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

Object

Representation ID: 5181

Received: 24/03/2021

Respondent: Ilkley Town Council

Ilkley has declared a climate change emergency and as such should be reducing the need for travelling to town the centre, work, school, leisure facilities etc. The building proposed at IL1/H is unsuitable for building. Firstly, there is no infrastructure linking this development to the local centre. A car would be required for access by many people, children will not be able to walk or cycle to school and people with reduced mobility will certainly need to travel into Ilkley or Ben Rhydding by car. The increased of car use in this area goes against our aim of carbon reduction and to reduce air pollution caused by car travel. New housing developments are said to generate 5 - 7 additional vehicle movements per day and given that 150 dwellings are planned for this area, it is alot of increased traffic. Further problems arise access to Wheatley lane which is congested.

Object

Representation ID: 5424

Received: 24/03/2021

Respondent: Ilkley Town Council

New housing development should be to the highest possible densities (Strategic Policy SP7, “ maximise the efficient use of land by building to highest possible densities, especially near public transport hubs and sustainable transport corridors.”)

If this is done the amount of land taken from the Green Belt for housing throughout the district would significantly decrease.

The draft Local Plan does not demonstrate the ‘exceptional circumstances’ (NPPF, para 137) to justify extensive changes to Green Belt boundaries.

Object

Representation ID: 5436

Received: 24/03/2021

Respondent: Ilkley Town Council

Wheatley Grove, IL1/H is unsuitable for housing development on several grounds. Amongst others, it does not conform with TR3, Integrating Sustainable Transport and Development since it is a steep site, unsuitable for walking and cycling. It is also close to Ilkley Moor, an SSSI, and will impact wildlife and biodiversity on the moor. It therefore does not conform to EN2, Biodiversity and Geodiversity.

Object

Representation ID: 8130

Received: 24/03/2021

Respondent: Ilkley Town Council

Ilkley has declared a climate change emergency and as such should be reducing the need for travelling to town the centre, work, school, leisure facilities etc. The building proposed at IL1/H is unsuitable for building. Firstly, there is no infrastructure linking this development to the local centre. A car would be required for access by many people, children will not be able to walk or cycle to school and people with reduced mobility will certainly need to travel into Ilkley or Ben Rhydding by car. The increased of car use in this area goes against our aim of carbon reduction and to reduce air pollution caused by car travel. New housing developments are said to generate 5 - 7 additional vehicle movements per day and given that 150 dwellings are planned for this area, it is a lot of increased traffic. Further problems arise access to Wheatley lane which is congested.

Comment

Representation ID: 8979

Received: 24/03/2021

Respondent: Ilkley Town Council

Whilst there are negative issues surrounding Coutances Way IL3/H, it fulfils the requirements of SP7, Sustainable Transport. If sensitively handled it could form a suitable site for development. However, housing densities must be increased at this site, so that it can contain a range of housing suitable for different demographics. Particular care must be taken to ensure that complementary measures are taken on matters such as landscape and habitat protection. Above all, it is absolutely essential that this site is not handed over to a traditional developer to build a large number of executive-style houses at low densities.

As this land is owned by BMDC, the opportunity should be taken to show that the council can develop land in an appropriate and sensitive manner in a conspicuous location close to one of the district’s principal towns.

Object

Representation ID: 29152

Received: 25/03/2021

Respondent: Ilkley Town Council

-Agree with CPRE comments:
• Support lower housing target at 1,700 per/annum
• Government approach is to target housing within major urban centres
• We consider that additional homes should go to the Bradford City itself
• The ENALR should be revisited in light of significant changes in working patterns post pandemic - to see whether more land identified for employment in Urban areas could now be used for housing to remove the pressure to release Green Belt sites.

- The reasonable alternative is therefore to plan for that shift in spatial distribution anyway, in order to maximize the use of brownfield land across the district, and thereby to more properly meet the expectations of NPPF para 137.

-If exceptional circumstances for Green Belt release are demonstrated, then only sites that are able to be served by high frequency public transport, contribute to 15-minute neighbourhoods and are suitable for development at at least 50dpha should be released from the Green Belt.

-Sequential requirements of NPPF para 137 not fulfilled as settlement hierarchy has been applied before the para 137 tests, rather than after

-Reasonable alternative is to measure housing land requirement by land area, rather than number of dwellings, and to allocate only enough land to meet the housing requirement at 50dpha net

-Climate Emergency and road traffic reduction – target setting not enough.

-Adopt the WY 21% absolute reduction in car mileage over the period as a reasonable alternative to ensure that all policies integrate to achieve it.

Object

Representation ID: 29158

Received: 25/03/2021

Respondent: Ilkley Town Council

We support CPRE's suggested alternative wording for Policy SP4

A. The Local Plan will adopt a car-free accessibility approach to ensure that new development contributes to the strategic target of significantly 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 would 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: 29162

Received: 25/03/2021

Respondent: Ilkley Town Council

Cross-boundary approaches – concerns re development near district boundary (Old Middleton Hospital site). Without SCG there is no recognition of the impact on Ilkley’s infrastructure should development go ahead/SIL/S106

SP5 (B) Exceptional circumstance have not been met for
-IL1/H - Ben Rhydding Drive, Wheatley Grove, Ilkley
-IL2/H - Skipton Road East
-IL3/H - Coutances Way

The Local Plan should carry out the assessment detailed in NPPF para 137 before concluding that exceptional circumstances exist to justify changes to green belt boundaries.

Exceptional circumstances not demonstrated as site yields have been dictated by the developers / the SLA and the 50dph density requirement has not been applied to sites.

Exceptional circumstances not demonstrated as the approach to housing distribution has applied the settlement hierarchy first before the NPPF para 137 tests

SP5 (E) reasonable alternative:
“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.”

Comment

Representation ID: 29164

Received: 25/03/2021

Respondent: Ilkley Town Council

-5.17.1 -Insert ‘South’ before Pennine
-5.17.2 -Define Ilkley’s public administrative functions
-5.17.2 -There has been no direct bus service to Bradford for c10 years
-5.17.3 -We have been using the Ilkley Ward Profile (March 2020) data unaware of the Local Insight Profile for Ilkley (16 December 2020). Will the latter be made avaliable?
-5.17.4 -Comment re INDP Reg16 Consultation progress
-5.17.7 -Does this mean a ‘small office’ market or a small ‘office market’?
-5.17.7 -Update this to reflect the current state and impact of the Covid-19 pandemic
-5.17.9 - Insert ‘and The Grove’ after Brook Street
-5.17.15 -It is impossible to see the detail on the Interactive Policies Map. The Ben Rhydding Park and Rail Scheme in the LIP is not mentioned in this overview or shown on the map (Figure 8?) as a strategic infrastructure project although the potential for its development is mentioned in IL3/H
-5.17.12 - Provide reference for survey data
-Table 1 -‘Waking’? Typo error
-5.17.27 -Provide reference for heritage data
-5.17.31 -Provide reference for open space data
-5.17.33 -Alexandra Road health centre is in Shipley

Comment

Representation ID: 29767

Received: 25/03/2021

Respondent: Ilkley Town Council

Ilkley Town Council declared a climate emergency in December 2019 and has pledged to do everything within its power to make Ilkley carbon neutral by 2030. The Town Council requires all its decision making and policies to have regard to its Climate Emergency Declaration including the Ilkley Neighbourhood Development Plan.

In seeking to protect local Green Belt, biodiversity and Ilkley’s overstretched local infrastructure we also acknowledge the need within our local community for affordable, well designed, energy efficient, zero carbon, adaptable and accessible housing.

However, it is our opinion these aspirations do not always translate into the detail of the Local Plan especially with regard to sustainability and site allocations.