Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 27960

Received: 24/03/2021

Respondent: Bellway Homes Limited

Agent: Barton Wilmore

Representation Summary:

Housing Need and Requirement

The Council’s proposal to set the housing requirement at 1,704 dwellings per annum over the plan period is not in accordance with the MCHLG standard methodology.

The Council’s justification for not including for the 35% uplift carries little weight in the context of the Core Strategy, which was only adopted in 2017.

It is unclear how only four years ago the Council were confident they could deliver 42,100 new homes over a 17-year period, being fully appraised of the extent of land supply, strategic constraints and infrastructure issues. Realistically nothing has changed in this regard and it is entirely unacceptable to claim otherwise.

By not including the 35% uplift, the Council are not using the standard method and in line with the PPG there is a requirement to demonstrate exceptional circumstances as to why a different approach has been taken.

Whilst it is noted that the 35% is ideally applied to urban areas and thus brownfield land, the PPG does not explicitly state that the 35% is only accounted for in urban areas. Whilst a ‘brownfield first’ approach is advocated, it is not meant to be a ‘brownfield only’ approach.

As currently drafted the Policy is unsound as it does not propose to deliver the minimum housing need identified in the standard methodology and does not include the required 35% uplift. As such, the plan is not positively prepared as required by paragraph 35 of the NPPF.