Bradford Local Plan Review

Bradford Local Plan Review CPRE West Yorkshire April 2021 Pages 2 Introduction 3 - 12 Strategic Policy Review 13 - 14 ‘Hotspots’ 15 - 16 Specific Site Allocation Review 17 - 18 Considering Reasonable Alternatives 19 - 20 Environmental Net-Gains using the NPPF This document was prepared by Stride Works Ltd on behalf of CPRE West Yorkshire Andrew Wood | Planning Consultant and Author Laura Harryman | Planning Assistant and Researcher Introduction The Bradford Local Plan has been a long time Thirdly, the updated National Planning Policy coming. We took part in influencing the Core Framework (NPPF) takes a much stronger Strategy which was adopted in 2016. The process line on ‘making effective use of land’. This has been stop/start since then and this is a means ensuring that available, suitable whole new draft Local Plan. brownfield land is being prioritised, and that development densities are being increased. The early stages of a Plan are some of the most That should result in less land being needed important in terms of community influence. This is overall, less pressure to release land from the a Preferred Options consultation (technical title Green Belt, and also more compact, walkable Regulation 18), which means there is still room to neighbourhoods. suggest alternative options for what the overall strategy should be. Later on in the process, there What’s CPRE’s position? is much less room for manoeuvre as the options become more fixed. We want to see pressure on greenfield and Green Belt sites minimised, and to ensure So what has changed since 2016? green spaces within urban areas are protected. Sometimes there’s a tension between these Firstly, the overall housing target is lower, at two goals, but if new development is built at 1,700 per year, although the government has the right density in the right places, it should be introduced a 35% uplift for large urban centres. possible to get the balance right. Bradford Council is keen that the additional homes should go into Bradford city itself, rather CPRE has identified that the Draft Plan does than being added on to the general housing not properly consider reasonable alternatives target for the district. We support this position. to the policies proposed. Whilst it has correctly identified key challenges for the district, there Secondly, Bradford has declared a Climate is no evidence that alternative strategies for Emergency, and West Yorkshire has published how to address these challenges have been the West Yorkshire Emissions Reductions considered. We have propsed some reasonable Pathways report. By 2038 (the end of the alternatives which address issues of climate, period for this new Local Plan), Bradford should housing density and inequality. be at net zero carbon. They need some huge transformations to achieve this. Some of the In developing our response, we worked with major infrastructure plans for West Yorkshire our network of friends and associates in the (such as the West Yorkshire Mass Transit Bradford area. System) won’t have a big impact on emissions until after 2038, so Bradford has a lot of work to do to tackle emissions through other means Andrew Wood before then. Planning Consultant 2 Strategic Policy Review Sustainable Development & Spatial Priorities Spatial Priorities (Policy SP2) Our response to the draft plan is shaped by our The Plan itself does not present any reasonable fundamental principles for a good Spatial Plan, alternatives for a spatial strategy. The only that it makes a positive contribution to climate alternatives presented are whether the policies action, and that conforms with NPPF para 148 in should be more or less comprehensive and shaping places to radically reduce greenhouse gas more or less specific in their scope, but there is emissions position. no consideration of an alternative strategy. We do not think that it is necessary for the airport The overall strategic outcomes of any local plan to be a spatial priority, which would enable should be net reductions in greenhouse gas the other objectives of the plan to be better emissions, car traffic, pollution and flood risk, a net implemented. enhancement of biodiversity and a net increase in access to green space. The benefits of these In relation to housing growth, the plan outcomes need be socially and spatially equitable. proposes 72% of growth within the regional city of Bradford, but the proportion of new Local plans also need to have an implementable development being directed to brownfield vision for their rural areas, and CPRE look to the sites remains at 50%. It would be reasonable plan to set policies that will actively enhance to expect the percentage of development on the countryside in terms of nature, landscape brownfield land to have increased, and it is sustainability and people’s ability to access and unclear why this is not the case. The new growth use the countryside in a sustainable way. in the plan period would be more effectively achieved with a greater focus on brownfield Delivering Sustainable Development sites. (Policy SP1) An alternative strategy of pursuing a significantly We consider that SP1B needs to be much more higher concentration of development onto clear and specific about the need to achieve high- brownfield sites has not been fully tested. level, net enhancements to social, environmental and economic well-being. The NPPF in fact describes a net gain approach to many areas of the local plan. The Plan should adopt this net gain approach at the top level, by expressing these clearly at the beginning of the plan in this policy. 3 The Settlement Heirarchy & Location of Development Hierarchy of Settlements (Policy SP3) Location of Development (Policy SP4) The text describing each tier of settlement is We strongly support elements of this policy broadly similar, but where there are differences, which point to 15 minute neighbourhoods and it is not clear why these exist. Each level of the an aspiration to reduce car dependancy and hierarchy should through the allocation and use. These aspirations are of fundamental development of land and buildings should seek importance, not only to achieving greenhouse to enhance the following considerations: gas reductions and improving quality, but also to tackling the wide range of public health and • the capacity of the settlement to social inequality impacts of dependence on accommodate development; cars for transport, and dominance of cars in the • the character of the place and places and spaces where people live and work. neighbourhoods within it; • high standards of design of buildings and We would encourage the use of the 15 minute the public realm; neighbourhood model to be adopted as a • connectivity and maximising opportunities policy in the plan for all but the smallest and for take-up of sustainable and active travel the most remote settlements. Communities modes; enhancing the quantity and quality of such as Addingham or Oxenhope should not green infrastructure; be more dependent on cars and less able to • and enhancing the vitality of the place as a access their basic needs on foot than people whole, and neighbourhoods within it. living in in urban neighbourhoods of the city of Bradford. There is also a lack of a vision for the future of Bradford’s rural areas. The West Yorkshire emissions reductions pathways report states that a 21% reduction in car mileage is needed by 2038, which is also the end of this plan period. If this is to be achieved, it is essential that the Local Plan does everything it possibly can to facilitate it. New development must be located and planned in such a way as to facilitate net reduction in car use in the host settlement. This is likely to depend on significantly greater concentration of new development within areas that are capable of being 15 minute neighbourhoods, and significantly more mixed-use rather than single-use site allocations. 4 Alternative Wording for Policy SP4: Location of Development A. The Local Plan will adopt a car-free accessibility approach to ensure that new A comprehensive approach is also needed to development contributes to the strategic target ensuring that non-car modes are safe, attractive of reducing car use over the plan period. It will and reliable choices for an increasing majority of do this by locating new development such that it: journeys and for all users. 1. Makes walking, cycling and public transport The extension of Permitted Development rights the most attractive and useful travel could seriously compromise the ability of mixed modes for day-to-day journeys, to achieve use sites to remain in mixed use. We think that 15-minute neighbourhoods; changes of use that undermine the 15 minute 2. Ensures that the pattern of development neighbourhoods concept would constitute an improves accessibility and independence overwhelmingly negative impact, and provides for all sectors of society; justification for use of Article 4 directions (a 3. Takes every possible opportunity to create piece of legislation that allows a local planning and enhance green corridors for nature, authority to restrict permitted development climate response and active travel; within a planning permission) to protect 4. Minimises the dependence of development neighbourhood vitality. on any additional road capacity that could otherwise induce additional traffic; The language used in policy SP4 is too 5. Maximises the use of rail and water for subjective. We want to see stronger potential uses generating large freight movements. to improve biodiversity. Biodiversity and environmental potential of previously developed B. Having identified how to maximize car-free land should be considered in an integrated way accessibility, the Local Plan will then maximize with its development potential. We also expect the efficient use of land, by allocating sites that: more specific requirements for examining the sustainability of greenfield sites within 1.

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