CPRE Policy Analysis – SP1 to SP8 Bradford Draft Local Plan March 2021
We will be submitting our consultation response to the Bradford Local Plan through the consultation portal. Below is a (long) post which replicates our submission on our policy analysis of SP1-SP8 of the Draft Bradford Local Plan.
Groups from around Bradford District felt that it would be useful to inform their own responses if ours was available prior to the consultation deadline. We hope this is helpful to them and others with an interest.
Our response to the draft plan is underpinned by our overall priorities for spatial planning our fundamental principles for a good Spatial Plan
Firstly, that it should be genuinely contributing to climate action and in full conformity with NPPF para 148 in shaping places to radically reduce greenhouse gas emissions position. The overall strategic outcomes of any local plan should be:
- net reductions in greenhouse gas emissions
- net reductions in car traffic
- net reductions in pollution
- net enhancement of biodiversity
- net increase in access to green space
- net reduction in flood risk
- and the benefits of these outcomes should be socially and spatially equitable.
As the countryside charity, CPRE is of course especially concerned about the need for Local plans to have an implementable vision for their rural areas. And therefore, we look to the plan to set policies that will actively enhance the countryside in terms of nature, landscape sustainability and people’s ability to access use the countryside in a sustainable way.
SP1A is a reiteration of NPPF’s presumption in favour of sustainable development and we see no need to comment on that. Part B is expressing Bradford’s local interpretation and application the presumption. Referring to our headline aspirations for all local plans, we consider that SP1B needs to be much more clear and specific about the need to achieve high-level, net enhancements to social, environmental and economic well-being.
NPPF in fact describes a net gain approach to several considerations:
- Para 32 seeks simultaneous progress against economic, social and environmental objectives;
- Para 91(c) describes approach to healthy lifestyles by identifying needs and improving provision;
- Para 97 (d) requires that open spaces losses should be replaced by ‘equivalent or better’ provision;
- Para 102(d) requires a net gain approach to the environmental impacts of traffic and transport infrastructure;
- Para 110(a) requires development to “give priority first to pedestrian and cycle” movements both within a scheme and with neighbouring areas, meaning that a net improvement to walking and cycling in a neighbourhood should be a reasonable expected outcome of a development;
- Para 118(a) identifies the potential for land to fulfil multiple uses at the same time (multi-functionality);
- Para 141 requires local authorities to plan positively for the beneficial use of their Green Belt;
- Paras 157 and 160 demand a net improvement to flood risk as a result of new development;
- Paras 170(d) and 174 identify the role of ecological networks and require biodiversity net gain;
- Para 171 demands the “enhancement of natural capital at catchment or landscape scale across authority boundaries”
In our view the Plan should adopt this net gain approach at the top level, by expressing these clearly at the beginning of the plan in SP1.
SP2B (1) to (6) describe the spatial approach to allocating land for development to implement the to implement sustainable development; and SP2B (7) to (12) describe the constraints and development expectations for those allocations. The policy contains a significant internal contradiction: (4) makes the airport a spatial priority, but dependence on the airport as an economic driver is very likely to undermine moves towards a green economy and the low carbon future, as envisaged by (8). This is a spatial risk, because it embeds further economic dependence on aviation through continued and increased use of the airport, and further carbon emissions from surface access. Further, there is a the risk that identifying the airport as a spatial priority locks in further road based economic development at relatively low employment densities.
The Plan does not contain a reasonable alternative spatial strategy. The only alternatives presented are whether the policies should be more or less comprehensive and more or less specific in their scope, but there is no consideration of an alternative strategy. In our view an alternative that should be fully considered is for the airport not to be a spatial priority and to consider the extent to which that would enable the other objectives of the plan to be better implemented.
In relation to housing growth, we note that the adopted cost strategy sets locates 66% of growth within the regional city of Bradford; the Core Strategy Partial Review increases this proportion to 70%; and the new Plan increases this percentage further to 72%. This is presented as an increase in the local plan’s urban. We note, however, that the proportion of new development being directed to brownfield sites remains at 50%. Considering the significantly increased emphasis given to making effective use of land in NPPF2019 compared to NPPF2012 (against which the adopted Cost Strategy was assessed), it would be reasonable to expect the percentage of development on brownfield land to have increased, and it is unclear why this is not the case.
Whilst we do not imagine that all of the new growth in the plan period could be accommodated on brownfield sites, it is important to consider whether the achievement of the development expectations set out in SP2B (7) to (12) would be more effectively achieved with a greater focus on brownfield sites, and this has not been adequately evidenced. We would therefore contend that an alternative strategy of pursuing a significantly higher concentration of development onto brownfield sites has not been fully tested.
We do not have any comments on whether the hierarchy of settlements proposed here is in itself correct. It appears to be logical insofar as it is principally informed by the size, level of services and relative accessibility and connectivity of each tier of settlements.
The text for each tier of settlement is broadly similar, and this leads to the problem that it is difficult to discern how the policy might lead to different decisions about land allocations or the development expectations for that land in different tiers. Where there are differences, it is not clear why these exist: for example, the Principal Towns, Local Growth Centres and Local Service Centres share an expectation to ‘achieve a high standard of design that protects and enhances settlement character’, and in Local Growth Centres and Local Service Centres and rural areas there is the addition of the phrase ‘landscape diversity’ into this clause. But the expectations for the Regional City do not contain this clause; and whilst they refer to a well- designed public realm and buildings, there is no reference to settlement character. This implies that on the one hand settlements character is not a development consideration in the regional city and, conversely, that the design of the public realm is not explicitly of concern when making decisions about allocation and development of land in the other levels of the hierarchy. This does not make sense.
SP3 could be greatly simplified by identifying the levels of the hierarchy, but then saying that in each level of the hierarchy the allocation and development of land and buildings would seek to enhance the following considerations:
- the capacity of the settlement to accommodate development;
- the character of the place and neighbourhoods within it;
- high standards of design of buildings and the public realm;
- connectivity and maximising opportunities for take-up of sustainable and active travel modes; enhancing the quantity and quality of green infrastructure;
- and enhancing the vitality of the place as a whole, and neighbourhoods within it.
There is also a lack of a vision for the future of Bradford’s rural areas. Currently the only concession to rural areas in the settlement hierarchy is through supporting broadband and live work and home working – neither of which are exclusively rural considerations.
We strongly support paras 3.4.7 and 3.4.8, which point to 15 minute neighbourhoods and an aspiration not to eliminate the car, but to reduce its use. These aspirations are of fundamental importance, not only to achieving greenhouse gas reductions and improving quality, but also to tackling the wide range of public health and social inequality impacts of dependence on cars for transport, and dominance of cars in the places and spaces where people live and work. 15 minute neighbourhoods are in our view a particularly useful concept and we would encourage them to be adopted as a policy in the plan for all but the smallest and the most remote settlements. There is no real reason why communities in Addingham or Oxenhope should be more dependent on cars and less able to access their basic needs on foot than people living in in urban neighbourhoods of the city of Bradford.
In terms of reducing car use, we now know the strategic scale of reduction needed because this is identified in the West Yorkshire emissions reductions pathways work which states that a 21% reduction in car mileage is needed by 2038, which is also the end of this plan period. If there is any prospect of that very significant reduction being achieved, it is essential that the Local Plan do does everything it possibly can to facilitate it. It should do so principally through the location of new development, the development expectations in each of those locations, and the transport investments proposed. Bearing in mind the TRICS data that every new dwelling generates five to seven additional vehicle trips per day, it is important to be specific in stating that it is not enough for a new development to show that it would it could produce 20% fewer additional vehicle movements associated with that development. 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. A comprehensive approach is also needed to ensuring that non-car modes are safe, attractive and reliable choices for an increasing majority of journeys and for all users.
In light of the extension of Permitted Development rights, which could seriously compromise the ability of mixed use sites to remain in mixed use, we would argue that changes of use that undermined the 15 minute neighbourhoods concept would constitute an overwhelmingly negative impact, and provides justification for use of Article 4 directions to protect neighbourhood vitality.
SP4(A) is essentially a reiteration of government policy and the settlement hierarchy. We are concerned that the phrase ‘not have high environmental value’ is too subjective. This is because there may be sites which are currently not of high environmental value, but which have strong potential to become so, for example through being beneficiaries of biodiversity net gain measures or significant urban tree planting. So it is important that the environmental potential of previously developed land is considered in an integrated way with its development potential.
Similarly, we would expect more specific requirements for examining the sustainability of greenfield sites within settlements. The sustainability outcome of developing a greenfield site within a settlement may be highly dependent on the type and mix of development identified for it, and how opportunities for environmental net gains and walkable neighbourhoods are implemented.
We are concerned that the phrase ‘subject to the above’ implies that the application of the sequence identified in part A of the policy takes precedence over the outcomes identified in part B of the policy.
This is counter intuitive. The intended outcomes in Part B must be achievable for any site allocation, and if a site cannot achieve those outcomes it should not be allocated, irrespective of its position in the sequence set out in part A. Hence, any justification for allocating greenfield and Green Belt land must be made on the basis that doing so will achieve the outcomes identified in SP4B.
We are also concerned that the intended outcomes in SP4B – whilst referring to an accessibility orientated approach – do not clearly consider the accessibility needs of different people for example, by age, gender or ability as required in NPPF para 108.
Turning to the alternatives considered for SP4, the wording is rather cryptic and it is not clear how those different alternatives differ from each other. We have provided below a suggested alternative wording for policy SP4 to address the concerns we have raised here.
Policy SP4: Location of Development
- The Local Plan will adopt a car-free accessibility approach to ensure that new development contributes to the strategic target of reducing car use over the plan period. It will do this by locating new development such that it:
- Makes walking, cycling and public transport the most attractive and useful travel modes for day-to-day journeys, to achieve 15-minute neighbourhoods;
- Ensures that the pattern of development improves accessibility and independence for all sectors of society;
- Takes every possible opportunity to create and enhance green corridors for nature, climate response and active travel;
- Minimises the dependence of development on any additional road capacity that could otherwise induce additional traffic;
- Maximises the use of rail and water for uses generating large freight movements.
- Having identified how to maximize car-free accessibility, the Local Plan will then maximize the efficient use of land, by allocating sites that:
- are compatible with the settlement hierarchy;
- give first priority to the re-use of brownfield and under-utilised land within settlements, and second priority to greenfield sites within settlements, while ensuring that development of those does not harm environmental assets or public space;
- are suitable for development at a minimum of 50 dwellings per hectare net.
- Where there are insufficient sites within settlements, land will be identified for release from the Green Belt adjacent to settlement boundaries, as set out in policy SP5, so long as those sites fulfil the three criteria in SP4 A and B above.
Green Belt Policy SP5
Para 3.5.27 comments that the government intends the 35% uplift for large urban areas to be targeted at urban centres and regeneration, not at generalized housing supply. This is a logical approach which we would support. However, this must be taken to mean that urban centre areas do in fact contain sites that the council anticipate could be brought forward for development to meet the 35% uplift; and if this is the case then the correct application of the locational policy described in SP4 would prioritise this urban land first. So it is unclear how the proposed scale of Green Belt change is needed to support the proposed housing requirement if a further 35% (10,000 dwellings) could be subsequently found within urban central areas. We infer from this that there are sufficient inner urban sites to accommodate the uplift, but that adding in the uplift would constitute a significant change to the distribution of new development such that a much larger share of the total goes into urban Bradford.
Furthermore, paragraph 3.5.6 states that the assessment of non-Green Belt land capacity takes into consideration density levels compliant with policy H02. However, our own analysis of proposed Green Belt sites indicates net densities averaging around 26 dpha – well below the HO2 minimum of 35 dpha, and even further below the 50 dpha that we consider all site allocations should be required to achieve. There is no sound rationale for releasing Green Belt land if the result will be 5,000 homes developed at non-policy compliant densities.
We do not accept that the housing density requirements set out in HO2 correspond with the site capacity assessment assessments for the sites in the plan, such that HO2 will be implemented and the high level strategic priorities for sustainable development and reduced car dependence will be implemented. Also, we do not accept that the economic growth proposals set out in policy SP6 robustly justify the allocation of Green Belt sites for employment, and therefore do not consider the exceptional circumstances have been adequately demonstrated for Green Belt change to supply employment land.
If the local plan is to demonstrate exceptional circumstances for Green Belt change. This must be set in the context of:
- the need to address climate action as we described in response to SP1;
- the need to achieve significant environmental net gains through development as required by NPPF, and the scale of car traffic reduction needed, as confirmed by the West Yorkshire Emissions Reduction Pathways report.
As we explained in SP4, a case for exceptional circumstances is in our view contingent on the Local Plan being confident that the resulting pattern of settlement both for housing and employment will actively address these high-level challenges. In our view, the net effect of releasing land from the Green Belt for the housing and employment sites proposed will undermine achievements of policies SP7 and SP9, resulting in failure to meet West Yorkshire’s net-zero 2038 target.
SP5E describes an approach to compensatory improvements to the Green Belt. In line with our comments about net gain it is essential that the net effect of releasing land from the Green Belt is a measurable net benefit to the function of the Green Belt. We suggest a rewording of SP5 along the following lines:
Where land is released from the Green Belt for development the Council will identify compensatory improvements to the environment quality and accessibility of remaining Green Belt that produce a measurable net improvement to the beneficial use of the Green Belt in the same locality as the Green Belts release. This may include inclusion of additional land in the Green Belt in those localities, and/or Local Green Space Designations to protect green spaces within settlements.
The alternatives considered at 3.5.30, as with other aspects of the Plan, do not in fact present the consideration of reasonable alternatives. They describe a different approach to how the policy is laid out, in particular by excluding sites from the policy listing, but no alternative approach is offered either for increasing the proportion of new development directed towards urban brownfield sites; or for further increases in residential and employment density as a way to reduce the amount of Green Belt land required.
The supporting text for this policy is unfortunately very opaque, and it is very difficult to discern from it what the plan’s economic rationale actually is.
The key task of the Local Plan in relation to economy is not to unquestioningly align with and support all forms of economic development, but to actively support those economic developments which contribute to the implementation of the spatial and sustainability objectives of the Plan.
SP6(A1) is a repeat of the district’s economic strategy referred to at the beginning of the chapter, and does not give any guidance as to what the local plan intends to do to support the economy.
SP6(A2) is merely a precis of the settlement hierarchy, and it is unclear why the regional city of Bradford is identified for enterprise in the green economy, where other parts of the settlement hierarchy are not. SP6(A3) describes priority business sectors and clusters that will be supported but without any reference to the different needs of the different sectors listed, in terms of the types and locations of premises that they would need
SP6B is again not clear how the specific needs of the priority sectors identified in SP6(A3) will be targeted.
SP6C states the council’s intention to support the delivery of at least 1,600 jobs a year but does not specify the degree to which the Local Plan policies and site allocations are anticipated to contribute to that level of job creation. It is therefore entirely unclear how the amount of land referred to in SP6(B2) relates to the delivery of the job target SP6C.
Considering that a substantial portion of the 72ha of new employment allocations are proposed to come from the Green Belt, we need to revisit the justification given for exceptional circumstances for Green Belt change. They do not stack up, for the reasons set out below.
Para 3.5.9 identifies issues in the provision of sites to support the development of high growth sectors and low carbon economy oriented businesses. Considering that West Yorkshire has committed to a target of net-zero carbon by the end of this plan period in 2038, it is self-evident that all growth sectors supported by the plan must by default be demonstrably low or zero carbon in outcome. We would therefore expect the priority business sectors in SP6(A3) to each be supported explicitly by a net-zero 2038 action plan; and SP6B, in identifying sites and locations for employment, would also make clear that economic development proposals will be supported where they deliver measurable progress toward zero carbon economy.
3.5.11 says that the locational demand for employment space for businesses already operating within the district tends to be very locally specific in order to retain staff and local trading relations. And 3.5.10 states that the vast majority of non-Green Belt allocations are in micro, small, and small-to-medium sized allocations. This indicates that the larger Green Belt sites that are proposed to be allocated will not deal at all with the locational demands of businesses already operating within the area because those sites may not be local enough for the retention of staff and local trading relations; so the larger sites are geared to providing for incoming, larger businesses. In line with our comment about 3.5.9, it is imperative that incoming businesses are expressly zero-carbon – otherwise the transformation of economic activity and the associated spatial patterns will be directly undermined.
To address these issues SP6 must make a clear and unequivocal statement that plan-supported economic development must actively contribute to the net-zero 2038 target for West Yorkshire.
Again, as with other policies, there is no alternative strategy presented as having been considered. There is no evidence that the plan has considered whether Bradford’s economic strategy is compatible with the spatial and sustainable development priorities of the plan. For one thing, we would expect to see within the local plan the recognition that employment within market sectors is only one component of the economy. The other key components are essentially the foundational economy which includes the public sector, health care, education and other services, and the many micro businesses for whom growth is not a priority, but who provide large numbers of jobs. For example, retrofitting existing buildings with zero carbon may offer employment opportunities within many small and medium-sized businesses, and would be hugely beneficial to the district in pursuing its net-zero carbon target. So an innovative policy for the development expectations of residential and business land and buildings would also provide a major employment opportunity and a major carbon reduction opportunity. That is the kind of economic policy we need to see in the Plan.
We warmly welcome and support many aspects of this policy, which is truly forward-looking in its intent for a 21st century, sustainable pattern of transport.
In SP7A and B, we are unclear as to the plan’s role in supporting these rail and mass transit improvements. Conversely it is unclear to what extent the the locational sustainability of the plan’s spatial strategy is contingent on the measures in A and B which may or may not be forthcoming within the plan period.
Given the need for Bradford to achieve net-zero carbon by the end of the plan period, any measures that are to contribute to carbon reduction must be able to take effect during the plan period. If they will not take effect until towards the end of or beyond the planned period, then they are legitimate measures to ensure that development post 2038 is zero carbon; but development that takes place before 2038 must measurably contribute to zero carbon in the absence of these measures. This needs to be clarified.
The four principles of sustainable transport set out in SP7C are very important and we give them our full support. It is very encouraging to see a local plan policy taking a robust and ambitious approach to demand reduction through the location of development, and to transforming travel choices and patterns through reallocation of road space and re-engineering of streets.
The supporting text for this chapter (3.71 to 3.7 28) is in fact much clearer than the policy itself in explaining what the plan aims to achieve and how to implement it. Indeed, we would suggest these components be moved into the policy itself.
CPRE believes in meeting genuine housing need by building the right types of homes in the right places. In that context we are content with the proposed numerical housing requirement. We strongly support the council’s proposed approach to dealing with the 35% uplift for urban centres because, for this if the uplift were added to the general requirement it could easily result in allocation of peripheral, Green Belt sites that would be poorly targeted for regeneration. The uplift is a policy intervention to boost urban centres, so it would be counterintuitive and counterproductive for it to result in more peripheral development.
The components of supply identified in SP8D effectively describe a sequential approach to supply and the two broad locations for growth. We infer from this that land for the broad locations would be removed from the Green Belt but not allocated. It is difficult to compare this information and the information on the policies map with the list of Green Belt release sites identified in policy SP5, considering that a significant proportion have the total housing supply identified to come from Green Belt is located within the broad locations for growth. It is also unclear whether those broad locations for growth are intended to supply further housing numbers beyond the plan period.
It is of great concern that we cannot see from the draft Plan the proposed what the extent of land-take in the broad locations for growth within and beyond the plan period is likely to be.
It would be helpful to know which of the settlements in Schedule 1 have prepared or are preparing neighbourhood plans. SP8F implies that neighbourhood plans could provide for additional housing numbers above and beyond those in Schedule 1, but it appears that the distribution in Schedule 1 has been derived from the availability of known sites and their indicative capacity. In many cases we know that communities are objecting not to the numerical target itself but to specific site allocations. Therefore it is important that SP8F is worded to empower neighbourhood plans to specify the type and density of housing, such that meeting or exceeding the numerical target but on fewer sites, or on more smaller sites, is an acceptable role for the neighbourhood plan.
The breakdown of previously developed previously developed land allocations in SP8H tells us that:
- In the Regional City, 45% of dwellings will be greenfield, ie 9,033
- In the Principle Towns, 65% of dwellings will be greenfield, ie 2,177
- In the Local Growth Centres, 85% of dwellings will be greenfield, ie 2,434
- In Local Services Centres, 70% of dwellings will be greenfield ie 963
Consequently, 14,607 new dwellings will be on greenfield land across the district, which is 48% of the total requirement but 53% of allocations, by number of dwellings. Due to the tightly-drawn Green Belt a high proportion of the greenfield allocations will come from the Green Belt.
CPRE does not have the capacity to assess every site, so we need to make some assumptions here. Our assumptions are:
- That the capacity of all brownfield sites identified in the Plan are calculated at 50dpha net;
- That across all sites there is an average of 25% undevelopable area, so 50dpha net translates to 40dpha gross;
- That the Plan has identified all the brownfield sites in the district that have a reasonable prospect of coming forward for development during the plan period.
Since, as we established above, any policy-compliant greenfield site should also be built to at least 50dpha net, we would expect 14,607 dwellings to require a further 365 ha of greenfield land.
However, if in fact all of the greenfield sites averaged the general minimum density of 35 dhpa net, which equates to 28dpha gross, then the same 14,607 homes would require 522 ha of land.
We have so far looked in detail at 25 greenfield sites in the draft Plan, of which the majority are to come from Green Belt. These 25 sites have a total area of 160 ha, and a total indicative capacity of 3,640 dwellings – a gross density of 23dpha – which suggests a net density of around 29dhpa. If this pattern were to prevail across all greenfield sites, in the plan, then 14,607 homes would require 635 ha.
Consequently, if the brownfield sites achieve 50dpha, but the greenfield sites are developed at the densities which appear to be prevailing in the allocations, then by land area the Plan may only be achieving 37% of housing on brownfield land.
This leads us to conclude that the Plan is not making the most effective use of land, and is not in conformity with NPPF para 137. Indeed, it suggests that the Green Belt land-take may be almost double what it would need to be if density expectations were properly applied.
Consequently, even if the district-wide brownfield rate remained at 50%, it appears that the proposed greenfield land take in the Plan is approaching double what it would need to be if all greenfield development were built to the policy-compliant 50dhpa net. In other words:
- roughly half of all the proposed greenfield land allocation is a product of low densities, not of meeting development need;
- the majority of Green Belt housing allocations are proposed to be developed well below the densities required by the Plan’s policies relating to density.
This being the case, then the exceptional circumstances for Green Belt releases have not been demonstrated, because the resulting allocations will be profligate in their use of land and will directly fail to implement key sustainability policies in the Plan. And we cannot see how the proposed site allocations, taken as a whole, will be suitable for the implementation of key policies in the Plan, especially SP7 on sustainable travel and HO2 on density.
We are not disputing that settlements at all levels of the hierarchy should be enabled to have a quantity and type of development that meets their needs. Furthermore, if some of those settlements are better served than others by public transport, and contain some sites that are more suited than others to implementing 15-minute neighbourhoods, then this does create a justification for adjusting the distribution between settlements to facilitate those sites being developed.
In our view the important first step towards redressing this problem is to measure housing land requirements by land area, rather than by the indicative capacities that are derived from market preference. Calculating land requirements by area in this way is an important, reasonable alternative to the approach currently taken by policy SP8.