Local Plan response.
On February 8th this year, Bradford announced a consultation on their new proposed Local Plan. This is the 3rd time in several years that there has been a change to the plan.
Bradford’s Core Strategy was open to consultation in February 2014 and adopted in July 2017. We then saw changes to the Core Strategy and the council sought comments on the same between January and February 2019. Thereafter in mid-2020 the Council started to prepare a single Local Plan which includes work undertaken to date on the Core Strategy Partial Review and land allocations.
Why not await the 2021 Census?
The Local Plan could take place at any time, providing it is completed ahead of December 2023, so why is there a rush to publish the Local Plan ahead of the 2021 Census? The 2021 Census would better inform council about the district housing need.
Ease of response.
The Local Plan is a complex series of documents comprising of over 9,000 sides of A4. If the Council has attempted to adhere to the governments ‘Planning for the Future’ format, then it has failed to deliver the simplicity that this document requires, – “While the current system excludes residents who don’t have the time to contribute to the lengthy and complex planning process, local democracy and accountability will now be enhanced by technology and transparency.”
The public had 44 days from February 8th to respond to the content of the Local Plan, quite clearly that’s simply not feasible. Many thought it was only prudent to consider their local area when responding to the Local Plan, but this is a misguided approach because we have the following on the opening page of the document:
“1.5.3 The plan should ideally be read as a whole as there are often connections across policy areas and in relation to site allocation proposals.”
Habitat regulations in the Local Plan.
Having focussed on the main plan policies, particularly looking at settlements and policies I had neglected to thoroughly read the Habitat Regulations. Burried deep in the index ‘draft’ of Bradford’s South Pennine Moors Supplementary Planning Document is the fact that there was an unpublished report that was carried out by “Footprint Ecology” back in 2019. Click here for that report.
“Hoskin, R., Panter, C., & Liley, D. (2019). Habitats Regulations Assessment of the Bradford District Core Strategy—Preferred Options Stage (Reg 18) (Unpublished Report for Bradford Metropolitan District Council No. 540). Footprint Ecology / Bradford MDC.”
This unpublished report makes it clear that there are severe pressures on the South Pennine Moors from ALL of the proposed housing: in particular recreational pressures, water issues and especially air quality.
Please note some pressures like air quality are not shown in any of the recently-published Local Plan documents. The HRA started off with the key assumption that these serious impacts on SPA/SAC should be mitigated; and not avoided completely.
I’m continuing my work on the Habitat Regulations, but the Local Plan is now closed for responses.
Bob Felstead – Author
My Local Plan submission: Local Plan report.pdf
Here’s the evidence that’s used to support the Local Plan: Local Plan statistical evidence.xlsx (this replaces the documents shown in the Appendix)