Our ‘Reasonable Alternative’ vision for the Bradford Local Plan – Headlines

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By Andrew Wood

A really important part of the Preferred Options (Regulation 18) stage of consultation is that the Plan needs to show how it has considered and assessed ‘reasonable alternatives’ to the policies it proposes. We feel there is a better alternative to the suggested proposals which grapples with the issues of climate, densities and inequalities. This Bradford Local Plan Preferred Options: A Strategic-Level ‘Reasonable Alternative’ (March 2021) forms our manifesto for the Bradford Local Plan, which will guide our responses during the future stages of the Local Plan Process. A pdf of these proposals is available to read and download.

Bradford Local Plan Preferred Options: A Strategic-Level ‘Reasonable Alternative’ (March 2021)

 

1. The Headlines: Key Features of a Strategic-level ‘Reasonable Alternative’

 

  1. 1.1  If the Council considers it could accommodate an urban centres uplift – which would effectively mean a major shift in housing distribution towards urban Bradford – then there must be brownfield land available to bring forward for it. The reasonable alternative is therefore to plan for that shift in spatial distribution anyway, in order to maximize the use of brownfield land across the district, and thereby to more properly meet the expectations of NPPF para 137.
  2. 1.2  West Yorkshire has a political commitment to net-zero carbon by 2038, which is the end of this plan period. We know that achieving this will require a 21% absolute reduction in car mileage over that period, so this should be adopted as a measurable target for the Plan. The reasonable alternative is therefore to adopt that target, and ensure that strategic, thematic and development management policies all integrate to achieve it.
  3. 1.3  Due to the climate target it is also self-evident that all plan-supported economic development over the plan period must be low or zero-carbon. This means growth related to the Airport is anomalous, and support needs to be specifically targeted at helping priority sectors to decarbonize. The reasonable alternative is therefore a spatial strategy that does not regard the Airport and its access corridor as a growth location, and specifically designs the overwhelming majority of employment land provision to suit the needs of low carbon enterprises and existing businesses wishing to decarbonize.
  4. 1.4  On the basis that any site allocation in the Regional City, Principal Towns or Local Growth Centres must necessarily fulfil policy SP7(1c), all allocated sites must be capable of and suitable for development at a minimum density of 50dhpa. Our initial calculations indicate this would roughly halve the greenfield land requirement, even if the district-wide proportion of 50% of housing on brownfield land were unchanged. The reasonable alternative is therefore to measure housing land requirement by land area, rather than number of dwellings, and to allocate only enough land to meet the housing requirement at 50dpha net as a baseline. Without this it is not possible for the Plan to show that the requirements of NPPF para 137 have been met, to justify Green Belt release.
  5. 1.5  The South East Bradford Access Road is a scheme directly at odds with the Plan’s climate targets and objectives to reduce road traffic, would be uniquely damaging to the Green Belt and would disproportionately harm access to the countryside for the most deprived neighbourhood in the district. It is also conspicuous by its absence from the Plan’s proposals, despite references to its relationship to the Holme Wood broad location for growth. The reasonable alternative is to plan on the basis that this road should not, and definitively will not, be built.
  6. 1.6  There are several aspects of environmental net gain that are required by NPPF but not robustly planned for in the draft Plan. These include enhancing the beneficial use of the Green Belt, and ensuring new development reduces flood risk. The reasonable alternative sets these as strategic priorities for the district.

The Details for this manifesto will follow in the next posts…

Ilkley from White Wells