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

Object

Representation ID: 25278

Received: 23/03/2021

Respondent: Tong & Fulneck Valley Association

Agent: Richard Buxton Solicitors

THE PLAN PERIOD, HOUSING & EMPLOYMENT LAND SUPPLY POSITION AND PROPOSED GREEN BELT RELEASES.

Need to clarify if 5-year land supply statement is out of date.

Support decision not to adopt 35% uplift. All reasonable alternatives for assessing housing need not considered. Would be justification for including mechanism to address current population shifts (impacts of pandemic; Brexit; changes to population projections/distribution).

Would be justification for not allocating sites for the full plan period, as housing need position is likely to shift. It would be prudent to allocate sites for the first 5 years with a partial review following to take account of up-to-date position on population distribution and household growth projections. Given this, it is not considered that exceptional circumstances exist for allocating Green Belt sites beyond the first 5 years of the plan.

Unclear how employment land figure has been set, but is likely to be out of date, given shifts in working patterns resulting from the pandemic.

Object

Representation ID: 25279

Received: 23/03/2021

Respondent: Tong & Fulneck Valley Association

Agent: Richard Buxton Solicitors

DISTRIBUTION OF GREEN BELT RELEASES.

Exceptional circumstances for Green Belt allocations do not exist. Also concerned with distribution of Green Belt releases and that so much is proposed for Bradford South East, in particular Holme Wood, by comparison to other areas. Most significant concerns relate to the proposal for a Strategic Urban Extension (SUE), in particular sites SE37/E, SE46/H and SE47/H.

SUE vastly exceeds the scale of others considered. No justification as to why Holme Wood is expected to absorb such a grossly disproportionate amount of the housing need in comparison to other areas.

Bradford South East/Holme Wood are within the most deprived areas of Bradford. Proposals will deliver very insignificant benefits to current residents. Will be exposed to years of disruption from construction, lose access to green spaces and the last remaining separation between their neighbourhood and Leeds, and subject to higher degrees of air pollution as a result of SEBAR.

Object

Representation ID: 25280

Received: 23/03/2021

Respondent: Tong & Fulneck Valley Association

Agent: Richard Buxton Solicitors

UNEVEN DISTRIBUTIONAL AND EQUALITIES IMPACTS OF THE BLP.

Bradford South East is more deprived than other areas, and also resident to more people sharing protected characteristics. Do not believe that Council has had regard to the distributional impacts that concentrating so much development in Bradford South East will entail. There is a moral and legal duty to consider this.

Residents do not feel development will have beneficial impacts. No consideration given whether the scale or form of development will serve existing resident’s needs. Will have no impact on the sub-standard existing housing in which residents live.

Equalities Impact Assessment is inadequate. Construction impacts are likely to have significant detrimental impacts on residents and, including those with protected characteristics. Same arguments can be made in respect of the loss of open space, loss of access to the countryside, air quality, severance etc.

Object

Representation ID: 25281

Received: 23/03/2021

Respondent: Tong & Fulneck Valley Association

Agent: Richard Buxton Solicitors

LACK OF CLARITY AROUND AND FAILURE TO ADDRESS IMPACTS OF THE PROPOSED SEBAR.

Not clear the extent to which proposals are dependent on SEBAR, and s106 contributions will be used to fund it.

SEBAR’s feasibility is not established; no assessment been carried out of its impacts including cumulative impacts and the level of development it would facilitate. No cumulative impact assessment is contained in the SA. Concerned it will lead to more development along its route.

Proposal will significantly affect local residents as:

1. Residents without access to a car (39%) would derive no benefit. Money would be better spent on measures to reduce car use and improve sustainable transport infrastructure.

2. Area contains areas of air quality concern – new road scheme likely to exacerbate local air quality issues.

3. Will entail high levels of greenhouse gas emissions in the construction and operational phases (increased car travel). Inconsistent with Council’s Climate Emergency Declaration and SA objectives.

Object

Representation ID: 25282

Received: 23/03/2021

Respondent: Tong & Fulneck Valley Association

Agent: Richard Buxton Solicitors

LACK OF ACCESS TO GREEN SPACE IN BRADFORD SOUTH EAST.

Description of open space is not a fair reflection of the area generally and Holme Wood in particular. Does not reflect the fact that quality of existing green space lags far behind provision in other areas. Access to green space is limited. Answer to under-provision is not to focus development on Bradford South East, but to invest in improving existing open spaces.

Concerned that the plan would entail much of Bradford South East’s Green Belt being released and developed, with even further development anticipated if stated ambitions in respect of the SEBAR are realised. While not formally being designated as “amenity space” or “park”, keeping this land free from development ensures a green gap between Bradford/Leeds. In the context of an area with under-provision, this area is a lifeline for local residents, who make use of it for recreation.

Object

Representation ID: 25283

Received: 23/03/2021

Respondent: Tong & Fulneck Valley Association

Agent: Richard Buxton Solicitors

ECOLOGICAL IMPACTS OF BLP IN BRADFORD SOUTH EAST.

Have been overlooked/not assessed. Fields/woodlands are home to hundreds of species of birds, mammals, insects and plants. Removal of green fields for housing removes habitats/food sources leading to further decline in biodiversity.

SE46/H, SE47/H & SE37/H would sever the Bradford Wildlife Habitat Network. SE45/H - Black Carr Woods LWS & SEGI is 65m from it and overlaps with an area of Network Enhancement Zone 2 of the National Habitat Network (strategically important for habitat creation), which would inconsistent with housing proposed. A missed opportunity for future habitat creation to offset biodiversity losses elsewhere.

Loss of hedgerows has not been taken into account in assessing the sustainability of the proposals.

Area ideal to bring forward tree-planting schemes to meet commitments in the Council’s Climate Emergency Declaration. Development will make this difficult to achieve. As well as meeting commitments, it forms an integral part is protection of existing trees, hedgerows and ecological networks.

Object

Representation ID: 25284

Received: 23/03/2021

Respondent: Tong & Fulneck Valley Association

Agent: Richard Buxton Solicitors

FAILURE PROPERLY TO ADDRESS FLOOD RISK IN PROPOSED BRADFORD SOUTH EAST ALLOCATIONS.

Currently not possible to make any informed decision as regards the flood risk potential of the allocations as SFRA is not available. Flood risk must be a key determinative factor in selecting appropriate sites. Consultation should be delayed in order allow up to date flood risk evidence to be prepared.

Evidence available that land and roads in and around sites SE37/E, SE46/H & SE47/H have been underwater during recent floods. Raises questions over whether mitigation will be possible if development comes forward, and what happens to residents in the area, particularly those living lower down the Tong Valley once the sites are developed.

These are fundamental issues. It would be prudent not to pre-empt a proper flood risk assessment and allocate sites when the evidence may reveal that flood risk renders them unsustainable/unviable.

Object

Representation ID: 25285

Received: 23/03/2021

Respondent: Tong & Fulneck Valley Association

Agent: Richard Buxton Solicitors

FAILURE TO DEMONSTRATE VIABILITY OF BRADFORD SOUTH EAST ALLOCATIONS.

If unviable and do not come forward, the Green Belt releases will have been unjustified. Four factors likely to undermine viability are:

1. Houses prices are lower than the West Yorkshire average, and it is likely that employment floor space prices are similarly depressed. Development values are therefore likely to be low;

2. Area is dominated by old mining operations (mineshafts and other infrastructure relating mining and processing). Will entail significant remediation costs to make sure the land is stable and level, and address contamination.

3. Flood risk issues will require major flood protection infrastructure.

4. The extent to which the allocations are expected to fund SEBAR through s.106 contributions.

Whole Plan Viability Assessment (Part 1) does not appear in the evidence base but is mentioned. Presumably it does not address the viability of the Regulation 18 draft of the Plan.