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

Comment

Representation ID: 29768

Received: 25/03/2021

Respondent: Ilkley Town Council

We recognise the immense challenges associated with transitioning to a net zero carbon District however these will only get harder and more costly if the Local Plan is not ambitious in addressing these matters in detail at this stage.

Should new housing be required this must be built with the highest insulation standards to promote energy efficiency and the use of renewable energy to prevent fuel poverty as a priority and avoid the need for retrofitting at a later date.

Comment

Representation ID: 29769

Received: 25/03/2021

Respondent: Ilkley Town Council

Components of Supply - Windfall

Housing from windfall sites and development that takes place before the Plan is adopted should be removed from the total number of houses required in the Ilkley settlement.

Comment

Representation ID: 29771

Received: 25/03/2021

Respondent: Ilkley Town Council

Housing Distribution - Ilkley

Bradford is being required by central government to build a given number of new houses. Given the numbers being proposed in other settlements locally, the number of 283 houses allocated for Ilkley does not seem unreasonable. For example:
Silsden allocation 522 dwellings
Addingham allocation 163
12
Burley in Wharfedale allocation 549
Menston allocation 181
Steeton allocation 169
Bingley allocation 703
Baildon allocation 195
Shipley allocation 1189

If we accept that 283 houses are reasonable, then two further issues necessarily arise:

(a) the type of housing; and
(b) the area of land necessary.

Comment

Representation ID: 29772

Received: 25/03/2021

Respondent: Ilkley Town Council

The Employment Needs Assessment and Land Review (ENALR) (2019) – should, post pandemic, be revisited in the light of the significant changes in working patterns and the increase of home-working 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.

Object

Representation ID: 29773

Received: 25/03/2021

Respondent: Ilkley Town Council

Previously Developed Land

If the Council were to provide for the 35% uplift (around 10,000 homes) in a way that fulfils the expected urban centre focus, this would amount to a significant shift in the spatial distribution of housing towards the urban centre. By implication, this suggests that the current 50% brownfield target for the district does not reflect the total amount of brownfield land across the district, but rather that the Council has chosen to distribute development to the other levels of the settlement hierarchy in a way it considers reflects the development needs of the other settlements, but does not necessarily maximize the district-wide use of brownfield land.

Comment

Representation ID: 29774

Received: 25/03/2021

Respondent: Ilkley Town Council

If Ilkley is to be a well-balanced town in population terms it needs more housing suitable for young families, single people, people with special needs, etc.

Ilkley is a town with a high proportion of large and expensive housing, whereas a large proportion of the paid employment is in the low paid sector (retail, hospitality, care work). The housing need therefore is for modestly priced accommodation, not ‘executive homes’.

Object

Representation ID: 29775

Received: 25/03/2021

Respondent: Ilkley Town Council

In the Local Plan, Bradford specifies two projected housing densities. For sites near main transport hubs, 50 dwellings per hectare and for other sites 35 dwellings per hectare.

The housing densities proposed for the sites identified by Bradford, in the Local Plan are very low indeed and much lower than those proposed by Bradford in the Plan.

By way of illustration Ilkley is planned to have 314 dwellings on the four sites.

For example
Only IL4/H approaches 50 dwellings per hectare (at that density it could take 11 dwellings rather than the 9 planned)

IL2/H, 1.18ha is planned to take 20 dwellings. At 50 per hectare it could take 59

IL1/H 7.18ha is planned to take 130, at an astonishingly low density of 18 dwellings per hectare. At 50 per ha it could take 359

IL3/H, 7.41ha is planned to take 155 dwellings (21 per hectare) whereas it could take 370. N.B. this number comes down to 350 if 0.4ha is allocated to a park and ride carpark

Given that three of these sites are on green belt, it seems impossible to justify building at a rate as low as between 18 and 21 dwellings per ha. These densities can only imply the building of large detached houses.

Comment

Representation ID: 29776

Received: 25/03/2021

Respondent: Ilkley Town Council

In the Local Plan, Bradford specifies two projected housing densities. For sites near main transport hubs, 50 dwellings per hectare and for other sites 35 dwellings per hectare.

The housing densities proposed for the sites identified by Bradford, in the Local Plan are very low indeed and much lower than those proposed by Bradford in the Plan.

By way of illustration Ilkley is planned to have 314 dwellings on the four sites.

For example
Only IL4/H approaches 50 dwellings per hectare (at that density it could take 11 dwellings rather than the 9 planned)
IL2/H, 1.18ha is planned to take 20 dwellings. At 50 per hectare it could take 59
IL1/H 7.18ha is planned to take 130, at an astonishingly low density of 18 dwellings per hectare. At 50 per ha it could take 359
IL3/H, 7.41ha is planned to take 155 dwellings (21 per hectare) whereas it could take 370. N.B. this number comes down to 350 if 0.4ha is allocated to a park and ride carpark

Given that three of these sites are on green belt, it seems impossible to justify building at a rate as low as between 18 and 21 dwellings per ha. These densities can only imply the building of large detached houses.

Comment

Representation ID: 29777

Received: 25/03/2021

Respondent: Ilkley Town Council

The sites identified by Bradford, with two exceptions, do not seem unreasonable.

The one wholly objectionable site is IL1/H (Wheatley Grove). Site IL4/H (Stockeld Road) is also of concern as it is within the Ilkley Conservation Area and Flood Zone 2.

The only areas left are then site IL/3H, Coutances Way and IL2/H, Skipton Road east which are both in Green Belt and would need exceptional circumstances to be proved for their release.

In addition

1. Development should be at, at least 50 dwellings per ha.

2. There should be a mix of housing types and tenures (including social housing).

3. Included in the design should be green play areas, trees (and if possible allotments) etc.

3. To be in conformity with Bradford’s zero carbon policy, the dwellings must be built to the highest insulation standards with electric car charging points etc. The danger of flooding must be mitigated by the use of permeable surfaces wherever possible, rain water collection from houses, etc.

4. The site should be screened from the A65 by the planting of a shelter belt of substantial native trees (oak, ash etc.)

5. The wetland area below the site should be converted into a wetland nature reserve. This would complement the Ben Rhydding Nature Reserve on the opposite side of the A65.

Object

Representation ID: 29778

Received: 25/03/2021

Respondent: Ilkley Town Council

The Ilkley Local Area Strategy document contains inaccuracies which misrepresent the site - example, regarding the Sustainability Assessment for site IL1/H Wheatley Grove where the Site Pro Forma says ‘There are unlikely to be any significant effects, either positive or negative, on any SA Objective arising as a result of development at this site’ yet the first line of the summary of the SA assessment for the same site (IL/009) is ‘A major adverse effect is predicted on the land and buildings SA objective due to the loss of greenfield land’.

It is clear this site has not been accurately assessed and should be removed from the Preferred Options site allocations as it does not support the policies of the Local Plan or NPPF regarding exceptions for development on Green Belt.

The level of habitat, landscape character and surface water flood risk/drainage mitigation plus the need for replacement of an area of open space of high visual amenity and biodiversity and tree cover with compensatory Green Belt enhancement and a new area to replace that which would be unnecessarily destroyed in order to achieve a development with limited accessibility to local services and a need to depend on cars begs the question as to why this site has been included.

Comments are also made on the inaccuracies and misrepresentation of the site within the SA.

On traffic and transport criteria this site is unsuitable for development (see separate comments on access, walking and cycling).

The location and steep nature of the site and surrounds mean that residents may experience some social isolation - conflicts with policies DS5 and CO3.

SP14 - making great places - This is already a heavily used community green space of amenity and biodiversity value, and is too close to the Moor.