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

Object

Representation ID: 16714

Received: 24/03/2021

Respondent: Shipley Town Council

Wording additions and changes are proposed to address the following issues:

To ensure that SP1 does puts achieving zero carbon at the heart of the Local Plan;

Under SP1:B4 we want to see attention also given to reducing health inequalities.

The Local Plan must take into consideration the impact on the environment of any proposed new developments. This should be in regard to:
● Carbon emissions
● Air pollution
● Biodiversity
● Other environmental pollution including water, light, noise, odour, soil

Criteria are proposed to guide the selection of sites in the most sustainable locations.

Object

Representation ID: 16715

Received: 24/03/2021

Respondent: Shipley Town Council

Concerned by the wording of part 4 relating to optimising opportunities provided by close proximity of Leeds International Airport.

This locks in a degree of economic dependence upon a very high-carbon activity, and influences land-use by providing a supposed justification for greenfield, road-based development between the city and the airport, including the use of Green Belt land.

Encouraging the increased use of Leeds Bradford International Airport is not compatible with Bradford Council’s zero carbon ambition as low carbon aviation cannot be achieved in this plan period and in fact to reach zero carbon it is highly probable that a contraction of air travel is in fact needed to prevent catastrophic climate change.

It is vital that Bradford develops an alternative strategy that is not reliant on the airport.

Object

Representation ID: 16716

Received: 24/03/2021

Respondent: Shipley Town Council

We recommend that this section emphasises the need to plan for, and deliver, local food growing.

We recommend that SP3 B3 is re-worded as follows:
● Create new and improve existing open space, green areas, networks and corridors including the urban fringe to enhance biodiversity, food growing and recreation.

Object

Representation ID: 16717

Received: 24/03/2021

Respondent: Shipley Town Council

See comments under SP1 for sequential approach and suitability of sites.

However, as TRICS data (http://www.trics.org/system.html) demonstrate every new dwelling generates 5 -7 additional vehicle journeys a day.

To combat the climate emergency we are going to need a net reduction in car use. Therefore, we recommend the below to be added to SP4.

The Local Plan will adopt a car-free accessibility approach to ensure that new development contributes to the strategic target of reducing car use over the plan period. It will do this by locating new development such that it:
● Makes walking, cycling and public transport the most attractive and useful travel modes for day-to-day journeys, to achieve 15-minute neighbourhoods with the creation of gold-standard segregated infrastructure and low traffic neighbourhood principles;
● Ensures that the pattern of development improves accessibility and independence for all sectors of society:
● Minimises the dependence of development on any additional road capacity that could otherwise induce additional traffic;
● Maximises the use of rail and water for uses generating large freight movements.

Object

Representation ID: 16718

Received: 24/03/2021

Respondent: Shipley Town Council

The draft local plan identifies over 65 housing sites in the current Green Belt.

We do not agree that Bradford Council has justified the exceptional circumstances for building on the Green Belt on the edge of Shipley. There is underutilised land in Shipley nearer Shipley Town Centre that could be used for development. See our specific comments on the proposed housing sites for more detail.

Also analysing some of the Green Belt sites indicates net densities averaging around 26 dpha – well below the draft Plan’s policy HO2 of a minimum of 35 dpha, and even further below the 50 dpha that we consider all site allocations should be required to achieve. There is no sound rationale for releasing Green Belt land if the result will be 5,000 homes developed at non-policy compliant densities.

We also cannot see how developments on Green Belt and greenfields will lead to the biodiversity net gain as the Council sets out it wants to achieve in Policy EN2: Biodiversity.

Object

Representation ID: 16719

Received: 24/03/2021

Respondent: Shipley Town Council

Bradford will not meet its target to reach zero carbon by 2038 if it does not focus on supporting the move away from carbon intensive jobs and sectors to low carbon sectors.

The phrase “fastest growing economy” is totally at odds with the stated aim of the Council to deliver sustainable development - which is about delivering an economy that meets the needs of people now within environmental limits, and allows future generations to meet their needs.

This policy should be reworded to say:
● Bradford aims to be at the forefront of the UK's LOW CARBON economy, which will also support the social well-being of the people of Bradford

This section should also include a policy on how Bradford will use its own investments and assets to support the development of a low carbon economy – such as building socially rented houses to Passivhaus standards and supporting a huge roll out of retrofitting to improve the energy efficiency of the current housing stock and create skilled jobs.

Object

Representation ID: 16720

Received: 24/03/2021

Respondent: Shipley Town Council

Absolute traffic reduction means that all new developments must be regarded as traffic-reducing interventions. In this context the demand reduction principles set out in policy SP7(1) are crucial, and must be rigorously implemented.

We welcome many of the policy approaches outlined in SP7. The supporting text (3.71 to 3.7 28) is much clearer than the following policy SP7 itself, in explaining what the plan aims to achieve and how to implement it. We suggest these components be moved into the policy itself.

SP7 should state clearly that cycling and walking will be prioritised over motorised transport. The wording “support the shift” is too vague.

The draft plan does not include meaningful detail from Bradford’s Local Cycling and Walking Infrastructure Plans or the Bradford Cycling Strategy.

Provisions should be made for the 1/4 of households who do not own a car and for whom cycling infrastructure and support is not within their grasp.

Alternative policy wording is put forward.

Object

Representation ID: 16721

Received: 24/03/2021

Respondent: Shipley Town Council

New housing development should be based on the following principles and we would like to see all of these reflected throughout the draft plan.
- Social Equity
- Sustainable Development
- Urban Capacity
- Zero carbon Design
- Participative Process

It appears that the proposed greenfield land take in the draft Plan is approaching double what it would need to be if all greenfield development were built to the policy-compliant 50dhpa net.

This being the case, then the exceptional circumstances for Green Belt releases have not been demonstrated.

Object

Representation ID: 16722

Received: 24/03/2021

Respondent: Shipley Town Council

We are very supportive of the target of zero carbon by 2038. To ensure this we want to see elements in the plan strengthened.

Point A3 needs to be strengthened by calling for modelling by developers for all new developments to demonstrate that the proposed development is carbon neutral or carbon negative; in terms of emissions from construction, building energy use and travel resulting from the development.

This policy also needs additional wording to ensure developments are being designed to incorporate measures to adapt to climate change.

We want the following added to SP9:
The following measures shall be incorporated into all development:
Wherever possible, new buildings shall be orientated to maximise the opportunities for both natural heating and ventilation and reducing exposure to wind and other elements;
● Proposals involving both new and existing buildings shall demonstrate how they have been designed to maximise resistance and resilience to climate change, for example by including measures such as solar shading, thermal mass, heating and ventilation of the building and appropriately coloured materials in areas exposed to direct sunlight, green and brown roofs, green walls, etc;
● Use of trees and other planting, where appropriate, as part of a landscape scheme to provide shading of amenity areas, buildings and streets and to help to connect habitat, designed with native plants that are carefully selected, managed and adaptable to meet the predicted changed climatic conditions; and
● All development shall minimise the impact of surface water runoff from the development in the design of the drainage system, and where possible incorporate mitigation and resilience measures for any increases in river flooding levels as a result of climate change

Object

Representation ID: 16723

Received: 24/03/2021

Respondent: Shipley Town Council

Support intention to develop a network of on- and off-road cycle routes (TR1 A4 & A5) but we would expect to see in these objectives a re-statement of the prioritisation of cycling over motor vehicle traffic. There should be a commitment to the consideration of closing roads to vehicular traffic in favour of exclusive use by sustainable active travel modes.

A2 should more definitively commit to the use of Low Traffic Neighbourhoods ‘wherever possible’ so that the outcome is the creation of an ‘extensive’ network of LTN’s.

Section E - highways / junction ‘Efficiency’ must be for ALL road users - this section should include a statement that any highways developments would be subject to the continued prioritisation of cycling over motor vehicle traffic.

We are concerned about the impact of the Bradford-Shipley Route Improvement Scheme (TR1: E) on Shipley. It will induce increased traffic, congestion, air and noise pollution.

A number of active travel schemes in the Shipley area (see attached document) are proposed.