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

Comment

Representation ID: 15769

Received: 24/03/2021

Respondent: West Yorkshire Combined Authority (WYCA)

The reference to achieving employment that ‘meets the needs of communities and employers’ in Policy SP3: Hierarchy of Settlements is welcomed.

However, it is noted that Local Growth Centres would benefit from achieving a greater level of sustainability within their own right, in addition to attaining good transport links with Principal Towns and the Regional City of Bradford. The Plan could be more explicit in its encouragement of greater investment in Local Growth Centre employment opportunities and community infrastructure, such as schools and health care, which would support reduced car travel and the well-being of residents.

Comment

Representation ID: 15770

Received: 24/03/2021

Respondent: West Yorkshire Combined Authority (WYCA)

The policy seeks to meet the employment land requirement in full through the allocation of a mixed portfolio of new employment land’ focusing most development within the urban areas - this is consistent with the SEP aspiration to attract inward investment into the City Region and WY Transport Strategy objectives to promote sustainable accessible development. However, emerging WYCA research has identified a lack of strategic industrial/warehouse employment sites in the west of the Sub-region including the district of Bradford.

Part 6 of the policy, which is directed towards the delivery of digital infrastructure, would benefit from being expanded to highlight some of Bradford’s particular strengths and opportunities in this area.

The Plan would benefit from greater consideration of the impacts arising from the Covid-19 Pandemic, and the potential policy repercussions including - future patterns of development, the flexibility of transport options and increased reliance upon broadband/digital infrastructure. This should be informed by the WY Economic Recovery Plan and Transport Recovery Plan.

Comment

Representation ID: 15771

Received: 24/03/2021

Respondent: West Yorkshire Combined Authority (WYCA)

The Plan sets out, primarily in Policy SP9: Climate Change, Environmental Sustainability and Resource Use, its target to achieve net-zero carbon emissions by 2038.

This is in broad alignment with the ambition for the City Region to become a resilient net-zero carbon economy by 2038. Tackling the climate emergency is one of the priorities of the Combined Authority and we are committed to reducing carbon emissions to meet our 2038 net-zero carbon target. The upcoming ‘Tackling the Climate Emergency action plan’ due to be published later in 2021 will lay the foundations as we work towards becoming a net-zero carbon City Region. There will be an expectation that local policies support the action plan
including local plans that will need to evolve with it.

Comment

Representation ID: 15772

Received: 24/03/2021

Respondent: West Yorkshire Combined Authority (WYCA)

The purpose the policy ‘to support a move to a lower carbon future’ is in broad alignment with the ambition for the City Region to become a resilient net-zero carbon economy by 2038.

An amendment to encourage higher standards more generally but also the identification of sites which have the potential to be exemplars of sustainability, and steps toward Passivhaus or similar would support market building for zero carbon homes.

The call for sites for renewable and low carbon options and technical work set out under Policy EN10 is welcomed and aligns with the West Yorkshire Devolution Deal 2020 and Strategic Priority 3 of the SEP.

Renewable potential / potential capacity was assessed in AECOM’s ‘Low Carbon and Renewable Energy Capacity in Yorkshire and Humber (2011). There is a need for increased renewable generation in W Yorkshire to meet the regional net-zero carbon target. Although Policy EN10 acknowledges this, there is a lack of clarity on the spatial or quantitative integration of zero carbon emissions infrastructure.

Comment

Representation ID: 15773

Received: 24/03/2021

Respondent: West Yorkshire Combined Authority (WYCA)

Recognition of the proposed national Standards Framework for GI is welcomed.

The proposed policy for new development to meet the national GI Standards is likely to support delivery of GI in Bradford district, but there may be a need to develop locally specific policy on GI to ensure application of the national Standards reflect local circumstances - the national Framework is expected to complement local policy rather than act in its place. This would provide the opportunity for local policy on GI to set out how it can support other policies on nature recovery and Net Biodiversity gain which are currently not recognised in section 4.25.

As the national Framework is still being developed, there is potential for further quantified standards to be included alongside the Urban Greening Factor and the Accessible Natural Greenspace Standards.

Although it does not currently seem to be reflected in the Local Infrastructure Plan, the national GI Standards Framework and associated national GI dataset and mapping is intended to support LPA's in undertaking assessments such as the Open Space Assessment Needs and Demand Assessment, and this work should be informed where appropriate by the national Standards Framework and national mapping data being produced by Natural England.

Comment

Representation ID: 15774

Received: 24/03/2021

Respondent: West Yorkshire Combined Authority (WYCA)

Under Policy EN3: Trees and Woodlands, the role of the White Rose Forest (WRF) Community forest proposal should be considered, in particular the contribution that development can make to achieving any future tree planting targets identified by the WRF partnership for the region.

The proposed policies under EN3 will help contribute to the WRF targets but there is currently no recognition in the supporting text of the WRF partnership, which Bradford are a member.

Comment

Representation ID: 15775

Received: 24/03/2021

Respondent: West Yorkshire Combined Authority (WYCA)

Housing Need and Requirement

It is noted that the Plan’s housing requirement does not meet the recently updated Local Housing Need figure for Bradford which incorporates a 35% Cities and Urban Areas uplift, resulting in a figure of approximately 2,300 dwellings per annum. The supporting text for Policy SP8, under Paragraph 3.8.57, provides justification for this approach.

The collective City Region ambition is to deliver between 10,000 – 13,000 net additional homes per annum, as set out in Matter 8 the LCR Statement of Common Ground (2020). Based on the number of homes planned across the City Region authorities, through draft or adopted plans, the provision proposed in the Bradford Draft Plan (without the 35% Cities and Urban Areas uplift) will still allow the collective City Region housing growth range to be achieved. On that basis the Local Plan will contribute to the SEP housing delivery ambitions. However, we are seeking advice from Government regarding how the 35% Cities and Urban Areas uplift should be applied locally and any potential sub-regional implications.

Comment

Representation ID: 15776

Received: 24/03/2021

Respondent: West Yorkshire Combined Authority (WYCA)

The Plan also sets out, primarily through Policy HO5: Affordable Housing, how it intends to deliver a sufficient supply of good quality affordable housing that meets identified needs across the District.

The Policy sets varying degrees of affordable housing contribution for all major residential developments (10 or more homes) across four ‘Affordable Housing Zones’ and dependent upon greenfield/brownfield status, above the identified size thresholds. These elements of the Plan support the SEP ambition to increase housing growth and the provision of affordable homes.

Comment

Representation ID: 15814

Received: 24/03/2021

Respondent: West Yorkshire Combined Authority (WYCA)

The Plan sets out a range of policies to facilitate the delivery of new infrastructure, including provision for new strategic and sustainable transport facilities. These policies and proposals support the SEP.

The Plan’s support for the delivery of strategic transport infrastructure is also consistent with the SEP as it aims to capitalise on the opportunities presented by HS2 by linking communities and businesses within Bradford District to other areas in the City Region.

We welcome the references to Northern Powerhouse Rail (NPR) and Mass Transit in the Plan which is in line with the Leeds City Region Statement of Common Ground (SoCG) (March 2020) Matter 20.

We are encouraged that the Local Plan provides several policy hooks that dovetail well with the WY Transport Strategy and draft West Yorkshire Connectivity Infrastructure Plan.

Both the NPR and Mass Transit projects have the potential to meet the demands of growing capacity and increased connectivity so communities can better access jobs, education and other opportunities. We anticipate that both schemes can act as a catalyst to regenerate
and improve places along the route.

Comment

Representation ID: 15815

Received: 24/03/2021

Respondent: West Yorkshire Combined Authority (WYCA)

The Plan’s approach to flood risk management (FRM) is set out in Policy EN7: Flood Risk, which is generally welcomed.

However, the Policy would benefit from reference to managing flood risk at a catchment scale. This approach would demonstrate greater alignment with the City Region Flood Review (2016) and support wider FRM activities across the catchment.