent: Burley Parish Council

3.5.3 BPC would like to understand BDMC’s definition of “exceptional circumstances” in the context of the NPPF. Whilst we accept that some elements of brownfield may be unviable, we find it hard to understand why land that would support the delivery of a significant number of homes still remains unviable 16 years after identification.

3.5.4 We would like to alert BDMC to the unoccupied housing which could contribute to the housing allocation figures and which throw a completely different perspective on where housing and regeneration efforts should be directed.

3.5.13 would not contribute to the District’s employment needs given 3.31

Object

Representation ID: 1908

Received: 17/03/2021

Respondent: Burley Parish Council

3.6.1 Statistics in SNPP clearly shows that across the plan period, the number of people in lower age groups is a shrinking not a growing proportion of the population.

3.6.4; 3.6.8: there is a need to ensure that through a strategy for inward investment, employment needs align with the District’s strengths by re-deploying and retraining workers so the they can contribute to the demands of the green economy.

3.6.9 The release of green belt for housing away from these areas is contrary to the need for homes to be localised close to centre of employment to reduce the reliance on the car.

3.6.12; 3.6.13: Future employment growth should be calculated using outcomes supported by data rather than to simply adopt an approach that factors none of these issues into account.

Object

Representation ID: 1909

Received: 17/03/2021

Respondent: Burley Parish Council

3.7.4 A reasonable policy but fails to solve the need to travel across the District.

3.7.5 is a good strategy but relates to regional rather than district travel, whereas the District’s travel infrastructure should be the focus and priority of transport policy.

3.7.12 In the absence of a defined transport strategy without a budget or timetable for delivery, it is difficult to see how BDMC can respond to the ‘rapid change’ required in the NPPF.

Whilst rail connectivity is reasonable across the District, timetabling is an issue for some shift workers. Particularly those in ‘transport poverty’.

When do BDMC anticipate that Bradford Transport Strategy 2040 will be fully documented and funded for public consideration?

Object

Representation ID: 1910

Received: 17/03/2021

Respondent: Burley Parish Council

See answer at Q6.

3.8.45 Please provide the evidence on which this statement is based.

3.8.50 The issue here is not one of affordability but of income and social housing. Affordable social housing needs to be delivered at a very low starting price.

Whilst BPC accept that it is inevitable that some housing need has to be met from green belt, our previous comments about housing viability in Q5 remain. In this section the housing allocation from Burley is 326 units of 625 houses in the Local Plan.
Why could BDMC not consider an affordable housing initiative as in Manchester?

Object

Representation ID: 1911

Received: 17/03/2021

Respondent: Burley Parish Council

BPC would prefer to see mandatory delivery of efficient carbon neutral housing, with BDMC taking the lead role in this initiative.