Object

Representation ID: 28523

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

Housing Need and Requirement:

Our Client strongly objects to the Council’s proposal to set the housing requirement at 1,704 dwellings per annum as this is not in accordance with the MCHLG standard methodology which require the 20 largest urban authorities in England to provide a 35% uplift to the baseline figure. As such, the Council’s housing requirement is a minimum of 2,300 dwellings per annum.

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, which set a housing requirement of 42,100 new homes and which was underpinned by evidence which must have assessed land supply, strategic constraints and the ability of existing infrastructure to cope with the level of growth that was planned. Realistically nothing has changed in this regard.

Moreover the Council have already demonstrated that exceptional circumstances exist through the Core Strategy to release land for 11,000 new homes in the green belt as opposed to the 5,500 in the new Local Plan.

By not including the 35% uplift, the Council are not using the standard method and 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.

The Council’s view is that the 35% uplift can only be provided within the Regional City of Bradford, however we consider this to be a misunderstanding of the intention of the uplift.

The Policy is therefore 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.