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

Object

Representation ID: 19758

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

A number of suggestions for detailed wording changes and wording additions are made focusing on:

- Putting the achievement of net zero carbon by 2030 at the heart of the Local Plan
- greater emphasis on tackling spatial inequalities across the district particularly in health and well being (additions to part B4 of the policy);
- ensuring that the impact on the environment of any proposed new developments is taken into account more fully (additions / alterations are proposed to part B5 of the policy relating to site selection principles)
- accessibility of sites by non car modes of travel

Object

Representation ID: 19759

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

We fundamentally disagree with the wording of SP2 B4 (“Optimise the opportunities provided by the close proximity of Leeds Bradford International Airport as an international business gateway for the District and the region and build upon sectoral expertise, worldwide connectivity and tourism.”).

Aviation expansion is simply incompatible with our region’s transition to a net-zero carbon future. This section of the Local Plan should therefore make it clear that the expansion of LBA will not be permitted and, indeed, that flights via this airport will be gradually reduced in line with the requirements of national legislation and related international climate agreements.

Object

Representation ID: 19760

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

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: 19761

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

We do not accept that the proposed release of tracts of Green Belt in the draft local plan is consistent with the NPPF. Nor do we accept that development on Green Belt and Greenfield land will lead to the necessary biodiversity net gain referenced in Policy EN2: Biodiversity.

Bradford Council has NOT justified the exceptional circumstances for building on the Green Belt on the edge of Shipley. There is under-utilised land nearer Shipley Town Centre that could and should be used for development, and higher housing densities should also be incorporated into the brownfield site allocations in line, for example, with those being achieved elsewhere in places like London.

Object

Representation ID: 19772

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

The policy makes repeated references to growth with only a passing reference to “a move towards a greener economy”.

In our view, this will derail Bradford’s stated commitments to making the transition to both a net-zero carbon economy and a circular economy.

Instead, our Local Plan should focus on supporting the move away from carbon-intensive jobs and sectors to low carbon sectors. The policy should therefore be re-worded to say: Bradford aims to be at the forefront of the UK's net-zero carbon economy, as part of our drive to build circular economy principles and practice into our development strategies and to support the social well-being of the people of Bradford.

This section should also include a policy on how Bradford will use its own economic resources and assets to support the development of a low carbon economy - such as building socially-rented houses to Passivhaus standards and supporting retrofitting to improve the energy efficiency of our current housing stock.

Object

Representation ID: 19773

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

Welcome many of the approaches outlined in SP7, but the wording should be strengthened in support of low carbon travel.

Reference to the Bradford Cycling and Walking Infrastructure Plan and the Bradford Cycling Strategy should be made.

Actions and targets we are seeking to reach should be included:
● providing secure facilities for bike storage;
● providing a comprehensive network of cycle-friendly streets;
● providing multi-use paths and cycle routes in both urban and rural areas which are well lit and well maintained so that all sections of society can use them;
● ensuring all new housing developments and individual properties include areas for secure bike storage;
● providing direct, well-maintained, and well-lit walking routes, including to and from schools;
● providing quality footways in towns and cities and Quiet Lanes in rural areas;
● slowing down traffic with 20mph zones and Home Zones;
● improving walking-related infrastructure;
● prioritising pedestrians at well-used road crossing points;
● designing infrastructure to meet the needs of different groups including older people, disabled people, and children

Object

Representation ID: 19774

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

This section of the Local Plan makes no reference to the need to achieve much higher housing densities than are proposed in this plan for Shipley – for example - in order to avoid the use of greenbelt and greenfield sites for housing and / or to mitigate the need to do so.

We note that the Campaign for the Protection of Rural England has previously suggested that 50dph is a minimum reasonable target to aim for in general and especially when considering the use of non-brownfield sites for housing (see CPRE publication, ‘Compact Sustainable Communities’, November 2006, p.3).

Object

Representation ID: 19775

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

The target date for net zero carbon should be brought forward from 2038 to 2030.

SP9 A3 should be strengthened to ensure that the developers demonstrate that their proposals are carbon neutral or carbon negative in relation to construction, building energy use (see below) and travel.

A number of specific measures that developers should be required to incorporated into all developments are provided relating to
- opportunities for both natural heating and ventilation and reducing exposure to wind and other elements;
- maximise resistance and resilience to climate change e.g. solar shading, thermal mass, heating and ventilation, appropriately coloured materials, green and brown roofs, green walls, etc;
- use of trees and other planting to provide shading, to connect habitat with carefully selected native plants
- minimising the impact of surface water runoff from the development in the design of the drainage system

Object

Representation ID: 19776

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

This policy is very welcome, but needs to be significantly strengthened in order to deliver net zero carbon by 2030.

Example wording from Merton Local Plan is given.

EN10 states that the Council and its partners will “maximise” improvements in energy conservation etc, yet then states that zero carbon standards will only need to be met for developments of fifty plus houses. This is a striking contradiction - all new developments (residential and non-residential) should achieve zero carbon standards.

There is almost nothing specific in EN10 on heating. A proposed policy on heat supply is provided.

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

Other LA's have adopted more far-reaching policies on low carbon building - Take the example of the ‘Merton Rule’, adopted by Merton Borough Council eighteen years ago in 2003 - The ‘rule’ states that all new developments should generate at least 10% of their energy requirements from on-site renewable energy.

Object

Representation ID: 19799

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

The majority of the housing allocations for Shipley are well-judged i.e. the brownfield sites however:

- Shipley proposals should be limited to brownfield site only to avoid losing green filed and green belt land;
- the council - in the light of post covid implications - review unneeded office spaces and re-designate for residential;
- the brownfield housing allocations for Shipley need to be reviewed in order to achieve significantly higher densities - 50dph minimum;
- the Council should abandon Valley Rd road widening schemes and utilise the land instead for housing;
- all new housing in Shipley should be net zero in line worth putting dealing with the climate crisis at the heart of the plan.