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

Object

Representation ID: 16724

Received: 24/03/2021

Respondent: Shipley Town Council

We welcome recognition of the need to include environmental considerations in all transport plans. However, the aims in this policy should be overarching requirements in all policies rather than being considered solely as a separate policy.

We are concerned that the aims of this policy contradict a number of the other transport policies. e.g. in relation to TR1, the Shipley-Bradford road improvement scheme (TR1: E) will encourage more traffic, and will worsen already existing environmental problems such as carbon emissions, air and noise pollution.

Modelling needs to be carried out to assess what the likely increase of carbon emission will be from any new transport infrastructure projects to ensure they are compatible with Bradford Council’s aim to get to zero carbon emissions by 2038.

Object

Representation ID: 16725

Received: 24/03/2021

Respondent: Shipley Town Council

We support the idea in the discussion (4.8.2) of a hierarchy of development favouring ‘zero-car’ developments and welcome the designation of developments which barely reduce vehicle use as ‘unsustainable’. However, in Policy TR3 itself there is no reference to this hierarchy.

The policy is too open ended. Instead, developers should be required to demonstrate how they have chosen to prioritise cycling/walking and public transport over car-use in their transport statements. LTN principles should be the default expectation in major developments so that, for example, it is easier, more convenient or quicker to move around on foot or by cycle than by car.

Looking at the specific example of the planned development of green belt on Bankfield/Branksome area (SH5/H & SH6/H) and SH4/H (Glenview Drive), there appears to be a significant contradiction in developing these sites that have very poor active travel connectivity, limited public transport options and no local amenities that are easily accessible by foot or cycle.

Object

Representation ID: 16726

Received: 24/03/2021

Respondent: Shipley Town Council

We would like to see a bold type policy to support the role of markets in our towns and local centres - protecting them and allocating space for new ones.

The draft Plan should also include a policy that in any significant new area of housing development, provision should be made for local shops and centres which:
• avoid an overall increase in travel (supporting the 20 minute neighbourhood idea);
• provide access to essential shopping and community facilities for those without
access to a car;
• encourage vibrant and diverse neighbourhood/district retail centres.

Example - Barnsley Local Plan policy:

"Outside existing centres, small shops that meet the daily shopping needs of a local community will be permitted where:
• The shops are of a type and in a place that would meet daily shopping needs
and this need is not already met by existing shops; and
• The shops are located and designed to encourage trips by pedestrians and cyclists and would not encourage car trips."

Object

Representation ID: 16727

Received: 24/03/2021

Respondent: Shipley Town Council

The policy should require a housing density of 50 dpha for all sites.

The site capacity assessments of many of the allocated sites do not even meet the housing density requirements of Policy HO2.

The 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:

● roughly half of all the proposed greenfield land allocation is a product of low densities, not of meeting development need;

● the majority of Green Belt housing allocations are proposed to be developed well below the densities required by the Plan’s policies relating to density - analysing some of the Green Belt sites indicates net densities averaging around 26 dpha. There is no sound rationale for releasing Green Belt land if the result will be 5,000 homes developed at non-policy compliant densities.

Object

Representation ID: 16728

Received: 24/03/2021

Respondent: Shipley Town Council

Proposed policy:

1. All development is required to protect and enhance both biodiversity and green infrastructure features and networks both on and off-site for the lifetime of the development.

2. Developments proposals are required to evidence a thorough understanding of context through the preparation of a proportionate assessment of existing and planned green infrastructure, biodiversity and ecological features and networks both on the site and in the locality, and demonstrate how:
a) Through physical alterations and a management plan for the lifetime of the development:
i. Existing green infrastructure and biodiversity assets will be maximised;
ii. Opportunities to enhance existing and provide new green infrastructure and biodiversity assets will be maximised;
iii. Development will deliver long lasting measurable net gains in biodiversity;
iv. Where appropriate, a monitoring plan will be put in place to review delivery of i -iii.
b) The mitigation hierarchy has been applied by following a sequential approach to avoid, minimise, mitigate, and finally compensate for (on then off-site) any harm to biodiversity. If significant harm cannot be avoided in this way, development will not be permitted.

Object

Representation ID: 16729

Received: 24/03/2021

Respondent: Shipley Town Council

We are very supportive of this policy, as Saltaire WHS is part of our parish area. However, we also need to see a reduction in carbon emissions from the Saltaire WHS.

Whilst we do understand the importance of maintaining the character of these buildings and sites, it is important to encourage retrofitting to improve the energy efficiency of buildings, eg insulation, solar panels where these would not be prominent, more efficient and low carbon heat sources.

We would like a policy in the draft plan to reflect this.

Object

Representation ID: 16730

Received: 24/03/2021

Respondent: Shipley Town Council

This policy is welcome but there are areas where it can be strengthened to ensure that delivering zero carbon emissions by 2038 is achieved.

Policy wording from the Merton Local Plan re sustainable design (see attached document) is advocated.

All new developments should meet zero carbon standards, not just those of 50+ homes as required by the policy.

There is nothing specific in EN10 on heating. Proposed heat supply policy wording is provided (see attached document).

The plan should also include a policy that states:
● Houses should not be being built that lock homeowners into the gas network for heating.

Object

Representation ID: 16732

Received: 24/03/2021

Respondent: Shipley Town Council

Welcome a number of sections (see attached document) relating to reinforcing the importance of Shipley town centre and town centre enhancements and conserving heritage / World Heritage Site.

Conditional support for some proposals - Dockfield Road proposals will need to include local amenities such as local shops, medical and school places; Employment Zone and Business Development Zone - no increase in vehicle movements; and developments will need to demonstrate net biodiversity gain.

However concerns as follows:
- The delivery of 1,200 new homes - more housing can be developed on brownfield and under-utilised sites in the town centre and that the density of housing can be increased to remove the need for the Green Belt and greenfield sites.
- Promoting the town as an important transport hub - reword so that Shipley is an important public transport and active travel hub.
- Shipley Eastern Relief Road - We object to this. All road building leads to an increase in road traffic.

Disappointed by the lack of specific proposals for new walking and cycling infrastructure.

Detailed provision for reducing severance and flow and a description of active travel flows that exist and where new potential can be created is needed.

Object

Representation ID: 16742

Received: 24/03/2021

Respondent: Shipley Town Council

A number of brownfield sites are proposed in the Plan in Shipley area which is welcomed.

The Council should increase the number (and the affordability) of the proposed residential units on these brownfield sites and limit its proposals to only develop/adapt existing brownfield and town centre sites for housing.

It should also consider the following additional sites which we propose for housing:
● Shipley Hospital – which is due to close
● Land that housed the Oddfellows Pub on Otley Road
● Land that housed the Branch Pub on the corner of Otley – which is owned by the Council
● Wharf Street Carpark
● Land behind the Aldi Supermarket
● Underutilised car park on St Paul’s Road, Shipley
● Underutilised office space on St Paul’s Road, Shipley
● Unused car dealership/garage on Saltaire Rd/John Street opposite Wycliffe flats.
● Land next to the new Fire Station on Canal Road

The draft Plan should also take into account the availability of ‘retail and office space’ in and around Shipley town centre in light of likely changes to working arrangements post Covid-19 and reflecting PD rights changes.

This would prevent need for losing Shipley’s Green Belt and greenfield land

Object

Representation ID: 16743

Received: 24/03/2021

Respondent: Shipley Town Council

We object to Wycliffe Gardens SH3/H being proposed for housing.

This is valued open space used by the whole community - houses nearby either do not have gardens or just have very small yards. The advantage of this area is that
the greenspace is overlooked and close to houses, therefore it is ideal for outdoor play by children.

SH3/H also contravenes part of Outcome 4 of Bradford’s Joint Health and Wellbeing Strategy 2018-2023, which states that “People [should] have access to green space and children [should] have safe places to play outdoors.”

The council itself has stated that Shipley has a deficit of Amenity Greenspace of 5.72 hectares, the priority for increasing provision is rated as ‘Moderate’. Shipley only has 36% of the Amenity Greenspace that the Council thinks the area needs. Bradford Council Open Space Audit Report 2021 (page 44). The priority for the Shipley area should be to increase greenspace rather than allow development on it.

We support the recommendation by the Wycliffe Neighbourhood Association to designate this area as Local Green Space.