LDF Draft Core Strategy Objections
The Parish Council objected to a number of specific areas in the LDF Draft Core Strategy and these are detailed below.
In Section 3, p66 in Policy SC7 paragraph B and in Section 5 in Policy HO2 paragraph B3 we objected to
Wilsden Parish Council objects to dismantling of the Green Belt in order to meet housing targets.
SC7 ‘Localised reviews of Green Belt boundaries will be necessary, to deliver longer term housing and jobs growth as set out in Policy HO3 and Policy EC3 in locations that deliver the Core Strategy policies and the strategic patterns of development set out in Policy SC5’.
HO2.B.3 ‘Specific area based initiatives to help deliver the supply targets will include; Local Green Belt releases where consistent with the Plan’s sustainability principles and where other sources of supply have proved inconsistent within the relevant strategic planning sub area’
The reasons for our objections were
5.1.8 [The RSS] states that ‘Growth will be part of a programme that secures the re-modelling and regeneration of the district’s urban areas, making the best and most efficient use of PDL whilst recognising that although the most valued green spaces will be protected there will be some greenfield development in essential locations’. However the Draft National Planning Policy Framework Impact Assessment makes it clear that ‘In all cases the test to preserve the openness and purposes of including land in the Green Belt will be maintained’.
Further to this, the Core Strategy says;
3.129 ‘The Plan seeks to prevent the dispersal of development to smaller settlements and open countryside’ and
2.86 ‘One of the most striking features of the district is the quality of its landscape and in particular the proximity of the main urban areas to areas of high landscape value.’
There is no justification for using green belt on which to build houses except in truly exceptional circumstances. Land so designated prevents urban sprawl and maintains the distinctiveness and character of the villages of the rural hinterland. Green Belt land must not lose its designation in order to appease developers who, experience shows, prefer to build on ‘easy’ sites whilst ignoring derelict urban sites. This would be against the Core Strategy on two counts, 1) it would promote building from the lowest hierarchy up instead of vice versa, failing all the 10 principles of HO1 for achieving Sustainable Housing Growth and 2) it would miss an opportunity to improve the urban landscape and deliver housing where it is most needed.
Our proposed amendment is
Removal of paragraph B from SC7. and to change HO2.B.3 ‘Local Green Belt releases only where consistent with the Plan’s sustainability principles and with the NPPF guidelines’.
In Section 4, p102 in Policy PN1 paragraph C we objected to
Wilsden Parish Council objects to any green belt deletions in the parish council area.
The reasons for our objections were
Unlike much of the Bradford district, development has continued in Wilsden over the last 5 years and as a result the supply of developable land has been exhausted. Since 2008 there have been more than 140 completions and permission has already been granted for another 35 dwellings. Based upon C Tax statistics Wilsden has shown the greatest increase in the numbers of dwellings amongst parished areas of a similar size in the Bradford district in this period.
Deletion of green belt in Wilsden would not protect and enhance the village and the surrounding environment and is therefore in contradiction of Core Policy SC4.
Our proposed amendment is
The Local South Pennine Towns and Villages Sub Area Policy 1 (PN1) should be changed to remove Wilsden from the list of communities in C that will need deletions from the greenbelt to meet housing need. This will result in a need to reduce the number of residential units between 2008 and 2028 to 175.
In Section 4, p101 in Policy PN1 paragraph A we objected to
In the Local South Pennine Towns and Villages Sub Area Policy 1 (PN1) proposes minimum levels of development for South Pennine villages. Wilsden Parish Council objects to the specification of minimum levels for any of the villages of Cullingworth, Denholme, Harden, Haworth, Oakworth, Oxenhope and Wilsden.
The reasons for our objections were
Although the Core Strategy aspires to focus development on PDL and for development to be limited within the South Pennine villages, the detailed policies do not deliver this. Unless there are clearly defined limits to the development levels in these settlements the pressure from developers to focus on PDL will not be controlled and developers will focus on greenfield developments in areas that deliver the highest profits.
Our proposed amendment is
For the overall objectives of the Core Strategy, in terms of protecting and enhancing the South Pennine villages, to be delivered there must be a maximum number set for the total level of development within the 7 villages. The individual number of developments within each community should be set as targets to allow flexibility.
To set minimum levels is a blank cheque to ignore PDL development targets and focus on development in areas that deliver the highest profits.
In Section 4, p101/2 in Policy PN1 paragraph B we objected to
The Core Strategy makes no reference to the protection of settlement boundaries and in particular restrictions on ribbon development between villages. This is already a significant challenge for Wilsden and its relationship with both Harden and Sandy Lane.
The reasons for our objections were
If settlements are joined up, even if only by ribbon developments on main roads, there is a loss of distinct character. This gives the perception that the South Pennine villages are part of an extension of the Bradford City suburbs into the rural areas of the district. This is contrary to the general principles of Core Strategy Policy SC4. Volume 9 of the Landscape character SPD specifically highlights this as a threat to Wilsden.
Our proposed amendment is
The Local South Pennine Towns and Villages Sub Area Policy 1 (PN1) should be modified by inserting a new B3 restricting ribbon development between villages. Based upon the Wilsden and Bradford NW SHLAA there appears to be a major threat to Wilsden in terms of ribbon development between the village and both Sandy Lane and Harden.
To achieve this there would also need to be restrictions to significant greenbelt releases outside the settlement boundaries of Bradford in this area.
In Section 5, p161 in Policy HO4 paragraph B we objected to
Phasing of sites
The reasons for our objections were
The principles laid out 1 to 6 are reasonable, but at present weak through lack of detail.
There is a danger of planning blight caused by unfortunate phasing of sites.
Our proposed amendment is
Phasing of sites should be sequential and dependent upon PDL targets being met (see comment form regarding PDL targets). Previous experience in neighbouring Leeds has shown that where phasing was set as points in time, ‘difficult’ urban sites were ignored by developers who were willing to wait for ‘easier’ green field sites to be phased in. This could not happen if the urban sites had to be developed first.
The Core Strategy also does not consider the likelihood of housing targets not being met. Phasing in greenfield sites as a ‘quick-fix’ may lead to an increased housing stock, but one which does not fulfil any housing need.
In Section 5, p164 in Policy HO6 paragraph B, C & D we objected to
The Core Strategy has weak targets to ensure PDL sites are developed before green fields. The District-wide target is only 50%, reducing to 40% in Principal Towns, 15% in Local Growth Centres, and 35% in Local Service Centres.
The reasons for our objections were
Developers will focus primarily on Greenfield sites in high added value areas unless there are high targets for the use of PDL.
5.2.49 states that ‘the LDF needs to be based on the most extensive search possible for development potential on brown field land’. The SHLAA1 site area parameter of >0.4 hectares predisposes the sites offered toward being open greenfield and it should come as no surprise that (5.2.61) 66% of the land offered under SHLAA1 is greenfield. As PDL often comes in smaller parcels of land, the SHLAA2 search for sites >0.2 hectares will undoubtedly bring in more brownfield sites.
5.2.58 asserts that ‘This [PPS3 60% target for PDL] will be challenging to achieve as it is above the level and proportion that such land makes within the SHLAA land supply. The need for greenbelt deletions further militates against the setting of a higher target level’. The need for greenbelt deletions cannot be demonstrated ahead of SHLAA2, therefore 5.2.30 ‘Results from the SHLAA also show that to meet the scale of the remaining housing requirement will require the incorporation of a significant contribution from currently designated areas of safeguarded land and currently designated green belt’ is premature.
A report commissioned by the CPRE in November 2011 (‘Building in a small island – why we still need the brownfield first approach’) demonstrated that brownfield land is not a finite commodity which is being exhausted, but rather is a recyclable and, over the long term, reliable supply of building land which can be used when there is the desire to do so.
Our proposed amendment is
Unless developers meet robust targets (we suggest 80%, a figure surpassed for all previous years 2004-10) for the development of PDL over the whole period to 2028, greenfield land should not be released except within the current settlement boundaries of Bradford and in the Local Growth Centres. Targets in these two areas should also be tied to percentage of total PDL reserves i.e. no release of greenfield sites until PDL reserves are less than 20% of those identified after SHLAA2 plus windfalls.