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

Support

Representation ID: 28993

Received: 24/03/2021

Respondent: National Trust

We support part A of policy SP5 which states that “the extent of Green Belt within the District is identified on the Policies Map and has a valuable role in supporting urban regeneration and transformation, keeping settlement separate, concentrating development and conserving the countryside.”

We note that the Green Belt boundary surrounding East Riddlesden Hall has been maintained and we strongly support the retention of Green Belt within this area which assists in keeping settlements separate, conserves the countryside and in keeping land permanently open.

Comment

Representation ID: 28994

Received: 24/03/2021

Respondent: National Trust

As an observation we consider Part E could helpfully be subdivided to make a distinction between new development sites which would be required to provide compensatory improvements in the green belt and other proposals for use of land within green belt which would be supported only where it is consistent with national policy, so that it is not muddled.

As a general principle, we consider compensatory improvements should be identified for the development sites identified to be released in order to demonstrate that the impact of removing land from green belt can be offset. Planning Practice Guidance makes clear there may be scope for a range of measures informed by supporting evidence of landscape, biodiversity or recreational needs and opportunities including those set out in local strategies. We consider that the Plan should identify specific measures that will be delivered.

Support

Representation ID: 28995

Received: 24/03/2021

Respondent: National Trust

We support part A of policy SP10 which states that “the District’s Strategic Green and Blue Infrastructure (GI) network and assets, as defined in this policy and identified on the Inset Map (Appendix 14), will be protected, maintained, and where appropriate, enhanced.”

We note that land at East Riddlesden Hall and the surrounding land is included as part of the GI network and we support the inclusion of this land, which provides a range of multi-functional spaces, routes and assets for recreation, leisure and biodiversity.

We also support part B of this policy which requires development proposals to make a positive contribution to the provision of GI. In particular providing good GI links and recognising the importance for access to green space so that people have access to nature near to where they live together with protecting, enhancing and securing net gains in biodiversity.

Support

Representation ID: 28996

Received: 24/03/2021

Respondent: National Trust

In a similar way to the comments expressed above with regard to GI, we support the policy which supports creating healthy places (SP15). The benefits of improving green infrastructure and access to it and the recognition that it can support healthy lifestyles is an important role that should form an integral aspect of good design particularly in new development proposals.

Object

Representation ID: 28997

Received: 24/03/2021

Respondent: National Trust

We are concerned that National Trust land has been incorrectly identified as suitable for development under site ref KY14/H. This site is not available for development and there is no intention to do so. It needs to be deleted from the Plan. See relevant comments under section 5 below.

Comment

Representation ID: 28998

Received: 24/03/2021

Respondent: National Trust

We are supportive in principle of policies which seek to improve green infrastructure across the district, and we note that further work is underway to finalise the framing of this policy. As the proposed policy is dependent on the publication of national standards it may need to be adapted / revised as these are introduced to ensure consistency at a national level.

Comment

Representation ID: 28999

Received: 24/03/2021

Respondent: National Trust

NT is generally supportive of this policy, in particular “to proactively preserve, protect and enhance the character, appearance, archaeological and historic value and significance of the District’s designated and undesignated heritage assets and their settings.” We are also supportive of point C to “require that all proposals for development conserve and where appropriate, enhance the heritage significance and setting of Bradford’s heritage assets (…).”

However, we are concerned that EN4 does not provide sufficient guidance that heritage decisions will be taken in accordance with national policy contained in the NPPF. Whilst the policy is sufficiently proactive and contains a positive suite of policies for the enhancement of heritage assets in the district, we consider the policy should contain direction on how harm to the significance of heritage assets will be assessed by the Council.

Comment

Representation ID: 29000

Received: 24/03/2021

Respondent: National Trust

It is noted that land to the south east of the East Riddlesden Hall estate is designated as green belt and is also now to be allocated as part of the newly proposed ‘Countryside Development’ policy (EN6). The NT own this land adjacent to the East Riddlesden Hall estate up to the river (Land ownership plan provided). It is recognised that this is a new policy which defines the area designated as countryside and sets out the approach to managing development in this designated area, which restricts development to certain appropriate countryside compatible uses.

Object

Representation ID: 29001

Received: 24/03/2021

Respondent: National Trust

Within NT ownership, it is noted that the majority of the central part of the East Riddlesden Hall estate is designated as open space, sport and recreation (parks & gardens), excluding land adjacent to the car park. The two cricket grounds within wider NT ownership are also designated as such.

Whilst we have no objection in principle to the open space and recreation designation we are concerned that the totality of the existing buildings East Riddlesden Hall and its car park are included as ’open space’ and we are not convinced this designation is entirely appropriate across the whole National Trust property. Whilst there is open space and gardens within it, the function of this important historic place is as a national trust visitor property, which includes the Hall itself and the established weddings venue within the barn and its car park. We believe the designation should be amended to remove ‘open space sport and recreation’ across the core of visitor facilities here.

Support

Representation ID: 29002

Received: 24/03/2021

Respondent: National Trust

We generally support point A of this policy which states that “land identified as open space, as defined on the Policies Map, will be protected from development.” However, as described above, we are keen to ensure that only specific areas of open space are designated to ensure that this policy is appropriate.