Written evidence submitted by Bradford Council
Metropolitan District Council (IRP0046)

Introduction

Bradford Council is the 5th largest City District in England, serving a population of approximately 537,200 in Bradford City Centre, Shipley, Keighley, Ilkley and elsewhere over an area of 141 square miles.  Our economy is worth £11.6bn, and is the tenth largest city economy in England and the third largest in the Yorkshire and Humber region after Leeds and Sheffield.  This year analysis by zero-carbon homes builder Etopia Homes, peer reviewed and supported by global infrastructure advisers WSP Strategic Advisory, placed Bradford first in the Levelling Up Opportunity Index – a league table ranking the 34 largest cities and towns outside of London according to their potential to benefit from the Government’s Levelling Up funds.

Bradford has also been identified as the best place in Britain to start a business, as ranked by Barclays Bank SME Growth Factors Index and was listed as one of the top 20 cities for business growth by the Sunday Times in 2020.  Sector strengths include advanced engineering, chemicals, automotive components and food manufacture alongside financial services and digital technologies.

In Transport for the North’s (TfN) independent Strategic Outline Business Case (SOC) for Northern Powerhouse Rail (NPR), providing a new line from Leeds to Bradford to Manchester was the identified as the top priority and preferred option. 

Further independent analysis by the National Infrastructure Commission’s Rail Needs Assessment for the Midlands and the North recognised that serving Bradford with a new Northern Powerhouse Rail line was the best option to stimulate trade and productivity across the north highlighting that it has “the highest potential benefits of all the packages, both in terms of productivity and trade benefits”

However, the Integrated Rail Plan (IRP) opted not to include Bradford on the Leeds to Manchester link.  This response sets out why Bradford Council is submitting a representation to the Transport Select Committee’s Call for Evidence on the IRP and why Bradford needs to be included on the Leeds to Manchester NPR core network.

We are submitting evidence because we believe the IRP has not considered the following:

1. The economic benefits to Bradford.  TfN’s SOC highlighted that a new city centre station in Bradford on the NPR network would be anticipated to:
1. Generate £3bn additional annual GVA by 2060
2. Create 27,000 additional jobs by 2060
3. Achieve a10% uplift in residential land values
4. Provide access to 1.3m additional jobs within 90mins of Bradford
5. Provide access to 86,000 additional business within 90mins of Bradford
6. Secure £30 bn value of city centre growth and investment
    
2. The opportunity to Level Up Bradford.  Bradford has emerged as the number one levelling up opportunity, indicating it has the strongest case for economic support as part of the levelling-up agenda, as well as significant capacity for new economic growth.
3. The opportunity to maximise the benefit of Government investment.  The National Infrastructure Commission’s Rail Needs Assessment concluded “Prioritising regional links appears to have the highest potential economic benefits overall for cities in the Midlands and the North and would improve many of the currently poorest services.” Rather than focussing on upgrades or prioritising long distances links (i.e. HS2)
4. The opportunity, and need, to improve Bradford’s connectivity to the wider Northern Economy as part of the high growth Leeds – Bradford – Manchester trans-Pennine corridor. Analysis of more than 3,000 real-life train journeys between Britain’s 20 largest cities by Be The Best Communications proved Bradford has the worst rail connections of any major city in Britain.
5. The level of disruption and lack of planning for future demand resulting from upgrading existing lines rather than building new ones.  Achieving the IRP stated aim of 12min journey time between Leeds and Bradford will have a detrimental impact on capacity and a reduction in services at New Pudsey and Bramley stations and services to Halifax. 
6. The opportunity to address the Climate Emergency.  NPR routed via Bradford would provide a viable alternative to car journeys made to/from Bradford along the M62 corridor.  The prohibitively slow train speeds between Leeds and Bradford result in nearly 30,000 people commuting daily from Bradford to Leeds with three times as many travelling by car than by train. To the west, 95% of journeys between Bradford and Manchester are by car. The years of disruption resulting from line upgrades will result in more people travelling by car to avoid the inconvenience of changing between coaches and trains.

Summary

The Integrated Rail Plan fails to deliver the rail infrastructure required to connect Bradford, the 5th largest City District in England and the UK’s youngest city, to the UK’s railway network which means it cannot fulfil its huge economic potential, and it has been left behind as the worst connected major city in the UK.

In a modern and increasingly service-led economy where the vitality of city centres is paramount, and reductions in carbon emissions is enshrined in UK law rail must play an increasingly strong role in meeting regional transport needs. Future rail plans should not be just assessed on whether they meet the requirements of natural growth, but also new trips generated from mode shift and significant agglomeration in our city centres. This submission addressing the call for evidence should be read in conjunction with the review of the Integrated Rail Plan undertaken by WSP for Bradford Council (“What does the IRP deliver for Bradford” - see Appendix A) which challenges its findings and furthers the investment case for a through station in Central Bradford.

     A Rail Needs Assessment for the Midlands and the North (RNA) was drawn up by the NIC. This clearly made a strong case for investing in Bradford and showed how connecting Bradford to other Northern cities on a new through line would be the most beneficial of all the scenarios considered. The IRP has failed to consider how these benefits could be achieved for Bradford. Bradford is left out of both the core and non-core pipelines of work.

     The IRP makes inaccurate statements about the future potential of Bradford.

     TfN had completed significant amounts of work investigating options for serving Bradford. Working together with TfN, DfT and Network Rail, CBMDC had worked hard to identify options which could be delivered sooner, in a modular process taking account of the NIC’s findings in the RNA, to achieve the best outcome for residents and businesses in Bradford and across the entire Northern Powerhouse region.

     Options that placed Bradford on a new through line delivered the best outcome for the 15 million people living in the North as well as for our city. In the TfN preferred network, Bradford would have a much improved, advantageous position on the national rail network with frequent long-distance connections to a wide range of destinations, which would be a significant draw for regenerative change and investment in our city. In contrast, the IRP’s position on Bradford is significantly disadvantageous, as Bradford is still on a branch line from the main network. Its inclusion is reduced to connections to Leeds, with no transformative connectivity implications whatsoever.

     Terms of Reference were set out for the IRP to report by the end of 2020, but these were not followed. The IRP was published nearly a year late and this has led to significant delay and detriment to the Council’s regeneration programmes and levelling up.

     Despite the positive progress and significant amount of work undertaken over the past decade into making the economic and connectivity case for better rail connections for Bradford and the wider north, Government and DfT have ignored Bradford’s potential. As a result, the IRP’s decisions will have a negative impact on more than 500,000 people living in Bradford district, 15,700 businesses, and millions more people across the north.

     Bradford’s ask now in light of the IRP, is for the Government to review its position on the St James’ Market Option to allow further work, and to start explorative work on new connections from Bradford to Manchester in the west as the way of linking Bradford into the rail network, and unlocking the Leeds-Dewsbury ‘IRP Bottleneck’, by providing a new high-capacity through route through Bradford City Centre.

Capacity and Connectivity

Level of Technical Detail

A distinction needs to be drawn between capacity as measured in the IRP, which is understood to be determined by number of seats provided (often per hour); and capacity as considered in railway operational terms, which is the practical capacity of the rail network to accommodate a number of (passenger and freight) services. The IRP does not always distinguish between these and appears to reduce decision-making to seat capacity only, when network capacity is often more important to cater for both freight and passenger services.

Connectivity is usually considered in terms of speed and frequency of passenger services. It is ultimately considered in rail industry processes as a kind of ‘timetable utility’, i.e. how useful different services are for the journeys people want to make, with particular consideration for direct services.

It is very difficult to make an assessment when the technical detail featuring timetables and services frequencies, which sits behind the IRP, has not been provided. This makes it difficult to scrutinise whether the IRP is ‘operationally deliverable’ in accordance with the Terms of Reference but it is already apparent that decisions taken in the IRP do not achieve the highest benefits in terms of productivity and trade to deliver the best outcome for the 15 million people living in the north of England.

Bradford and NPR

City of Bradford Metropolitan Council (CBMDC) has consistently put a case forward for new and improved rail connections to Bradford, to restore connections that were lost in the 1960s and to gain faster connections to other northern cities. Bradford is often cited in the media for its poor rail connectivity https://www.bbc.co.uk/news/uk-england-leeds-59281221 .

In 2017, Bradford launched the Next Stop Bradford campaign to bring NPR to Bradford City Centre (https://www.nextstopbradford.com/) alongside the development of economic evidence and the Bradford Northern Powerhouse Rail Growth Strategy to make the case for a City Centre NPR station.

Key among the city’s ambitions are faster connections to Manchester, Manchester Airport, Liverpool, Sheffield, Nottingham, Wakefield, York, Hull and Newcastle. Services to most of these cities require a change and journey times are long and uncompetitive with road.

The monthly Bradford Northern Powerhouse Rail Board (formed in 2017) was set up to work in partnership to develop the case and programme collaboratively. DfT, TfN, WYCA and Network Rail are key members of the Board. The Council has been working collaboratively with these partners to prove the strong case for serving Bradford with NPR during this time. All partners gave their support to Bradford council selecting St James Market as the preferred option based on clear evidence.

Options Assessed

Optioneering had identified a range of different options for serving Bradford on a new line between Manchester and Leeds. There were three possible options for a Bradford NPR station, which were:

• Bradford Underground (D), a tunnelled station below Bradford Interchange
• Bradford Gateway (E), a surface station located on a reopened Dudley Hill Branch. However, due to the horizontal and vertical distance between this and the city centre, an option was proposed and had also been evaluated by TfN, namely on the site of the current St James Wholesale Market, itself formerly a railway station.
• Bradford Parkway (C), located near Low Moor.

Figure 1:Bradford central station locations analysed, Arup, 2020. Bradford Underground (D) is shown in blue Bradford Gateway (E) is shown in crimson; St James Market option is shown in orange,

After a sifting workshop in September 2020, when development work on the St James Market option was progressing, three options were taken forward for further development and other options were discounted.

The retained options were:

• an upgrade of the existing route via Diggle (referred to as Option 1 in the IRP), with a cut-off between Ravensthorpe and Leeds. This was retained purely as a low-cost alternative as it did not conform with TfN’s strategic objective of serving Bradford.
• a new alignment via Bradford Gateway (E) (Option 2), which consisted of a mostly underground new line between Bradford and Leeds, a surface station in Bradford (whereby further development work would be undertaken on the St James Market Option), and continue as a new line to Manchester.
• a new alignment via Bradford Underground (D) (Option 3), which consisted of a new line between Bradford and Leeds as above, but would remain underground through Bradford and continue as a new line towards Manchester.

As a consequence of the other options being discounted, a station at Bradford Parkway (C) (near Low Moor) was no longer to be considered.

Figure 2: Bradford to Leeds intermediate sift options, Mott MacDonald, 2020

St James Market Option

The perceived benefits of the St James Market Option station are manifold:

• It is only a short distance from the existing Bradford Interchange station, at about 400m.
• It is within the defined city centre boundary, and serves the city centre well
• It has the potential to accommodate a through station to ensure efficient rail operation, and is the closest location to the city centre to be able to achieve this
• It can be built at or near ground level, ensuring that cost would remain comparatively low and that future expansion could be done cheaply.
• The site is within Council ownership and control,
• As the wholesale market’s expansion could not be accommodated on the present site, plans are being made for its relocation, ensuring that the site would be made available rapidly to start works for a new station.
• The site was formerly connected to the railway network
• The St James Market station option would enable co-location between Calder Valley and NPR services, at the same time as remaining in the city centre, which no other option offers, maximising its rail network utility and journey and interchange opportunities for passengers
• The station would have enabled services to switch between conventional and NPR lines in times of disruption, thus allowing flexibility in operations
• The construction could be undertaken as part of significant regeneration in that area which would also see changes to the highway network to lessen or remove this barrier to pedestrian movement
• The option offers good connection opportunities with Mass Transit options already under investigation, for which work has been underway since 2019.
• The new station would be pivotal in regenerating Bradford’s Southern Gateway with a development area three times larger than Canary Wharf.

Bradford Council in partnership with Arup have also undertaken a review of potential station locations, as a first stage in creating a Masterplan to maximise the benefits brought by new rail connections, as advocated in the RNA. The station locations were assessed based on criteria identified as part of the master-planning exercise. Each station was given a RAG rating based respectively on a low, medium or high potential to deliver on each criterion.

Table 1: Assessment of different Bradford station options based on Masterplan criteria, Arup 2020

This review was complete by October 2020 and examined the potential for each of the different options. The report was also shared with partners including WYCA, the DfT and TfN. As a consequence of this work, Bradford Council made public its preferred option for a new station on the site of St James Market in March 2021 with accompanying press release. The Council’s preferred option was thus Option 2, with the caveat that the station site was the St James Market Option.

A variety of options were assessed by TfN which included different levels of service provision at Bradford. The most ambitious offered 6 trains per hour on a through route between Manchester and Leeds. The least ambitious offered 4 trains per hour between the same points but running slower. A further option featured no services to Bradford at all.

TfN had given a strong preference to serving Bradford on a new Leeds-Manchester NPR line and has repeatedly given this statutory advice to Government. Only the least ambitious proposal put forward by TfN did not resolve Bradford’s connectivity asks, this being the proposal which provides no services to Bradford at all.

In November 2020, TfN leaders Board agreed the new line between Manchester, Bradford and Leeds as the preferred NPR Route with a gateway station at Bradford. This was agreed with the caveat that further work would be undertaken to locate the station as near the city centre as possible. St James Market was and remains the strongest location for the station.

IRP Chosen Options

Bradford

The IRP does not retain any of the options serving Bradford identified above.

Nor does it retain the infrastructure in the cheapest option; the IRP has not retained any of the NPR options. As a result, Bradford will not have direct, fast services to any UK city other than possibly Leeds despite the size and significance of Bradford as the UK’s fifth largest Metropolitan District. .The rail thinktank Greengauge 21 have said that NPR is ‘largely abandoned’ .

On the basis of the different options which were assessed, the IRP’s chosen options delivers an extremely poor outcome for Bradford. The abysmal position in which this puts Bradford cannot be underestimated. It is the equivalent of abandoning the 5th largest city district in England to a future of managed decline.

The IRP’s chosen options for Bradford shows short-sighted thinking.

Retaining Bradford Interchange significantly restricts future service growth from the City. Without extra investment on top of the IRP to separate out service patterns, Bradford will not be able to accommodate many additional services. As the station is a terminus and most services run through by reversing at the station, this creates an exponential increase in timetable conflicts as services increase, with decreasing reliability for each additional service.

The network capacity benefits of the Bradford options in particular seem to have been disregarded. Bradford on a through line would have avoided forcing all trains through the ‘Leeds-Dewsbury IRP Bottleneck’.

The IRP proposes to electrify the existing Bradford to Leeds rail line . This promises to deliver a 12 minute journey time between Bradford and Leeds, which is considered impossible to deliver without sacrificing existing services on this line, not just for stations like Bramley and New Pudsey but also services from Halifax and beyond. The IRP provides no explanation for this. Bradford Council has repeatedly called for upgrades and electrification to the Calder Valley Line in full, but this has never been at the expense of NPR and the two projects are entirely distinct. It is unlikely that services would be able to be split at Bradford, because this would mean a reduction in services to Halifax. The IRP’s chosen options for Bradford would reduce connectivity and would impose lasting capacity constraints on passenger and freight services.

Outside Bradford

Capacity constraints at Leeds station currently prevent growth in rail services from Bradford. It is therefore important that capacity issues at Leeds (taking into account the different programmes) are resolved.  The IRP states plans for the West Yorkshire Mass Rapid Transit (MRT)system must consider how services could be removed from Leeds station to use this system. It is unlikely that MRT could provide an adequate replacement for heavy rail in terms of capacity, journey time and journey quality.

The curtailment of the Manchester-Leeds new line at Marsden is problematic for rail system capacity in the north and this will affect services across the country. This creates a 2-track ‘IRP bottleneck’ between Dewsbury and Leeds which will severely restrict service development on this section. If NPR had been selected for implementation in full then this could have been avoided.

The IRP does not deal with current capacity pinch-points or offer scope for these to be resolved. For services to Bradford, the lack of capacity at Manchester and Leeds railway nodes have prevented new Bradford services (in the pipeline since 2016) from being introduced, in particularly the Northern Connect Bradford-Leeds-Sheffield-Nottingham, Bradford-Manchester-Liverpool and Bradford-Manchester-Manchester Airport.

Levelling Up Communities

In our attached review of the IRP, ‘What does the IRP Deliver for Bradford?’ (Appendix A), we consider how the IRP will contribute to levelling up in Bradford.

Bradford emerged as the number one levelling up opportunity, indicating it has the strongest case for economic support as part of the levelling-up agenda, as well as significant capacity for new economic growth when ranked against 34 of England’s biggest cities, as measured using the new “Levelling-Up Opportunity Index” (see Table 1 below)

Table 1: Bradford’s case against the Levelling-Up Opportunity Index

In the NPR Bradford Growth Strategy, we show how investing in NPR to Bradford will unlock significant growth at different geographic levels:

Having an NPR stop in Bradford City Centre would deliver:

• 670,000spm extra commercial floorspace,
• 8,500 further sustainable housing units in the city centre
• £61M land value uplift returns
• £119M additional business rate returns

The table below shows the outputs of economic work undertaken by TfN supporting the Strategic Outline Case for Northern Powerhouse Rail, demonstrating the wider benefits of an NPR station in Bradford.

Table 2: Wider Economic Benefits from a new central NPR station in Bradford, NPR SOC 2021

This demonstrates how NPR would have been transformative and strongly contributed to local, regional and national growth and levelled up communities by re-balancing the economy.

Mott MacDonald’s recent report "How to kickstart a northern renaissance" assessed that a Leeds-Bradford-Manchester line would:

• Increase productivity by 6%
• Raise the employment rate by 1.5%
• Increase GVA in the north by around 8% over 10years (the equivalent to a £22bn GVA uplift by 2060)

The IRP had the potential to invest in an NPR through line at Bradford. This increase in connectivity would have had a strong effect of reducing disparity and levelling up the many communities in Bradford which are classed as deprived. The consequence is that investment in Bradford has a disproportionately positive impact. As of a 2019 report, Bradford has the 11th highest proportion of most deprived neighbourhoods, with more than one third of Bradford’s areas (LSOAs) classed within the 10% most deprived nationally, worsening since 2015. Despite the NIC recently concluding that “transport is the sector with the most opportunity for helping to reduce disparities between places”, the IRP doesn’t consider the potential NPR investment in Bradford would have for Levelling Up the City.

The IRP argues that routing NPR via Huddersfield rather than Bradford should be based on population served rather than the economic benefits of the investment. Bradford suggest that this is an inappropriate representation of the economic potential of serving Bradford as it doesn’t take into account the transformative economic, regeneration and labour market impacts, population catchment, transport and suppressed rail demand among others.

It is Bradford Council’s view that IRP doesn’t take future upgrades and network expansion into consideration. This is both a departure from what the evidence base shows, and to the approach put forward by the NIC, which was to:

• Identify the funded investments
• Identify further opportunities that could be funded based on value for money later.

Another reason for the IRP proposing not to progress a station at St James Market is that it is located on the wrong side of a “six lane highway”.  It disregards work carried out by TfN showing how Wakefield Road could be traversed. The Terms of Reference for the IRP also stated that Government will consider the development of different options in reaching its conclusion.  They have not given TfN, CBMDC and partners the time or funding to further elaborate the St James Market station option. The remaining Master-planning funding of £400,000 announced through the West Yorkshire devolution deal has been held back by Government pending the IRP.  This has prevented Bradford from being able to fully demonstrate the solutions to the issues raised.  Not including the St James Market option is not consistent with its stage of development or its potential to meet future needs (demonstrated by work carried out by Arup for TfN).

It is clear that Government has decided on an NPR network based on cost rather than on any economic and Levelling Up basis.

As the Conservative MP Kevin Hollinrake says: “An example of that is the Integrated Rail Plan and Northern Powerhouse Rail in particular, I think that is a false economy and I think we should look at that again and make sure we don’t start trying to cut corners on the basis that we’re spending a lot of taxpayers’ money. “Investment spending is a different kind of spending which is good for taxpayers and will ultimately reduce the burden on taxpayers.”

Supporting the Regeneration of Southern Gateway

Bradford Council is planning a new 150ha Southern Gateway regeneration Area (nearly 6 times larger than the Kings Cross regeneration area).  The St James Market station would be centrally located in this area and through the regeneration of the Southern Gateway, Bradford is looking to achieve impacts in six key areas: investing for return, transport improvements, creation of a new health quarter, resetting the housing market, supporting the cultural renaissance of the city and the 2025 ‘City of Culture’ bid and driving forwards the Net Zero and Clean Growth objectives of CBMDC (see Appendix A for further info). It is central to Bradford’s future growth plans and been identified in the draft Local Plan as having capacity for at least 2500 dwellings which, combined with new commercial and community uses, will create a new environment for a carbon zero city centre and urban living. 

It is estimated that employment activities in Bradford City Centre generate in excess of £0.95bn per annum in GVA, compared to £0.29bn in Southern Gateway. This provides a stark illustration of the current economic productivity of the regeneration area compared to its potential if unlocked through the creation of a new city centre station. The  overall estimated value of growth and investment in the city centre resulting from a new station in the Southern Gateway would be £30bn.

Infrastructure and Services outside the Midlands and North

The building of infrastructure which is due to be constrained in its operation on opening will present timetabling constraints that prejudice timetables in other areas of the national network.  A solution will still need to be found for Leeds station as a key node on the national network, to enable service level growth and prevent operational delays propagating.

In Appendix B we outline how well the IRP meets its Terms of Reference and how it will have a negative and long-lasting impact on the prospects for future rail enhancements.

Challenges to Delivery

The NPR plans have been carefully developed over 7 years since the 2014 Higgins report. The IRP has not considered Local Growth Plans (as advised in the RNA), this is very challenging for Bradford Council as we have planned our City’s development on being on the NPR network (e.g. as articulated in our Draft Local Plan  Given the importance the Council puts on a driving regeneration through the development of a new through station at St James and the connectivity benefits this brings, will continue to make the case and push for delivery of the proposed NPR infrastructure in Bradford.

The IRP has been developed independently of local growth plans (particularly Bradford’s and Leeds’s), and local stakeholder aspirations, contrary to the direction set out in the Rail Needs Assessment.  It will therefore not gain a suitable level of stakeholder support and will be difficult to deliver.  We outline in Appendix C how the IRP performs and against the RNA

It is important that Great British Railways (GBR, when instituted) be given the responsibility for delivering the IRP, overseeing the core pipeline and adapting it as necessary, to ensure holistic planning within the rail industry. GBR as an overseeing body with local accountability, has the potential to regroup the disjointed planning processes for future services and ensure value for money for the taxpayer sooner.

Interaction with HS2

Phase 2a and 2b of HS2 was included for consideration in the IRP. Bradford express doubt over the turnback configuration at Manchester Piccadilly. It is likely that this will be a severe operational constraint, limiting further service development. The IRP is incorrect in its statement that it is acceptable and that other European cities have this arrangement. Many cities have gone to great expense to remove city-centre turn-back stations because of the operational constraints they impose, such as through the Stuttgart 21 project, the Wien Hauptbahnhof project, and future plans for the Marseille LNPACA scheme, or for Frankfurt.

Scheme Selection

It is apparent that cost, rather than coherence and overall benefit, appears to have been the main factor the IRP used when selecting its chosen NPR network.

Bradford appears to lose out due to cost inflation on other railway schemes.

The IRP’s chosen rail schemes were selected with no input from local stakeholders, in direct contradiction to the main statutory advice, and also in contradiction of the criteria of the main recommendations for the IRP’s decision. In this sense, the IRP has failed because it cannot draw consensus.

There is little assessment of what types of schemes could procure the best return in the face of a constrained budget. The budget for these improvements is not as advertised, but will the actual amounts spent in the north will be much lower (~£46bn). The National Infrastructure Commission has advised that much higher spending was advisable.

Value for Money

Capital investment is an investment in the economy of the future and will deliver benefits over its lifetime. The NIC’s assessed option of serving Bradford via an NPR new line would have delivered the most benefits of all the options and very strong value for money.

Bradford loses out from the unwillingness to show more flexibility on the specification as has been done on other major rail schemes, as we set out in Appendix B.

Concluding Statement

As we show in our evidence, the IRP’s position on Bradford is not only of detriment to Bradford but also the north of England as a whole, missing out on the opportunity to unlock the £30bn economic potential of the 5th largest City District in England and connect the youngest population in the UK to employment opportunities across the North and UK.

In order to remedy this, the Council proposes:

• That the Government acknowledge Bradford’s position of being uniquely disadvantaged by the IRP 
• Reconsideration of Bradford on the NPR Route with plans to integrate the city fully into the NPR programme.
• Commit to further development work on the St James Market Option to bring forward a new through station for Bradford as soon as possible with the potential for it to be delivered by 2030
• Commit to reviewing the IRP’s position, in particular for
• Work on St James Market is our first ask for resolving the need for a through station and Bradford being properly connected on the National rail network.
• A new connection from Bradford westwards, to link to the NPR towards Manchester
• Undertake more work to improve the specification for Bradford-Leeds to allow significant improvements in both fast and local services

January 2022

Appendix A: The Case for Reconsideration of NPR in Bradford “unleashing the power of place, place and business”

City of Bradford Metropolitan District Council (CBMDC)

The Case for Reconsideration of NPR in Bradford

Sub-title

January 2022              Confidential

City of Bradford Metropolitan District Council (CBMDC)

The Case for Reconsideration of NPR in Bradford

Type of Document (Version) Confidential

Project no. 70082240

DATE: January 2022

Confidential 

Quality Control

Contents

What does IRP deliver for Braford?

The IRP fails to deliver transformational investment for Bradford

The IRP fails to address Bradford’s lack of connectivity and support the City’s growth ambitions in three major ways:

1. Connectivity to Leeds – Whilst the IRP proposes improved journey times to Leeds compared to business as usual (BAU), the feasibility of achieving 12-minute journey times remains unproven without a reduction in the service provided to Bramley and New Pudsey. IRP also fails to achieve what could have been delivered under TfN's preferred option for NPR and the electrification of the line will cause significant disruption compared to the preferred offline solution. Similar issues were observed on the WCML upgrade.
2. A New City Centre Station – The creation of a new station which can enable a through line has been endorsed by Network Rail, TfN, WYCA through 5 years of work with CBMDC on NPR routing options to reach a consensus view on improving Bradford’s connectivity. During this time CBMDC has convened a monthly Bradford NPR board with strategic partners (NR, WYCA, TfN and DfT) to ensure alignment on progress. IRP also fails to recognise the critical importance of a new station within the St James Market site to unlocking the regeneration of the Southern Gateway growth area and levelling up Bradford. A new, city centre station, is critical to enabling the City to deliver its strategic growth ambitions in terms of attracting inward investment, reinvigorating Bradford’s housing market and creating a new city centre district, supporting its cultural renaissance and clean growth objectives.
3. Improved Connections to Manchester and Further West – The IRP does not meet the needs of Bradford for better connections further west to Manchester, and beyond to Liverpool. A through station is vital to overcoming the timetabling issues to the wider network, which the current interchange station causes. It fails to connect Bradford’s large, diverse, young, fast-growing and digitally capable population to labour markets within the Northern Powerhouse and fails to deliver for Bradford’s business base and their access to new talent pools. Better connectivity is critical to enabling Bradford to achieve its clean growth and Net Zero targets and journey times remain the same under IRP as they do today under a ‘Do Nothing’ scenario.

Connectivity and capacity of Bradford’s rail connections remain poor under the IRP proposals

NPR

TfN's preferred option for NPR proposed a direct high speed rail line between Leeds and Manchester via Bradford. Following implementation, all fast services would be routed via this alignment, providing Bradford with new direct connections to cities such as Liverpool, Birmingham, Newcastle etc., and Manchester Airport, as well as significantly faster and more frequent connections to Manchester and Leeds.

IRP

The Integrated Rail Plan (IRP) has rejected the Leeds-Manchester line on the grounds of cost and potential journey time savings. Instead, it proposes to upgrade and electrify the line between Bradford and Leeds giving a non-stop journey time of approximately 12 minutes. Crucially however, Bradford now does not benefit from enhanced connectivity to cities other than Leeds.

Additionally, NPR services will share track with local services on the 2-track alignment between Dewsbury and Leeds under the Manchester to Leeds via Huddersfield option, creating a 'bottleneck’. A through route via Bradford would have unlocked this bottleneck and alleviated congestion on the route.

The IRP proposals therefore fail to deliver for Bradford, but also fail to deliver the required output for the proposed NPR services themselves.

Scheme Comparison

The IRP potentially delivers journey time savings between Bradford and Leeds (up to 40% quicker – subject to business case) but fails to improve regional connectivity to the wider NPR network and core cities within Northern Powerhouse.

Journey Times

Figure 4 - IRP vs NPR Scheme Comparison

Train Frequency

IRP fails to recognise the preferred station option

The preferred station option sits within the heart of the Southern Gateway

The three potential station options are presented in Figure 3. CBMDC and WYCA’s preferred NPR option is Option 2: St James Market. Figure 3 demonstrates the spatial location of the proposed NPR station in the context of the Southern Gateway regeneration area.

The St James Market station would integrate NPR and Calder Valley railway services, reducing journey times on these lines to destinations such as Halifax. The station would include a new bus interchange creating a new integrated transport hub with mass transit and other modes. The replacement of Bradford Interchange would also unlock a major redevelopment site within the City Centre.

It illustrates how the position of a new NPR station within the heart of the regeneration area would serve as a catalyst for the economic and social regeneration of Bradford City Centre, which would be expanded to include the Southern Gateway within the Local Plan.

As a new transport hub within the city centre, the preferred station location would deliver significant opportunity for change and creation of a new vibrant and connection place for new homes and businesses within the City.

In addition, the new station is located less than 500m away from the existing Bradford Interchange station, demonstrating its close proximity to the city centre. The preferred station also includes active travel infrastructure to enhance Bradford’s multi-modal trip offer.

Figure 5 - Bradford NPR Station Options

Source: Arup (2020)

Specific Points of Challenge to the IRP

Extract from the IRP

The scenarios tested indicate there is no demonstrable business case for a new underground station in Bradford. The existing Interchange station site has an excellent central location and integrates well with the existing bus station; however, the approach and orientation lead to slower journey times. A new surface station at the St James’ wholesale market site, Bradford Council’s proposed solution, could offer journey time savings, and facilitate wider regeneration.

Points of Challenge

There is a significant body of work, which has been undertaken since 2020 with TfN, to examine the technical feasibility of accommodating a new surface station within the St James Market site. This station option provides an offline solution, on council owned land which can be delivered at pace before 2030.

This option has been the direction of travel for the NPR Board, convened by Bradford and including TfN and DfT, of which all partners have been supportive. TfN have undertaken work on this option to make the case for it with support from partners and it represents the preferred Bradford station option for the Manchester to Leeds NPR route.

The IRP fails to recognise the advanced nature of this route option in its consideration of the NPR proposals, including the consensus reached on the St James’ Market site with TfN.

Extract from the IRP

However, it is separated from the centre of Bradford by a major 6-lane highway (Wakefield Road) and risks poorer interchange with other local rail and bus, services without additional unfunded interventions. A station on the former avoiding line to the south would be further from the city centre than St James’s Market and would likely require some further local transport investment to make it viable.

Points of Challenge

The IRP does not consider the location of the station in the context of the Southern Gateway regeneration area. The Southern Gateway is a major growth area for the city and represents an extension of Bradford City Centre. This will be delivered through transformational mixed-use regeneration of existing underutilised industrial land. The St James’ Market station is not recognised as a catalyst for this expansion and growth within Bradford City Centre.

The change of use in the Southern Gateway area from an under-utilised industrial area with high vacancy levels to a vibrant new extension of the city centre with 2,500 new homes, improved employment spaces, public realm, conveniences, and amenities, will change the movements within the city and put many more people in the direct vicinity of the station.

Additionally, strategic improvements to reduce severance and impact of major highways (such as Wakefield Road) within the Southern Gateway, are not given due consideration in the IRP in their determination of station options. The IRP also omits the consideration of proposed active travel infrastructure as part of the new station to tackle its separation from the centre of Bradford. CBMDC was previously allocated £400,000 within the 2020 Spring Budget to undertake comprehensive masterplanning and transport appraisals of the St James Market site but these funds were not released by Government.

The IRP itself acknowledges the journey time savings and regeneration potential of a new station at St James Market, however it discounts it based on the perceived distance from the city centre as it currently stands.

Extract from the IRP

We will also upgrade and electrify the line between Leeds and Bradford giving a non-stop journey time which could be as low as 12 minutes.

Points of Challenge

Network Rail have been asked to take forward electrification of the line between Bradford and Leeds however, the IRP acknowledges that the achievement of 12-minute journey times is still subject to business case.

It is very doubtful whether 12-minute journey times could be achieved without a reduction in stopping services at New Pudsey and Bramley. Additionally, the IRP fails to acknowledge the level of disruption that electrification of the existing line and existing station will cause, compared to the ‘offline solution’ proposed within the NPR and the construction of a new city centre station at St James Market.

Electrification of the line will be disruptive for very little benefit as the current service patterns, which are constrained by Leeds, have only through services at Bradford which will not benefit from the electrification.

Extract from the IRP

In Bradford, the IRP retains a conveniently located city centre station, and links it more quickly to Leeds.

Points of Challenge

The IRP states that the proposals retain a city centre station with quicker links to Leeds. CBMDC has transformational ambitions for a new city centre integrated transport hub which could not be accommodated within the existing interchange station. The proposed St James Market station is located less than 500m from the existing Bradford Interchange (~6-8 minutes walking distance) and therefore maintains the accessibility of the city centre to rail connections.

The St James Market site is proposed to be an integrated transport hub, joined up by mass transit to Forster Square station, the bus network, and walking and cycle routes. Furthermore, the regeneration of Southern Gateway will be an extension of the city centre and will be accompanied by public realm and active travel improvements promoting sustainable travel modes.

Extract from the IRP

We carefully examined the other options put forward by TfN, for full newbuild lines from Liverpool to Leeds via Manchester and Bradford. They would have made Manchester - Leeds journeys only four minutes faster than the option we have chosen and cost an extra £18 billion.

Points of Challenge

IRP fails to consider the full extent of economic benefits which a direct Manchester to Leeds via Bradford NPR option delivers, beyond traditional journey times savings. The Bradford NPR route option delivers a considerable amount more capacity (more than double what the IRP proposes, roughly 150% more capacity for Leeds to Manchester), and critically connects Bradford to other Northern cities.

Previous analysis by Systra JMP in 2016, found that Bradford City Centre was the best location for an intermediate station between Manchester and Leeds based on economic analysis which suggested an additional station would contribute £116m per annum in net additional GDP compared to <£100m per annum with a Huddersfield station.

Extract from the IRP

Bradford, Nottingham, Derby, and other towns and cities could see more frequent and faster services to more places, sooner than under previous plans.

Points of Challenge

The IRP does not substantiate this claim within the proposals. Aside from the electrification of the line to Leeds, the IRP does not identify any other interventions or proposals which will generate increased services to Bradford. These identified services are heavily dependent on upgrades to rail infrastructure at Manchester and Leeds, which are not committed to in the IRP.

The IRP programme identifies that Leeds-Bradford will be electrified by early 2030s. However, within the NPR proposals, the TfN programme stated that a new city centre station could be delivered by 2030 and the new line between Leeds and Bradford delivered in 2030-2035. The IRP proposals therefore bring forward the benefits for Bradford slower than that proposed within NPR.

Extract from the IRP

Considering the choice between Bradford and Huddersfield. Bradford Metropolitan Council’s area has a greater number of people than Kirklees, the district around Huddersfield and Dewsbury, but around 23 per cent of them live in communities such as Keighley and Ilkley which are some distance from Bradford itself. Because of the design of Options 2 and 3, they would not be connected to an NPR station in Bradford by rail (though they will be directly connected to the NPR station at Leeds). At Dewsbury and Huddersfield, NPR would use the existing stations, which are in the town centres and well connected to other public transport routes.

Points of Challenge

The IRP references that in terms of local authority districts, Bradford has a higher population density, however it is claimed that a significant proportion of the population live outside of commuting distance of Bradford station in comparison to that of Huddersfield and Dewsbury.

The city of Bradford Metropolitan District contains approximately 540,000 people compared to 440,000 people in Kirklees as a whole. It is estimated that City of Bradford contains approximately 360,000 people, compared to 170,000 in Huddersfield and 77,500 in Dewsbury. This indicates that a new station within Bradford could potentially serve 1.4 times as many residents as Huddersfield and Dewsbury combined.

Bradford city centre is a large hub for the local public transport network. The Mass Transit scheme which the government has endorsed through the IRP, will connect a new St James Market station to the North of the district.

The evidence suggests that a new station at St James Market with direct connections to both Manchester and Leeds, would have a greater impact on a large number of people compared to the proposed IRP option of Leeds-Manchester via Huddersfield.

The choice of Bradford would also benefit people living along the Calder Valley Line in Halifax, Hebden Bridge and Todmorden among others.

Extract from the IRP

On the Preferred Option: The Government considers that this approach could:

• Deliver IRP strategic objectives and benefits sooner, including decarbonisation of the key Trans Pennine corridor;
• Improve Bradford–Leeds sooner;
• Better improve connectivity between more of the West Yorkshire towns and cities; and
• Offer better value for money than alternative costlier packages of investment;

Points of Challenge

The IRP has a strategic objective to ‘improve transport capacity and connectivity’ through addressing major capacity, frequency and speed shortfalls on the existing network. The IRP fails to deliver against this strategic objective in its proposals for connections between Manchester and Leeds via Huddersfield as it creates the 'IRP Bottleneck’ between Leeds and Dewsbury, significantly limiting the number of trains that can be run.

Two other core strategic objectives of the IRP are to ‘grow and level up the economy by creating opportunities for skills, employment, agglomeration and regeneration’ and ‘reduce environmental impacts by supporting…modal shift for passengers’.

The IRP proposals do little to level up Bradford in line with the rest of the UK. Transport connectivity is one of the most important factors in increasing the productivity of an economy and generating agglomeration economies through reductions in the cost and time of travel between economic centres of activity.

The National Infrastructure Commission’s Rail Needs Assessment also recommended that a new line from Manchester to Leeds via Bradford be considered given the level of benefits a new line would deliver.

Similarly, the IRP does not encourage the modal shift of movements between Bradford and connections to the West (Liverpool and Manchester). If Bradford is to contribute to UK Government’s Net Zero agenda, then connectivity between the City and core cities within the Northern Powerhouse need to be improved. Using the M606 as a proxy for journeys between Manchester and Bradford, it is observed that approximately 60,000 car journeys are made on this route per day.

IRP states that the proposals will improve connectivity between more of the West Yorkshire towns and cities.

1. There is a significant level of demand within Bramley and New Pudsey stations. The IRP fails to acknowledge that improved connectivity between Bradford and Leeds, is likely to lead to a reduction in services at both these stations. To achieve a 12-minute journey time between Leeds and Bradford there will be have a negative impact on Generalised Journey Times (GJT) due to lower service frequencies and demand associated with GJT reductions at these stations. According to the Office of Road Rail, Bramley and New Pudsey attracted over 350,000 and 830,000 trips, respectively in 2019/20.
2. It should be acknowledged that the WY Mass Transit (WYMT) scheme is not an alternative to investing in the strategic rail network and CBMDC and WYCA are both agreed that both are needed to improve connectivity within West Yorkshire. NPR is a fast connection between major centres, whereas WYMT is about improving local connectivity with frequent stops, both of which will be required to achieve modal shift.

Making the Case for Investment in Bradford

Bradford has a strong and growing workforce

Bradford is the UK’s 7th largest city in population terms. However, it is also the 7th least qualified city overall with 12.3% of the population holding no qualifications and is ranked the 6th lowest UK city overall in terms of economic activity (only 69.1% of 16–64-year-olds are economically active).

There are, however, significant areas of opportunity which need to be capitalised on:

• Bradford has the highest concentration of advanced engineering and materials jobs in the UK and the 4th highest number of manufacturing jobs;
• Bradford has a relatively young population with 29% of residents under 20 years old. Education plays an important role in Bradford with key institutions such as the University of Bradford offering excellent opportunities;
• It is estimated that by 2024, a total of 24,000 new residents of working age will be living in the city, compared with 2021;
• It is home to well-known business institutions, including WM Morrison Supermarkets, Yorkshire Building Society, Provident Financial, Santander, and Yorkshire Water;
• There is a growing digital sector within the City; and
• Bradford was identified by the Barclays Bank SME Growth Factor Index (2021) as being the best place in the country to start up a business.

These residents and businesses have the potential to significantly drive Bradford’s growth in the future, but incentives, such as access to jobs, are needed in order to retain them in the City.

Currently, Bradford experiences poor rail connectivity, with Bradford the largest city in the North of England to not be served by the National North-South main lines or the regional Trans-Pennine lines.

Poor connectivity has held back the competitiveness of the City and its full economic potential. Bradford’s growth continues to be constrained by its accessibility and the ability of its population to access employment opportunities within the West Yorkshire region and beyond (Manchester and Liverpool city regions).

In order for Bradford to utilise its true economic potential, attract and retain a young, skilled population, and showcase its diverse population it needs to be better connected to the productive economic region within which it is situated.

Missing the Mark – IRP fails to consider Bradford’s true economic potential

Productivity: Bradford’s productivity lags behind that of the Northern Powerhouse core cities and significantly behind that of the national average. Improving the productivity rate to align with the regional (Yorkshire and Humber) average would generate approximately £0.5bn in additional economic activity (GVA) per year.

Figure 6 - GVA per Filled Job (Productivity)

Source: WSP Analysis (2021), ONS (2021)

Bradford has the youngest population of any City in the UK with 35% of the population under the age of 25 compared to the national average of 30%.

Bradford’s population will grow to 552,000 people by 2030

Bradford benefits from above average concentrations of high-value production businesses and employees across food manufacturing, engineering, chemicals, digital technologies, energy and utilities. There is growing evidence that a number of new niche sectors are beginning to develop, particularly in new media and telecoms.

Bradford has a strong entrepreneurial economy, 4.9% of those employed as self-employed, compared to 2.0% in Leeds and 3.2% in England.

In total 10.3% of Bradford’s population holds no qualifications. Bringing the qualification attainment rate up to the national average would upskill an additional 13,500 working age persons within the labour force.

Bradford needs greater connectivity to support its strategic growth ambitions

A study by People, Places, Policy and Data Unit agency in 2021, found that Bradford has the worst rail connections of any major British city – identified through analysis of 3,000 train journeys across 20 UK cities.

The IRP was announced in November 2021, offering £96bn to ‘transform connectivity’ in the UK. The proposals however represent a significant downgrade on the preferred NPR option.

This plan no longer includes placing Bradford on the main rail network, which many considered a pivotal part of the NPR – this was initially proposed by Transport for the North (TfN) but has now been omitted from the Government’s investment plans for NPR.

This finding proves that for the IRP to solely speed-up existing journeys through electrification would fail to address Bradford’s real connectivity issues – the lack of direct routes and lack of connections to the main rail network linking Bradford with regional centres such as Manchester and Liverpool.

An NPR station within Bradford would have driven substantial increases in accessible jobs to the City’s population. The result of this would have been:

• An increase in the attractiveness of Bradford as a centre for investment, utilising those parcels of land within the city centre which are unused or underutilised;
• An increase in the density and agglomeration of economic activity within key growth sectors in the City – such as Knowledge Intensive Business Services (KIBS) and Digital;
• Agglomeration of business activity in turn would generate productivity growth benefits at both the local and regional level due to the greater accessibility of businesses to sources of labour and accessibility to other businesses; and
• The ability of Bradford’s population to access higher quality and more productive jobs within the wider city region due to accessibility improvements leading to beneficial GVA impacts.

In summary, a high-speed line between Bradford, Manchester and Leeds would have:

Increased productivity by 6% and raised the employment rate by 1.5% (+50,000 jobs) within the North of England

Unlocked 1.3 million additional accessible jobs within 90 minutes of Bradford

Generated a 10% uplift in land values

Enabled Bradford to attract inward investment and increase its business base which would improve its financial sustainability and reduce its dependence on Government finance and assistance

Bradford remains disconnected from the Northern Powerhouse under IRP

Despite short distances (as the crow flies) Bradford is segregated from the Northern Powerhouse Core Cities as a consequence of its transport connections.

Figure 7 - Travel Times from Bradford

Source: NPR Bradford, Growth Strategy, National Rail

IRP will exacerbate the out-commuting of workers to Leeds to access high quality jobs

New direct connections to Manchester and Leeds would have unlocked the true economic potential of Bradford and its young, entrepreneurial population. It would have allowed Bradford’s young population, access to Northern labour markets and surrounding cities and towns.

It would ultimately support economic agglomeration, as firms have access to a wider market and a wider pool of talent, there are a greater number of jobs, and innovators have access to new knowledge.

Bradford’s increased connectivity would have attracted inward investment and created further jobs in the centre and surrounding areas.

Bradford experiences a net loss of residents to Leeds for work, with 62% more outbound journeys to Leeds compared to inbound from Leeds to Bradford for work. In total 15% of economically active Bradford residents work in Leeds, significantly higher than any other destination.

There is a strong identified need to increase the strength and depth of Bradford’s business base through increased investment in transport connectivity

• Bradford has the lowest employment density of the core Northern Powerhouse cities (0.62 jobs per head of working age population).
• Per head there are 3 times as many Knowledge Intensive Business Services (KIBS) jobs located in Leeds compared to Bradford (0.31 vs 0.11 per head respectively).
• The IRP proposals will further exacerbate the out-commuting of Bradford residents to Leeds to access employment opportunities. It does not provide the level of enhanced economic connectivity to the Northern Powerhouse required to increase the attractiveness of Bradford as a place for investment.

Figure 8 - Total Employment Density

Source: ONS (2020) BRES

IRP fails to connect Bradford to core hubs of economic activity in the North of England

The scale of Bradford’s missed economic connectivity is significant in the context of the Northern Powerhouse and Bradford’s connections to key employment centres.

Figure 9 - Bradford's Proximity to Employment Centres

Source: WSP Analysis (2021), ONS (2020) BRES

NPR would Unlock Regeneration of the Southern Gateway

The proposed NPR railway station would be located on the existing St James’ Market site. The Market is a six-acre site owned by the Council and sits within the heart of Bradford’s new 150ha Southern Gateway Regeneration Area. It houses a large wholesale market and is a short walk from the existing Interchange station and has major road connections to the A650 and M606 link.

The Southern Gateway is currently comprised of predominantly industrial employment uses, as well as underused and underutilised sites and buildings. It is identified within the Local Plan as a broad location for growth, with capacity for 2,500 dwellings and new commercial and community uses which will create a new environment for sustainable city centre urban living.

With a new station, the Southern Gateway could deliver:

Figure 10 - St James Market Location

The scale of Bradford’s opportunity is significant

The regeneration opportunity for Bradford’s Southern Gateway is very large. The regeneration area is significantly greater than the Kings Cross regeneration area and comparable with the central development zones within the Queen Elizabeth Olympic Park. It is approximately 10x larger than Birmingham Smithfield.

Figure 11 - Southern Gateway Regeneration Area Scale Comparison

Source: WSP Analysis (2021), ONS (2020) BRES

NPR WOULD UNLOCK REGENERATION OF THE SOUTHERN GATEWAY

Through the regeneration of the Southern Gateway, Bradford is looking to achieve impacts in six key areas: investing for return, transport improvements, creation of a new health quarter, resetting the housing market, supporting the cultural renaissance of the city and the 2025 ‘City of Culture’ bid and driving forwards the Net Zero and Clean Growth objectives of CBMDC.

These areas are described in further detail below.

Investing for Return

1. Build a tax base: change is needed to reduce the cost of welfare benefits as, currently, government spending outweighs the tax contribution within the City of Bradford.

2. Harness entrepreneurism: provide more opportunities to the 33,000 self-employed Bradford residents and encourage further opportunities for Bradford’s entrepreneurial business base to thrive and expand.
3. Create an environment that facilitates the upskilling of the existing working age population, as there is a current mismatch between employer needs and the skills of the working population.
4. Business intensification – enhance the quality of employment space through increasing the density of existing employment land sites and aim to increase the job yield per hectare making Bradford’s strategic employment sites more productive.

Transport Improvements

1. The Southern Gateway is a key transition point between the main urban areas of Southern Bradford and the core city centre.

2. It is an area of opportunity for clean growth, due to it being highly accessible to the city centre and major public transport hubs and will facilitate the transition to more sustainable mobility options for Bradford’s residents.
3. The new transport links which underpin the regeneration of the area, especially the new railway station at St James Market, can help to achieve clean growth through people-focussed and spatial/clean growth themes. The new integrated transport hub will also be connected to the WY Mass Transit scheme connecting the new station with the north of the District.
4. People: Regeneration of the Southern Gateway can generate positive inclusion benefits, helping to reduce transport poverty and promoting active travel movements within the city centre. These improvements will drive safety benefits and tackle direct health challenges as well as support Bradford’s clean growth and Net Zero ambitions.
5. Spatial and clean growth: improving the attractiveness of public transport, improving the visitor experience of Bradford’s central station and providing opportunities for sustainable freight, enhancing innovation, enhancing the quality of place, and reducing the impact on the environment.

A New Health Quarter

1. Regeneration would include the relocation of the Bradford Royal Infirmary to within the Southern Gateway. This would not be possible without the creation of a new station which will bring greater accessibility to the area and support the hospital’s Net Zero agenda.

2. It would achieve positive impact in four key areas: economic growth, regeneration, social inclusion, and a sustainable and healthy environment.
3. Economic growth: provide jobs (healthcare, research, and construction) and provide R&D opportunities as Bradford has the potential to become a leader in clinical research.
4. Regeneration: a new hospital will act as a catalyst for wider regeneration and will provide a positive signal to public and private investors.
5. Social inclusion: the new health infrastructure will increase employment and education opportunities within the district, improve access to healthcare, and support the provision of affordable housing within the development, especially for key workers.
6. Sustainable and healthy environment: the regeneration will increase sustainable transport options to the new hospital location, as it will be within the Southern Gateway. Air quality will be improved, as well as congestion reduced, and there will be an opportunity for the hospital to support the development of a Combined Heat and Power Network.

Resetting the Housing Market

1. Bradford hopes to achieve an improved housing market, with improvements being realised in five key areas.

2. City living environment improvements: improve the physical environment to live and work in, reduce anti-social behaviour and crime, and address the physical maintenance issues.
3. Housing developments: improve the quality and management of new and existing housing developments.
4. Markets: be clear on who wants to invest and live in Bradford to ensure it is the desired living environment.
5. Rethink housing: change the dynamic of city housing to include a variety of housing densities and building types that still sustain local character. Reduce the reliance on car use and increase the number of outdoor spaces.
6. Improve housing performance: tackle stalled development and brownfield regeneration challenges and include targeted funding support.

Cultural Renaissance

1. The Southern Gateway regeneration will aim to showcase Bradford’s diverse culture.

2. Make Bradford a better place to live and work, increasing visitor appeal and enhancing the number of visits to local attractions and heritage sites.
3. Enhance Bradford’s culture by attracting new people with new cultures to live and work within the city.

Clean Growth / Net Zero

1. A new station will enable Bradford to deliver significant new housing and employment sites with sufficient density to meet the City’s Net Zero and Clean Growth objectives.

2. It will unlock the potential to deliver long term transformational clean growth development opportunities linked to the expansion of Bradford City Centre, supported by high quality sustainable transport infrastructure, green/blue infrastructure improvements and a new health quarter for Bradford.
3. It supports the re-urbanisation of the area through the creation of new sustainable and highly accessible and connected low-carbon neighbourhoods and mixed-use developments improving transport links and connectivity to the heart of the city centre and beyond.
4. Regeneration of the Southern Gateway will transform a largely commercial industrial environment into a walkable, healthy, people-friendly environment.

NPR Would Catalyse Bradford’s Development Potential

The omission of a new station for Bradford within the IRP will impact the regeneration potential and future viability of the Southern Gateway. A new transport interchange would have the following key impacts:

1. Allowing future development to occur at higher densities, given the existing housing need within Bradford City Centre and bringing forward development sites more quickly;

2. Increasing the demand for housing in both the Southern Gateway and Bradford City as a whole, given the existing lack of local, regional and national connectivity;
3. Supporting and increasing the growth of higher density employment uses that are more dependent on public transport accessibility – such as office uses; and
4. Increasing the value of land and property in the vicinity of the new station.

Stimulating Growth within the Regeneration Area

A new NPR station will lead to significant improvements in transport accessibility for the City, leading to a range of currently non-viable sites within the Southern Gateway being developed and other sites coming forward more quickly, increasing the pace of change within this strategic regeneration area.

Additionally, increased accessibility will enable development to occur at higher densities, resulting in a net increase in homes compared to the IRP proposals. The station will also provide a catalyst for change of use of existing industrial employment sites to residential and/or mixed-use development.

Higher Density Employment Uses

The significant uplift in connectivity within the Southern Gateway is likely to result, over time, in higher levels of employment density, given the expansion of the labour market that will be within a 60-minute commute time of the sites by public transport. This may initially be captured in improved occupancy rates in existing city centre commercial properties, but over time a shift from lower density employment uses (which are less reliant on public transport) to higher density uses which can better exploit the improved connectivity is to be expected.

St James Market Station would increase accessibility across the Southern Gateway

Figure 12 - St James Market Station – 1km walking radius

The St James Market station would unlock the economic potential of Southern Gateway

Figure 11 illustrates the extent of low value, low density industrial and warehousing land uses which sit on the edge of the existing city centre. Increased accessibility through a new station could unlock the economic potential of the area, helping to increase the viability of key development sites and stimulate land use change over the local plan period.

It is estimated that the Southern Gateway accommodates approximately 5,800 jobs (4% of the total jobs in the city of Bradford), of which ~40% are within the manufacturing, construction, wholesale and retail trade and transport and storage sectors (2,200 jobs).

In contrast, the city centre accommodates approximately 20,500 jobs (15% of total jobs in the city of Bradford), of which the majority are in public administration, retail, health and financial and insurance and business administration and support service activities.

It is estimated that employment activities in Bradford City Centre generate in excess of £0.95bn per annum in GVA, compared to £0.29bn in Southern Gateway. This provides a stark illustration of the current economic productivity of the regeneration area compared to its potential if unlocked through the creation of a new city centre station.

Figure 13 - Bradford City Centre Land Uses

Source: WSP Analysis (2021), OpenStreetMap (2021)

Levelling Up Bradford through transport investment

The objectives of Levelling Up are to invest in local infrastructure in order to enact a visible impact on people and their communities, with larger investments being granted for local transport schemes.

The key priorities of ‘Levelling Up’ transport investment are the following:

• High-impact;
• Reduce carbon emissions;
• Cut congestion;
• Support Economic Growth; and
• Improve the experience of transport users.

Net Zero and the promotion of clean and sustainable growth is a significant priority identified within the Levelling Up criterion.

Funding will be targeted towards places with the ‘most significant need’, which is identified by an index which takes into account the following:

• The need for economic growth;
• The need for improved transport; and
• The need for regeneration.

Bradford meets the archetypal definition of a place which needs levelling up. If Government were truly committed to ‘Levelling Up’ they would support proposals to create a Levelling Up Investment Area within the Southern Gateway.

NPR and Levelling Up

Members of the local Council have expressed frustration, as Boris Johnson appeared to support an NPR route between Leeds and Manchester back in 2019, but this commitment has yet to come to light.

In the 2020 Spring Budget, £500,000 was earmarked for Bradford to undertake technical work on the St James Market station option. To date, only £100,000 has been released to examine the spatial options, with the remaining £400,000 which was required to undertake comprehensive masterplanning and transport appraisals of the Site, not provided by Government.

The overall proposals perfectly sit within the UK Government’s Levelling Up agenda. Equally, Bradford agreed that their initial plans for an underground station would be too costly and consequently found a more suitable alternative which would still align with the Government’s agenda while lowering costs.

This would create a new city centre district that not only allows for better connectivity to the centre, but also spreads the economic opportunities found in the centre significantly beyond its boundaries.

The proposed station’s location just outside the existing city centre means that development sites will be relatively cheaper, enabling Bradford to maximise their benefits, given the lower initial costs.

Large companies are coming to the area, such as PWC and Channel 4, both of whom are setting up major facilities in Bradford. In addition, Bradford is already home to a number of major companies, including VM Morrison, Yorkshire Building Society, Santander and Yorkshire Water.

Bradford is strategically located (without factoring for transport accessibility). The city is equidistant between London and Edinburgh, as well as Liverpool and Hull, making it an ideal location to work and reside.

The other planned major investments in Bradford further complement the potential benefits of the new station. Major proposed or potential investments in Bradford include the new entertainment venue Bradford Live, the aspiration to become UK’s City of Culture 2025, and the One Park City offices. These would all benefit from greater connectivity, further enhancing their transformative effect.

Levelling-Up Opportunity Index

A new study conducted by the government looked at a range of economic indicators to pinpoint areas that need targeted government support.

34 of England’s biggest cities and towns were investigated and ranked based on six indicators. The ranking of these indicators was then totalled to establish an overall ‘Levelling-Up Opportunity Index’.

Instead of focusing on deprivation factors, this index considers data on growth, business rates, commuting patterns and land use.

It aims to identify areas that have been underperforming economically in the past but still have room for growth.

The following table identifies the six indicators which form the basis of this index, mapped against Bradford’s case for each indicator.

Based on these indicators, Bradford emerged top of the overall list, demonstrating that Bradford has the best case for economic support as part of the levelling-up agenda. Therefore, this provides resounding evidence for the development of the St James’ Market site railway station and increased connectivity to Core Cities within the Northern Powerhouse.

Table 2 - Bradford Levelling Up Index

Bradford’s St James’ Market station is a perfect contender to support the Levelling Up Agenda in bradford

Levelling-Up Investment Area (LUIA)

CBMDC wish to work with central government to pilot LUIAs in Bradford and are asking for the Department of Levelling Up to support the LUIA concept in their forthcoming Levelling-Up white paper.

The LUIA approach sets out to enable local authorities to create public-private partnerships to unlock and drive growth. The aim is to attract and maximise private sector investment to drive much-needed transformative change. The change required within an LUIA would be identified and established by local authorities. The idea within an LUIA is that local authorities would be given permission to relax their planning policy to help facilitate and encourage private development.

Bradford have identified two areas, but in terms of the IRP this will focus on the Southern Gateway, as mentioned previously. The Southern Gateway (shown below) would be one of Bradford’s LUIAs that the council wish to use as a pilot.

The Southern Gateway offers potential to deliver growth in a sustainable location, helping to expand and grow the emerging city centre residential offering through a number of neighbourhoods, the existing business base and the emerging cluster of schools. There will be potential for new health infrastructure as a result of the reuse of existing estates and the improvement of sustainable public transport to develop a new hospital site estate.

There are further opportunities to deliver a new residential neighbourhood, which would link with existing open spaces to develop a mixed-use LUIA.

Figure 14 - Southern Gateway Regeneration Area LUIA

Conclusion

In summary the IRP fails to deliver the transformational change in transport connectivity for Bradford which is required for the City to realise its ambitions with regards to:

1. Levelling Up and providing a greater number of economic opportunities for those who live in Bradford and the core cities within the Northern Powerhouse;

2. Delivering the Southern Gateway regeneration area and supporting Bradford achieve its housing and employment targets over the local plan period;
3. Driving the clean growth and Net Zero agenda for the city. IRP fails to enable the creation of new sustainable and highly accessible and connected low-carbon mixed use neighbourhoods integrated with a new multi-modal transport hub for the City.

Appendix B: Analysis of how the IRP meets its Terms of Reference

We consider how well the IRP met the Terms of Reference.  The IRP was supposed to build on the Oakervee Review into HS2, which concluded that the HS2 Y-shaped network to both Manchester and Leeds was the right solution for the country as a whole.

The review also suggested that the IRP could challenge the standards, cost and delivery process for the network, but not the network itself. The IRP has failed to meet the Terms of Reference by calling the network solution into question, potentially undermining the rest of the network.

The IRP was to consider the whole of HS2 and NPR with other major rail schemes to see how these can be operated as an integrated network.

The IRP does not ensure that these can be operated as an integrated network. There is no technical evidence available to support the decision making. The decisions to keep 2-track sections (such as the Leeds-Dewsbury ‘IRP Bottleneck’) and terminal instead of through-stations (including at Bradford and Manchester Piccadilly) will severely impact operations in the future. The focus has been placed on seat capacity and journey times but without a proper understanding of – and likely therefore prejudicing – connectivity, timetable and network capacity benefits which are just as important in driving whole network benefits.

The Terms of Reference set out that the IRP was to be informed by the NIC’s Rail Needs Assessment (RNA) for the North and the Midlands, which we consider in more detail below.

The Terms of Reference set out 4 points for the IRP to consider, of which the first three are most relevant. These are:

1

How best to integrate HS2 Phase 2b and wider transport plans in the north and Midlands, delivering benefits from investments more quickly. This should include a recommended way forward on scoping, phasing and sequencing delivery of HS2 Phase 2b, Northern Powerhouse Rail, Midlands Rail Hub and other proposed rail investments. This should take into account: government commitments; the current state of development for different projects; the transformational and capacity benefits of these schemes; fiscal and supply chain capability constraints; network integration; consenting routes (including legislation); and, in line with the Oakervee Review conclusion, the appropriate mix of high speed line and upgrades of conventional network, and the sequencing of these, on any elements of the investments under consideration.

In relation to Bradford, although information relating to options such as St James Market had been provided to inform the IRP, we believe that Government had not taken these into account. Bradford in particular delivered more transformational benefits than other options, but because these were assessed last, they were not always available until later. The DfT obstructed level 3 (transformational) benefits work on the St James Market option pending the outcomes of the IRP, which neglected this option on the very basis of such information not being available.

Government’s comments in the IRP on and decisions relating to St James Market in that document do not reflect its earlier stage of development. The Council, in partnership with TfN and WYCA, had developed positions relating to bus services, local highways and city centre development.

The Government had committed on several occasions to building NPR. The Prime Minister himself committed to ‘building a new line between Leeds and Manchester across the Pennines’. However, this notion of NPR has been abandoned in the IRP, which doesn’t take into account previous government commitments on this issue.

2

How best to reduce cost, including opportunities to reconsider HS2 Phase 2b scope and design standards to prevent over-specification, improve efficiency and reduce costs, drawing on the Phase One lessons learnt work to be led by the Infrastructure and Projects Authority (see below).

Bradford has been penalised by Government not addressing the over-specification on HS2, meaning that within budget constraints there was less available for NPR.

The IRP could have been expected to deliver cost savings on HS2, delivered through:

     Best practice from abroad, where similar schemes achieve lower unit rates

     Changes to contract mechanisms to make the Government or GBR in future assume more financial risk

     Adapting the size of construction contracts

     Directly addressing supply chain capacity

     Agreeing a future timetable specification, to enable all IRP-linked projects to be planned coherently

     Reducing future market uncertainty – the IRP states that options selected will depend on future market demand, not recognising that this demand is ultimately a result of policy decisions made by government in rail (for instance through setting fares) and other areas (such as land use, regeneration, fuel duty, highway capacity). This would have enabled a plan to be created for a future network which would be based on achieving a desirable mode shift from other modes.

     Planning improvements to high-speed services alongside improvements to local services and taking into account the needs of both when planning infrastructure, reducing costs for future projects.

     The Council believes that the Government has not acted with due care to exhaust these avenues to reduce the cost on the HS2 scheme, which has left less money for NPR.

3

The recommended approach to sponsorship and delivery, including governance and delivery models, and how to take account of the views of local leaders, consistent with delivering on the objectives of the scheme and value for money. This will include exploring options for new delivery vehicles with northern leaders for the relevant rail enhancements including new lines that may form part of the delivery of HS2 and Northern Powerhouse Rail.

GBR would have been a much better fit for considering how the network will need to adapt as a whole, to implement the IRP. Responsibilities for sponsoring these schemes and relevant expertise should be transferred to this body as soon as possible.

It is strongly felt that the decisions to remove TfN from the process for developing NPR are related to Government and DfT not agreeing with TfN’s vision for the future rail network in the North. The proposed future arrangements do not reflect TfN’s role as convenor, or its responsibility for having a strategic plan for pan-northern transport investment.

4

How best to deliver rail connectivity with Scotland, in conjunction with the Scottish Government.

Not examined here.

Appendix C: Analysis of how the IRP performs against the Rail Needs Assessment for the Midlands and the North

The IRP is a response to an earlier document, the Rail Needs Assessment (RNA) for the Midlands and the North, undertaken by the NIC. This set the standard for the IRP to achieve. The RNA set out 5 criteria for success of the IRP. The IRP broadly does not meet these, particularly in Yorkshire:

1. Start with a realistic plan of core investments
• This plan seems unrealistic, especially for Yorkshire, given the lack of separation between fast and slower services and the creation of capacity bottlenecks that arises from not building NPR in full as advocated by local partners.
2. Add further options subject to success
• The plan only identifies very limited further options, preferring to discount these entirely. A better plan could have included more options to serve places like Bradford.
• The Plan does not adequately identify options beyond the core investment.
3. Be agreed with local stakeholders
• The plan stands very little chance of being agreed with local stakeholders. Worse, the Government preferred to exclude local stakeholders from the IRP process.
4. Contribute to net zero and environmental net gain
• In Yorkshire, the IRP could have delivered much needed extra capacity to relieve lines which are effectively full, allowing for mode shift to highly efficient electrified rail. The IRP plans in no way allow for any significant mode shift in Yorkshire, and will hold back local ambitions for decarbonisation.
5. Accelerate schemes and deliver benefits in the shorter term
• The Government did explicitly say how the IRP would allow benefits to be delivered sooner. However, this has come at expense of losing most of the scheme benefits. The IRP has also been used to mask delays to scheme delivery.  The IRP process itself has delayed schemes such as Trans Pennine Route Upgrade. There is a commitment to WY Mass Transit, but this was not part of the remit given to the IRP so its inclusion is unwarranted.

-         The RNA also set out the expected levels of investment in rail in the North and the Midlands. There were 3 levels of expenditure analysed:

-         £44bn, to complete HS2 Western Leg and upgrades to MML and ECML lines (Base)

-         £68-69bn, with different packages of investment including improved links to Bradford (+25%) – this was felt to be the most realistic by the report writers

-         £90-92bn, with different packages of investment including a new line via Bradford. (+50%)

-         The IRP proposes investment of £54bn, between the Base and +25% packages. However, due to funding increases on the core schemes, there is less to spend on other enhancements.