Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Representation ID: 29706
Received: 24/03/2021
Respondent: Keyland Developments Ltd
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 over the plan period 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 with a housing target of 2,476 units per annum.
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.
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 and strategic constraints and the ability of existing infrastructure to cope with that level of growth. Realistically nothing has changed in this regard and it is entirely unacceptable to claim otherwise.
The Council have already demonstrated that exceptional circumstances exist through the Core Strategy to release land sufficient to accommodate 11,000 new homes, as opposed to 5,500 proposed in the new Local Plan. Those sites remain available and developable, and it is unreasonable for the Council to imply otherwise.
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.
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.