Object

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

Representation ID: 28468

Received: 24/03/2021

Respondent: Lovell Homes

Agent: PB Planning

Representation Summary:

Housing Need and Requirement:

The Preferred Options Local Plan identifies that the Council will seek to deliver 1,704 homes per annum, which reflects the Standard Method Calculation without the Cities & Urban Centres Uplift required by Step 4 of the PPG’s prescribed methodology.

The actual minimum housing need is therefore 2,300 homes per annum not 1,704.

Whilst the use of the Standard Method is not mandatory, the PPG is clear that “there is an expectation that the standard method will be used, and that any other method will be used only in exceptional circumstances” (Paragraph: 003 Reference ID: 2a-003-20190220).

The Council’s Housing Need Addendum (February 2021) is inconsistent and incorrect in the way it addresses what the minimum level of housing need is. In particular, the Cities and Centres uplift the uplift is not a variable to be considered when determining if there is evidence to increase the minimum housing need, it is one of the four initial key steps which establishes that Bradford’s minimum housing need is 2,300 homes per annum.

As insufficient evidence has been provided to demonstrate that exceptional circumstances exist for the removal of the Cities & Urban Centres Uplift from the Standard Method calculation, the Local Plan should seek to deliver 2,300 homes per annum over the plan period 2020-2038. Which equates to 41,400 homes.