Consultation Question 1

Support

Representation ID: 1071

Received: 09/03/2021

Respondent: Clive Brook Planning

On behalf of my client landowners and developers I support the selected plan period of 2020 to 2038 and the need for a minimum 15 year period from adoption. However, it has taken a considerable period of time to reach this Regulation 18 Consultation Draft composite plan containing proposed policies and site allocations. The anticipated period remaining to adoption in 2023 is too long and the Council must now do everything possible to speed up production of the plan, particularly as the current land supplies for housing and employment development fall a long way short of requirements and the aspirations of the Council. The sub 2.0 years of housing land supply against the required 5.0 years of deliverable housing supply (recently confirmed by the Inspector and the Secretary of State - planning appeal for 500 dwellings at Burley-in-Wharfedale) requires the earliest possible adoption of a full suite of residential allocations.

Object

Representation ID: 1099

Received: 09/03/2021

Respondent: Mr Matthew Beattie

This plan focuses far too heavily on green belt development and not enough on urban regeneration. The green spaces around Bradford and Keighley are the lungs of a region that is already blighted by excessive air pollution. There are enormous swathes of empty brownfield sites in urban centres that are crying out for investment, yet Bradford Council is planning to overdevelop areas that already have oversubscribed schools and poor transport infrastructure. The developments will add nothing to the local areas, will destroy wildlife and blight the landscape. It is irresponsible development of the worst kind and nothing short of a scandal that the council is putting to consultation during a lockdown when communities can’t object.

Support

Representation ID: 1191

Received: 10/03/2021

Respondent: Mr Paul Holmes

This period allows for the planning of support and amenities for any new housing developments proposed in the area. Provision of school places for various ages along with medical support and the provision of local amenities can be planned and timed to suit the building of new housing. This will allow those provisions to be in place for when they are needed.

Support

Representation ID: 1281

Received: 11/03/2021

Respondent: Lightowler Associates

Although not endorsing the overall plans, which can hopefully be modified, the overall time periods are acceptable,

Object

Representation ID: 1872

Received: 16/03/2021

Respondent: Sir Stephen Brown

I SUPPORT THE TIMEFRAME 2020-2040 BECAUSE WE WILL NOT KNOW FOR PROBABLY 24 MONTHS HOW OUR WORLD WILL LOOK POST-COVID. THERE MAY BE SIGNIFICANT CHANGES TO WORKING PRACTICES, INCLUDING WORKING FROM HOME, WHICH WILL IMPACT ON MANY ASPECTS OF THE PLAN. AS THE "NEW NORMAL" EMERGES, THE PLAN CAN BE SHAPED TO FIT.

Object

Representation ID: 1902

Received: 17/03/2021

Respondent: Burley Parish Council

The preferred plan period runs for 17 years (2020-2038) as opposed to the normal 15 year plan, extending forecast methods used to inform the plan by an extra 5 years. We would therefore suggest that the Local Plan’s progress is scheduled for review no later than 5 years before the plan period ends.

BPC also believe that it is important to review the Local Plan after the 2021 census data is released in 2022. The census will contain the latest demographic profiles, commute data etc. which may reveal something significant about housing and jobs throughout the District.

Support

Representation ID: 2110

Received: 18/03/2021

Respondent: Mr Paul Roach

With such an ambitious plan, especially within a pandemic then a 17 year plan length is appropriate

Support

Representation ID: 2538

Received: 20/03/2021

Respondent: Baildon Branch Labour Party

This seeems a sensible time period and meets the minimum required by National Planning Policy

Support

Representation ID: 2616

Received: 20/03/2021

Respondent: NEAT

15 years is a long enough period to introduce some genuinely strategic approaches.
At present the approach is mainly reactive (e.g. responding to demand for housing) without any apparent attempt to alter trends that could render Bradford a truly appalling place to live (does the council carry on feeding demand for housing until we have a Hong Kong-style city full of skyscrapers?).
15 years is enough to introduce 2 strategies:
1) Make clear the consequences of population growth and encourage families of 1/2 children maximum;
2) Tackle mental health issues (described by a psychotherapist as "of epidemic proportions). The Council must familiarise itself with research evidence for the benefits of contact with the natural environment (ecotherapy). MIND (the mental health charity) and Dr. Jo Barton (Essex University) are good starting points. To provide ecotherapy for all, surviving green spaces must be preserved and expanded. This would halt declining biodiversity.

Object

Representation ID: 2729

Received: 21/03/2021

Respondent: Mrs Helen Owen

Consultation takes no account of the changes which have taken place since the start of the pandemic. This should wait till lockdown is over.

Support

Representation ID: 2830

Received: 21/03/2021

Respondent: Mr David Smith

Agreed

Support

Representation ID: 3420

Received: 22/03/2021

Respondent: Mrs Mary Girling

We may be dead by 2038

Object

Representation ID: 3668

Received: 23/03/2021

Respondent: Mr Philip Sutcliffe

The green belt was set up to stop urban expansion. In the case of Bradford, to stop it becoming part of Leeds. Bradford planning office being completely undemocratic wishes to pour cement and tarmac all over the green belt in Tong. The reason I say undemocratic is as follows. ~There has not been one survey, or opinion poll taken in Bradford, which agrees with Bradford councils views on building on green belt. In fact approx 90 % of population of Bradford totally disagree with Bradford councils housing and road plans. However, the council which claims represents the people is acting like a fascist state.

Your new road and housing plans directly effect my Grade II house and land. However, you have not had the decency to contact me over the last 10 years. I doubt you care less about me than the environment and the creatures that need it.

Object

Representation ID: 3768

Received: 23/03/2021

Respondent: Mr Andrew Lund

The suggested plan period is inappropriate. It disregards development which has already taken place in earlier iterations of the core strategy, and does not recognise the impossibility of determining housing and employment needs in the district so far into the future, particularly in light of the fundamental shifts resulting from the COVID-19 pandemic.

Support

Representation ID: 3863

Received: 23/03/2021

Respondent: Mrs Susan Burn

I support the decision of BMDC to not adopt the new Government standard method for housing looking for an increase in dwellings of 35% in the largest cities and urban centres in England (including Bradford) above what is considered our base housing requirement (1704 dwellings per year).
I support the approach of BMDC to the planning period - there is considerable uncertainty about how our district will look post-covid - I support the measured and sensible proposal of this plan.

Support

Representation ID: 4740

Received: 24/03/2021

Respondent: SHMS

From the explanation seems reasonable, although 8 years addition to the Core Strategy. Will I consider help businesses to forecast. However the council needs to ensure agents and developers do not cherry pick the most lucrative and easy sites in green belt, greenfield before pdl/brownfield.
Identifing sites that should be developed late in the plan period leaves the council open to challenge due to the back stop of lack of a five year supply. PDL in Bfd and Keighley should be prioritised for development first to support the retail offerings.

Object

Representation ID: 5640

Received: 24/03/2021

Respondent: Ms Heather Jones

CONSULTATION PERIOD & PROCESS
The plan is heavily flawed, and this consultation is also flawed and inadequate. The use of a digital only (or at least digital first) approach will not result in good input or proper representation of citizen's views, and it is discriminatory. This is exacerbated by the short timescale that has been allowed to citizens to register comments, and the very poor communication there has been about it.

The inadequate consultation therefore leaves the council open to the charge that the Plan is not valid, cannot be relied on, and any developer could challenge it in the courts.

If it goes ahead at all, it should be reviewed and revised as soon as possible, in any case in the next 12 months, following a proper consultation exercise.

Object

Representation ID: 5843

Received: 24/03/2021

Respondent: Mr John McKee

At various stages throughout the Plan reference is made the Coranvirus pandemic and the detrimental impact on economic differences and social inequalities (3.6.2). Additionally the data is old. It would be far more sensible to base the plan on more up to date data as will be provided by the 2021 Census.
Whilst it is acknowledged that the short, medium and long term impacts of the Coronavirus pandemic will not be known for some considerable time to base the plan on "old" data presents significant risks. Will the Whole Plan Viability Assessment take the age of the data into account?

Object

Representation ID: 10933

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We consider the plan period should be extended to 2040 resulting in a 20-year period .

The Core Strategy accounted for housing needs between 2004 and 2030 (a 26 year plan period) and sought to actively plan for new homes required between 2013-2030 (i.e. 17 years). The Site Allocations was originally anticipated to be adopted in 2020 resulting in a 10 year period where the Borough would have had a complete set of housing policies in place.
The above demonstrates that it takes a long time to prepare plans and therefore it is our view that once a plan is prepared and adopted it should plan for a considerable period of time. Planning for at least a 20 year plan period will mean plenty of scope and flexibility can be built into the plan to meet more pressing needs should these arise in the interim and before a full review of the Local Plan can be completed.

Object

Representation ID: 11367

Received: 17/03/2021

Respondent: Mr Robert Felstead

The preferred plan period runs for 17 years (2020 – 2038) as opposed to the normal 15-year plan, extending forecast methods which are used to inform the plan by an additional 2 years.

I would therefore suggest that the Local Plan’s progress is scheduled for review no later than 5 years after the plan period commences. I also believe that if Council forges ahead with the Local Plan based on the existing MHCLG ‘unapproved’ Five Year Housing Land Statement dated January 2021 and Housing need Addendum dated February 2021, that the plan will need to be extensively reviewed shortly following publication of the 2021 Census data.

Comment

Representation ID: 13813

Received: 20/03/2021

Respondent: John Finnigan

Whilst I have no objection to the BDLP having an overall Plan period running to 2038 it is essential that the plan is reviewed no less frequently than every five years.

In respect of site allocations I propose that these be reviewed on a five yearly basis to minimise the risk of surplus Green Belt releases being included.
If that were the case the Council could not show exceptional circumstances at present for Green Belt site allocations. After the first five years it may be that the Council could show exceptional circumstances by reference to changes in housing growth predictions, but precious Green Belt land would not be lost to the District any sooner than absolutely necessary.

Support

Representation ID: 16257

Received: 22/03/2021

Respondent: Robbie Feather

Agent: ID Planning

We support the proposed 17 year plan period with a start date from April 2020 and end date 2038 subject to housing needs and requirement figures fully recognising past under delivery.

Support

Representation ID: 16870

Received: 23/03/2021

Respondent: Avant Homes

Agent: ID Planning

We support the proposed 17 year plan period with a start date from April 2020 and end date 2038 subject to housing needs and requirement figures fully recognising past under delivery

Object

Representation ID: 17161

Received: 24/03/2021

Respondent: The Norris & Holmes Families

Agent: Savills

The plan period proposed for the Draft Local Plan runs from 2020 to 2038, stated as being a period of 17 years
albeit at paragraph 2.10.7 of the draft Local Plan 2021-2038 is also calculated as being a 17 year period. Clarity
is therefore required on whether the plan period is in fact over a 17 year or 18 year period.

For reference we therefore calculate that the plan is over an 18 year period, which accords with the average
dwellings per annum figure set out at Draft Policy SP8.

Recommendation 1: Clarity needs to be provided on how the 2020-2038 period is calculated as a 17 year
period. We understand the plan length to be 18 years and have undertaken our assessment based on this.

Object

Representation ID: 17167

Received: 24/03/2021

Respondent: Jones Homes (Yorkshire) Limited

Agent: Savills (UK) Ltd

The plan period proposed for the Draft Local Plan runs from 2020 to 2038, a period of 17 years as stated
within the draft Local Plan.

The draft however also states that the Core Strategy runs for a 17 year period from 2013 – 2030, and at paragraph 2.10.7 of the draft Local Plan that 2021-2038 is a 17 year period.

Clarity is therefore required on whether the plan period is calculated in line with the Core Strategy (i.e. 18 years for the period 2020 - 2038), or intentionally differently at 17 years. For reference we therefore calculate that the plan is over an 18 year period, which accords with the average dwellings per annum figure set out at Draft Policy SP8.

Recommendation 1: Clarity needs to be provided on how the 2020-2038 period is calculated as a 17 year
period, when the Core Strategy and Draft Local Plan take different approach elsewhere.

Support

Representation ID: 17407

Received: 23/03/2021

Respondent: Mr & Mrs . Pyrah and Saunders

Number of people: 4

Agent: ID Planning

We support the proposed 17 year plan period with a start date from April 2020 and end date 2038 subject to housing needs and requirement figures fully recognising past under delivery.

Support

Representation ID: 17493

Received: 23/03/2021

Respondent: Barratt Homes and David Wilson Homes

Agent: ID Planning

We support the proposed 17 year plan period with a start date from April 2020 and end date 2038 subject to housing needs and requirement figures fully recognising past under delivery

Support

Representation ID: 17671

Received: 23/03/2021

Respondent: Bannister Investments Limited

Agent: ID Planning

We support the proposed 17 year plan period with a start date from April 2020 and end date 2038 subject to housing needs and requirement figures fully recognising past under delivery

Object

Representation ID: 18916

Received: 23/03/2021

Respondent: Mrs WE Nichol

Agent: Carter Jonas

We are concerned that the Plan period identified is insufficient.

The Framework is clear in paragraph 22 that it requires plans to look ahead over a minimum of 15 years from adoption. Plans should establish a clear strategy for bringing sufficient land forward, at an adequate rate, to meet the objectively assessed needs over the Plan period.

Given that it is acknowledged within section 2.10 of the Preferred Options that there has already been slippage on the timetable for the proposed Draft Local Plan with adoption now expected in 2023, we consider that it would be prudent to build in additional flexibility to the Plan period to allow for any further delays.

Extending the Plan period to 2040 would provide such flexibility and ensure that the Plan looks ahead over a minimum of 15 years from any potential adoption.

Object

Representation ID: 18926

Received: 23/03/2021

Respondent: Mrs J Kamyar

Agent: Carter Jonas

We are concerned that the Plan period identified is insufficient.

The Framework is clear in paragraph 22 that it requires plans to look ahead over a minimum of 15 years from adoption. Plans should establish a clear strategy for bringing sufficient land forward, at an adequate rate, to meet the objectively assessed needs over the Plan period.

Given that it is acknowledged within section 2.10 of the Preferred Options that there has already been slippage on the timetable for the proposed Draft Local Plan with adoption now expected in 2023, we consider that it would be prudent to build in additional flexibility to the Plan period to allow for any further delays.

Extending the Plan period to 2040 would provide such flexibility and ensure that the Plan looks ahead over a minimum of 15 years from any potential adoption.