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

Comment

Representation ID: 25175

Received: 23/03/2021

Respondent: Bradford Chamber of Commerce

It is noted that the Introduction to the Plan (section 2.8) does not mention the Bradford Economic Strategy as one of the local strategies the new Local Plan seeks to align to. This is concerning not only because the Council were involved in its preparation, but that the economic aspirations that have been agreed locally are not clearly reflected in the Local Plan.

Proposed change: The Plan should make reference to the BES.

Comment

Representation ID: 25176

Received: 23/03/2021

Respondent: Bradford Chamber of Commerce

No reference in the policy to “inclusive growth” or “green growth”. Should be front and centre, reflecting the aspirations of the BES.

Policy sets out the approach to sustainable development. Not clear why it is necessary to duplicate national policy.

SP1B/2: Chamber supports aim to “support the economic strength of the district by allocating sufficient land for employment uses”. Concerned the amount of employment land has reduced substantially from the RUDP and Core Strategy.

SP1B/4: Chamber supports the need to ensure a sufficient supply of good quality homes. Critical that the number, size and location reflects the varied nature of the population

SP1B/5: Critical that focus on brownfield land is not at the expense of providing/retaining good quality employment land, particularly where there are good transport connections.

Proposed Changes: amend to refer to inclusive and green growth; ensure the balance of jobs to homes will support the future economic growth of the city.

Comment

Representation ID: 25177

Received: 23/03/2021

Respondent: Bradford Chamber of Commerce

This Policy recognises the need to “transform” the economy, environment, physical and social conditions in the District; this implies a step-change from the current position. In order to achieve a step-change, the Plan needs to be more positively prepared and more ambitious in what it is seeking to achieve. The approach set out in Policy SP2 will require a significant improvement in the city centre including new green space, improved transport connections (including rail/mass transit) throughout the District. A key part of “transforming” the district will be more employment opportunities within the city centre, as well as more new B Use Class development in the key transport corridors.

The Chamber supports the other objectives within Policy SP2 relating to enhancing the role of the District within the Leeds City Region as a key employment location, maximising the proximity of Leeds Bradford Airport, supporting the roles of the main settlements as well as protecting the District’s environmental resources.

Support

Representation ID: 25178

Received: 23/03/2021

Respondent: Bradford Chamber of Commerce

The Chamber supports the aim of directing a large proportion of development to the City of Bradford including Shipley/Canal Rd corridor. It is imperative that if the District is to meet its economic growth ambitions, the balance within the city centre of new homes to employment opportunities should be more balanced.

It is important that the role of the Principal Towns in providing employment opportunities in different sectors is recognised and some new employment land provided to support the retention of jobs in these key areas. A failure to do so will impact upon the ability of these sustainable locations to retain employers, particularly where there is strong pressure for housing development. Any site allocations (i.e. employment, housing, open space, etc) need to be considered in a methodical and consistent approach across the District.

Object

Representation ID: 25179

Received: 23/03/2021

Respondent: Bradford Chamber of Commerce

The policy should on balance be deleted as it serves very little if any purpose. It is far from clear in the written justification why a system of sequential selection or prioritisation of sites for allocation is necessary. In certain settlements there are few if any previously developed sites likely to come forward except on an unpredictable 'windfall' basis. Given past high rates of development of brownfield, it has to be recognised that the opportunities for the future identification of potential brownfield allocations is severely restricted in at least one of the three principal towns and in other settlements in the lower tiers of the hierarchy. Similarly, the opportunities for developing greenfield sites are greatly restricted in all tiers of the hierarchy as a result of existing greenfield uses or designations or the need for these to become publicly accessible open spaces in the future.

Object

Representation ID: 25245

Received: 23/03/2021

Respondent: Bradford Chamber of Commerce

Noted that Green Belt approach has been reviewed and due to exceptional circumstances, there is an allowance for some employment development. Further releases will be required to enable the District to recoup its economic position and support other policies.

Support conclusions that exceptional circumstances exist which require the deletion of land from the Green Belt for the provision of housing and employment land allocations.

Object to conclusions that the amount land take must be kept to an absolute minimum. Continued application of tight Green Belt boundaries is harmful. Has led to specific problems:

1. continuous household out-migration;
2. increased house prices due to lack of delivery;
3. negative impact on housing delivery;
4. failure to realise environmental/recreation enhancements, and other Plan policies.

Comment

Representation ID: 25246

Received: 23/03/2021

Respondent: Bradford Chamber of Commerce

Urban Brownfield Development
Agree best possible use should be made of brownfield land in urban areas in terms of increasing density targets. Several factors that will cumulatively impact on the densities that can be achieved if urban developments are to be truly sustainable and avoid cramming that must be taken into account:

• High design standards necessary to meet national/local policies
• Impacts of Grenfell Tower disaster and fire hazards on tall buildings as well as experience of living in high rise buildings.
• Importance of providing new/enhanced open spaces/environmental improvements as part of urban development.
• Need to provide/support supporting infrastructure and facilitate connectivity by active travel modes, and generating community facilities/interactions essential to health & wellbeing.
• Viability
• Need to regenerate existing urban areas and improve environments/living conditions of existing communities.

The challenge to achieve enhanced designs and living conditions is recognised in the Plan policies but the land use/land take implications have not been fully taken into account.

Comment

Representation ID: 25247

Received: 23/03/2021

Respondent: Bradford Chamber of Commerce

Policy aim of being “UK’s fastest growing economy” reflects the Chamber’s aspirations. Achieving this will be difficult - plan only seeks to plan for 4ha of employment per year (less than other West Yorkshire authorities). District has been losing out to its neighbours - needs to significantly increase the amount of new employment land available. Might mean comprehensive review of existing low-grade areas as well as tougher decisions around the Green Belt.

Will be significant pressure on existing employment areas to be redeveloped for housing, particularly if the Council is to accommodate the 35% uplift identified by Government.

Policy seeks to “build the economic strengths of the principal towns” yet there are no allocations for Ilkley & Bingley and nominal 5ha in Keighley. Existing employments areas will be under pressure from housing, therefore critical new employment land is identified.

Support the delivery of improved fibre optic, mobile and fixed wireless infrastructure and digital innovation.

Support

Representation ID: 25248

Received: 23/03/2021

Respondent: Bradford Chamber of Commerce

The Chamber recognises the importance of strong transport connections both within the District and beyond. It supports the overall principles of Policy SP7 regarding reducing demand by locating development in accessible and sustainable locations, and where appropriate, maximising densities and supporting co-locating residential and employment development.

The Chamber is particularly supportive of the technological changes to transport both in terms of improving connectivity and also in terms of the economic opportunities for businesses within the District. The Chamber supports the need for a city centre Northern Powerhouse Rail station, and a Mass Transit System.

The Chamber also supports improvements in the public transport network and walking/cycling routes, although it has reservations about the introduction of a Clean Air Zone in the City Centre due to the potential economic impact on businesses already affected by Covid-19 and Brexit.

Comment

Representation ID: 25249

Received: 23/03/2021

Respondent: Bradford Chamber of Commerce

Policy EC1’s approach does not reflect that of Policy SP2.

Agree with the general premise of Policy EC1, but concerned that approach is not ambitious enough, given previous poor performance in delivering quality employment land in the right locations. Has meant businesses relocating/locating elsewhere. New plan should seek to provide significantly more employment land to attract business back to the District.

Should reconsider the Richard Dunn Centre site as an employment allocation due to its proximity to the M606 and wider road network.

Bradford has under-performed economically compared to neighbouring areas and reflected in its approach to employment land provision. Decline will not stop without a more ambitious approach. To secure sustainable development and reduce climate change impacts, it is important that sufficient jobs are provided. It will be difficult for Bradford to compete with neighbouring areas unless it allocates more new sites in the right locations.