Object

Representation ID: 18383

Received: 24/03/2021

Respondent: Johnson Mowat

Housing Requirement

The proposed 1,704 dwellings / annum is a substantial reduction compared to the Council's 2017 position tested in examination i.e. 2,476.

HBF calculates minimum housing need (standard methodology) to be 1,699. The additional 35% uplift to be applied to minimum need for Bradford (and other large urban areas) is a central Government requirement and not an option for a LA to accept or reject. It is inappropriate to reject this as the Council has done in paragraphs 3.8.11 and 3.8.12

The identification of ‘strategic constraints (Green Belt)’ as a reason not to apply the uplift is unacceptable.

PPG indicates this increase / uplift is expected to be met by the cities and urban centres themselves, rather than the surrounding areas’. i.e. the uplift should not be met by substantial additional allocation of land in rural areas or lower order settlements.

However, the allocation of additional green belt land abutting the main urban areas is appropriate.

Part A of Policy SP8 should be amended to:

‘The Local Plan will seek to deliver a housing requirement of 41,407 new homes over the plan period 2020-2038, equating to an indicative average of 2,300 new dwellings per annum.'