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Bradford Core Strategy Preferred Options: A Tale of Two Halves

24th September 2019

CPRE have submitted their comments on Bradford Metropolitan District Council’s Bradford Core Strategy Partial Review – Preferred Options. Here is our general comment on the preferred options, and you can read our full submission document to see in detail how we have responded. As you will see, it is a tale of two halves.

We are delighted that Bradford chose to widen the scope of the CSPR on the basis of responses to the scoping report consultation. This has created the opportunity for a revised Core Strategy which represents a huge step in the right direction, for which we commend Bradford Council.

It sets an example to neighbouring authorities by moving away from the unrealistic relationships between wildly ambitious economic growth projections and wilfully excessive housing targets which have characterised Local Plans across West Yorkshire and beyond for a number of years. This will result in a more measured, evidence-based Plan that is much more likely to meet genuine needs for development, and is not burdened by unachievable land supply requirements that place needless pressure on greenfield land.

The draft also takes a much emboldened approach to tackling climate change, liveable neighbourhoods, creating healthy places and green infrastructure. Taken together, these changes create a holistic, strategic direction for Bradford that shows true leadership, and should be an exemplar to other local authorities.

It is not all good news, however. Despite the high ambitions, there is no clear pathway by which quantifiable reductions in greenhouse gas emissions will be achieved either at the strategic or individual levels. Most damagingly of all, the Council appears to remain wedded to a new road in South-East Bradford, to the growth of Leeds-Bradford Airport, and to the ‘unlocking’ of development land in those areas, without any clarity as to how such development would contribute positively to the laudable strategic aims for climate action and placemaking. Alongside this, the proposed urban extension at Holme Wood is repeatedly described as ‘sustainable’, without any evidence provided of how sustainability would be achieved or measured, and indeed with no lines on a map to enable anyone making a representation to make an informed analysis.

It might, theoretically, be possible for additional road capacity and an urban extension, both impacting on the openness and amenity of the Green Belt between Bradford and Leeds, to be delivered in a way that is demonstrably sustainable, acceptable to the community and consistent with meaningful climate action. But it will be very difficult to do so, and in our view the Council must provide very clear, compelling evidence of how that might be achieved, if those aspects of the Plan were to be considered sound and legally compliant.

On the basis of the evidence before us, the SE Bradford Relief Road and the Holme Wood urban extension appear to run counter to NPPF Para 148’s requirement to ‘shape places in ways that contribute to radical reductions in greenhouse gas emissions’. It would therefore directly harm the Council’s ability to meet its obligations in relation to the Climate Change Act 2008 and the UK’s commitment to net zero carbon by 2050.

We also believe that it is not possible to conclude that exceptional circumstances exist for removing land from Green Belt when the resulting development runs a high risk of undermining climate action. CPRE believe that these aspects of the draft Plan should be deleted and the Plan revised accordingly. This has been our recommendation to the Council.

Bradford Local Plan Consultation Submission
Bradford Local Plan Consultation Submission