Object

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

Representation ID: 29812

Received: 23/03/2021

Respondent: Addingham Parish Council

Representation Summary:

Housing Distribution - Addingham

It is unclear how the distribution strategy set out in the draft Plan is applied, as it seems to result in a relatively high housing target for Addingham, as opposed to the targets set, proportionate to the relative size of the local populations, for nearby principal towns, such as Ilkley, and local growth centres.

In responding to the Partial Review of the Core Strategy in 2019, the Parish Council welcomed the reduction in the housing target number for Addingham from 200 new houses to 75 new houses during the Plan period, and supported policies aiming to ensure that any green belt land required for the purpose should be released only in sustainable locations. Clearly, with the higher target reintroduced, it is considerably more difficult for this objective to be achieved.

As discussed in the draft Plan, development in Addingham is heavily constrained by Green Belt (para. 5.15.23), has more limited employment opportunities which might give rise to growth requirements, and, compared with nearby towns, is a less sustainable location, where the supply of potential development land which would not lead to adverse environmental impacts is limited.

Local service centres, as defined in the Plan, are expected to take “a reduced scale of growth, compared with urban areas” (para.3.3.11) because they are less sustainable locations for new housing development. The reduction in Addingham’s housing target in the Partial Review was justified on the basis of employment led scenarios designed to align housing needs with economic growth (para. 3.8.5); on this basis, fewer new houses were required in Addingham as it is a less sustainable location with limited employment opportunities. The new draft Plan’s spatial distribution growth does not adequately explain, except by means of unsubstantiated generalised narrative statement, why this conclusion has now been reversed for this particular local service centre. The Parish Council would recommend that the scenarios used to identify forecast housing requirements need to be updated urgently if the Plan’s spatial growth strategies are to be justified and properly evidenced; data shortly to become available following the Census 2021 should be taken into account to support these updated analyses to ensure more accurate and appropriate application of the Plan’s policies.
Overall, the Parish Council is concerned that the draft Plan simply does not adequately address the overall housing needs of the Bradford City region as a whole. In particular, it ignores the needs of a relatively young city, one where there is now clearly a need for more affordable and sustainable housing sites to be developed within the main urban areas, especially to the South. Also, much of Bradford’s land is now “brownfield and post-industrial”, and thus is ideal for developing more affordable housing, as part of a wider programme of urban regeneration.