Consultation Question 9

Object

Representation ID: 1086

Received: 09/03/2021

Respondent: Birkbeck, University of London

Housing Need and Requirement

The core information missing from this discussion is the basis upon which future housing needs have been calculated, by whom and based on what assumptions in approaching the data. The discussion above already indicates that the projected 1704 houses per annum, of which only just over half will be built on brownfield sites (and a truly abysmal proportion in some areas) 'will ensure that the housing requirement will meet (and exceed) demographic housing need in terms of projected household growth'. What possible justification is there for exceeding demographic housing need? With global population projected to plateau over the next 30-60 years and to decline in the industrially developed world, what is the basis for assuming the housing need outlined in this document?

Object

Representation ID: 1716

Received: 16/03/2021

Respondent: Mr Paul Stephens

Community Led Housing (CLH) has a role to lay, particularly in providing affordable housing that meets local needs. SP8 should explicitly refer to the role that Community Led Housing should play. This would seem to fit with paragraph I of SP8. Paragraph L of SP8 should also include a commitment to making land available for Community Led Housing initiatives.

Object

Representation ID: 1824

Received: 16/03/2021

Respondent: Mr Glenn Miller

Housing Need and Requirement

Bradford claims that its housing requirement is 1704 dwellings pa for the period of the Plan. They base this on The Strategic Housing Market Assessment (2019) and (2021); The Bradford District Updated Demographic Evidence June 2019 and February 2021; and the Bradford Housing Need Addendum dated February 2021. These various reports put forward a number of estimates of future housing growth none of which requires 1704 dwellings per annum. Bradford use the "Standard Method Housing Requirement" without justifying why in the face of the lower estimates of population growth they have.

Object

Representation ID: 1829

Received: 16/03/2021

Respondent: Mr Glenn Miller

Housing Distribution - Ilkley and Wharfedale

I have already noted above that there is a question mark over the housing growth required to cater for Bradford's supposed population growth.

The allocation of development to Ilkley and to Wharfedale generally is itself questionable on the basis that additional housing in this area is likely to be only for the benefit of those working in Leeds and further afield. It will not enhance urban Bradford nor Bradford employment opportunities. Indeed it will not enhance Ilkley whatsoever, nor employment opportunities in Ilkley itself.

Object

Representation ID: 1879

Received: 16/03/2021

Respondent: Sir Stephen Brown

Housing Distribution

300 new dwellings in Ilkley is over bearing. The town cannot absorb so many dwellings without fundamentally losing its character. The less attractive the town becomes the less tourists it will attract. The less economic activity there will be.

Object

Representation ID: 1910

Received: 17/03/2021

Respondent: Burley Parish Council

See answer at Q6.

3.8.45 Please provide the evidence on which this statement is based.

3.8.50 The issue here is not one of affordability but of income and social housing. Affordable social housing needs to be delivered at a very low starting price.

Whilst BPC accept that it is inevitable that some housing need has to be met from green belt, our previous comments about housing viability in Q5 remain. In this section the housing allocation from Burley is 326 units of 625 houses in the Local Plan.
Why could BDMC not consider an affordable housing initiative as in Manchester?

Object

Representation ID: 1954

Received: 17/03/2021

Respondent: Clive Brook Planning

Housing Need and Requirement

On behalf of my landowner and developer clients I object to policy SP8 :- These objections relate to :-
1.The considerable under-assessment of the District's housing need and the lack of any applied uplifts to the baseline minimum housing need figure of 1,704 dwellings/annum.
2. The determination of the housing requirement and its distribution throughout the settlements in the Bradford hierarchy.
3. Objections to the proportion of the housing requirement which will be required from the Green Belt to meet the objectively assessed needs of the District in the most sustainable way.

Object

Representation ID: 1957

Received: 17/03/2021

Respondent: Mrs Helen Miller

Housing Need and Requirement

Bradford claims that its housing requirement is 1704 dwellings pa for the Plan period. The various reports they rely on put forward a number of estimates of future housing growth none of which require 1704 dwellings pa. Bradford use "the standard method housing requirement" without justifying their choice in the light of the lower estimates referred to.

Support

Representation ID: 2114

Received: 18/03/2021

Respondent: Mr Paul Roach

Previously Developed Land

I fully support the policy to maximise the use of brownbelt land where possible. Regeneration of derelict/previously developed buildings will help the aesthetic of the towns, reduce climate impact as more will be able to walk to work and create new communities

Support

Representation ID: 2510

Received: 20/03/2021

Respondent: Mr Peter Down

Whilst I support the proposed Policy SP8, there are various issues to be addressed. The current practice of developers deliberately not including affordable housing in their proposals and, instead, providing a contribution to City of Bradford MDC in order to delegate their responsibility must be stopped. If possible, disincentives should be in place to encourage developers to provide affordable housing. Similarly, there should be financial disincentives in relation to developed of greenfield and Green Belt land and, possibly, incentives provided to promote the redevelopment of brownfield sites. The provision of housing should not be at the expense of local amenities and facilities, especially in Local Centres and Rural Areas. There should be an aim for retaining amenities and facilities so that they are there for the benefit of the local population, including those related to areas of new housing.

Object

Representation ID: 2624

Received: 20/03/2021

Respondent: Mr Richard Partner

Housing Distribution - Addingham

The present proposal for housing developments across the whole of Addingham is disproportionate to the neighbourhood plan agreed 12 months ago, which was set to achieve the previous target of new dwellings within the village considering minimal impact to the character of the village, environment, traffic, recreational spaces and impact on the school. These new plans have double the number of dwellings in areas of green belt and on the periphery of the village which would have multiple negative impacts on the aforementioned categories. Necessary affordable housing is important in all catchments of Wharfdale, however the numbers allocated to Addingham are disproportionate to other areas. The consultation time and method proposed is inadequate especially in the present pandemic as there will be many people who will not have digital access to voice their opinions. The consultation time should be extended until such time where residents can access community Internet facilities.

Object

Representation ID: 2637

Received: 20/03/2021

Respondent: Mrs Hannah Partner

Housing Distribution - Addingham

The present proposal for housing developments across the whole of Addingham is disproportionate to the neighbourhood plan agreed in 2019, which was set to achieve the previous target of new dwellings within the village considering minimal impact to the character of the village, environment, traffic, recreational spaces and impact on the school. These new plans have double the number of dwellings in areas of green belt and on the periphery of the village which would have multiple negative impacts on the aforementioned categories. Necessary affordable housing is important in all catchments of Wharfdale, however the numbers allocated to Addingham are disproportionate to other areas. The consultation time and method proposed is inadequate especially in the present pandemic as there will be many people who will not have digital access to voice their opinions. The consultation time should be extended until such time where residents can access community Internet facilities.

Object

Representation ID: 2672

Received: 21/03/2021

Respondent: Mr Kevin Nabb

Housing Distribution - Addingham

Addingham can not sustain any more houses. Bradford Council's own policy confirms major issues with sustainability in the village. Addingham has not got the infrastructure to accommodate more housing. We have been classed as a service centre therefore a lower number of housing developments due to sustainability (Housing Policy - Planning for homes 3.8 - SP8 , Housing Growth 3.8.40)

Why are we even considering building on greenbelt areas ? These should be protected.

We can not understand why Addingham's housing numbers have increased by 133 % when other neighbouring towns have had a reduction of 40 %.

We also object to running a consultation in a pandemic with everything based online. On such a sensitive issue which will effect everyone in Addingham for years why have Bradford Council not sent a leaflet to every household. Anyone without a computer or access to online facilities have been discriminated against.

Support

Representation ID: 2750

Received: 21/03/2021

Respondent: Mrs Helen Owen

Developers MUST be required to provide low cost, environmentally friendly, sustainable housing, NOT expensive 4/5 bedroom homes. Young adults should not have to move from the district in order to be able to purchase a home.

Object

Representation ID: 2779

Received: 21/03/2021

Respondent: Mr Robin Hargrave

Housing Distribution - Addingham

This is totally wrong, innumerate and illogical for Addingham.

Addingham is a Local Service Centre (described as having the emphasis on a smaller scale of development), has growth of 10.3% - being the highest in this tier, and nearly double the average of the other 10 centres.

Addingham's growth is also higher than Ilkley (only 4.2%), Keighley and Bingley which are meant to be the principal towns with the main emphasis on the provision of local housing, and also less than Bradford City, including Shipley and Baildon, (growth of 9.3%) which will be “the prime focus of new housing development” within the area.

Object

Representation ID: 2819

Received: 21/03/2021

Respondent: Mr Kevin McAllister

Housing Distribution - Shipley

The local plan has a disproportionate weighting towards Shipley, 1322 houses required when several other areas, in proportion to population have far fewer houses proposed e.g. Ilkley 300 and East Morton 10 homes. A fairer method of allocation should be used based on existing population size In particular I object to SH4/H. This is a greenfield protected site, with significant benefit to the local community. The local area here already struggles with traffic congestion, pollution and Nab Wood is increasingly a rat run with traffic calming measures introduced in recent years. There are several large sites in the immediately adjoining areas (shay grange golf , hallmark cards , Cottingley, Bankfield farm) which will result in almost 1000 homes being built in a very small area . The local plan has set targets on arbitary ward boundaries without considering collective impact on a local neighbourhood such as Nab Wood.

Support

Representation ID: 2887

Received: 21/03/2021

Respondent: Alison Tribe

Housing Distribution - Silsden

I agree with the Preferred Option although I have concerns about not using the Baseline Population Proportion, as mentioned previously. In order to minimise the impact on Silsden and Burley, the settlements where development is most at odds with population size, maximising housing is crucial.
Regarding M, 'The right infrastructure will be provided at the right time' - the right time is BEFORE the houses go up. Road junctions, recreatioinal space for children, sewage, electricity, safe access to railway stations (still not provided in Silsden despite the housing growth and the Council's stated aim of encouraging sustainable travel). If residents could see that the Council took this seriously, there might be less opposition to developments.

Support

Representation ID: 2897

Received: 21/03/2021

Respondent: Mr David Smith

Housing Need and Requirement
I very strongly support your view that 1,703 dwellings/year are adequate to meet Bradford's needs.
More recent 2016 and 2018 household projections are considerably lower and it seems likely that government will use these in the future (or 2020 based ones). With Brexit there is every reason to believe that international migration will be lower than assumed in the 1,703 figure.

The Government's 35% increase for Bradford and 19 other large cities is unreasonable and arbitrary. If it results in greater loss of Green Belt that is unacceptable.

Apart from London the total England housing requirement increases from around 290,000 to 300,000, through the 35% increase, so it does not add significantly to meeting the government's own arbitrary target. It seems extremely unreasonable for Calderdale's requirement to be only 800/year, but for Bradford's to be potentially increased from 1,703 to 2,300 given that both authorities are the same geographical size.

Object

Representation ID: 3048

Received: 21/03/2021

Respondent: Mrs Birgit Schluckebier

Housing Distribution - Burley in Wharfedale

I object to the proposed housing target for the settlement of 625 units.

I acknowledge that Burley in Wharfedale continues to be a designated local growth centre. However, the figure of 625 units is disproportionate in the context of the existing size and status of the village. An additional 625 dwellings would represent an increase of almost 25% to current number of housing. It is difficult to see how a relatively small settlement like Burley in Wharfedale could accommodate such a dramatic increase.

I am aware that planning permission has recently been granted for 500 dwellings to be built on the Sun Lane site in Burley in Wharfedale. I would respectfully submit that these additional 500 dwellings – representing an increase of about 18% on current levels – are certainly sufficient for Burley in Wharfedale and that no further allocation for housing is needed or indeed appropriate.

Object

Representation ID: 3115

Received: 22/03/2021

Respondent: Mr Carl McKeating

Housing Distribution - Addingham

Addingham has been allocated an unfairly high number of new houses in the plan. Per head of population, the number is the higher in the Bradford area.

Addingham is a traditional Dales village that should be preserved as such rather than overdeveloped.
Addingham is not a place where it is possible to build affordable housing for young families in Bradford.
Addingham does not have the infrastructure to support 175 new houses.

An alternative approach would be to look at current empty/dilapidated property near the centre of Bradford to redevelop for affordable housing. Invest in rewilding, creating safe green leisure spaces for the residents across the district and preserve those parts of the council area which are peaceful and unspoilt and popular for visitors from across the diverse population of the council area.

Support

Representation ID: 3250

Received: 22/03/2021

Respondent: Wilsden Parish Council

Previously Developed Land

We strongly support the targets to maximise the use of Previously Developed Land and minimise the development of greenfield sites, especially those in the Green Belt. Emphasis should be given to development of Previously Developed Land both inside and outside existing settlement boundaries.

Object

Representation ID: 3326

Received: 22/03/2021

Respondent: Mr Peter Miller

Housing Distribution - Addingham

The projected number of new houses is too high. This many will compromise the village feel with increased traffic and strain community resources like school and medical services. It threatens the biodiversity, green spaces and corridors so important for our wellbeing. The additional risk of flooding and pollution are also very real.

Object

Representation ID: 3386

Received: 22/03/2021

Respondent: IMCO Holdings

Agent: Tetra Tech (Manchester)

Housing Need and Requirement

Policy Parts A and B - The housing requirement target of 30,672 does not appropriately adopt the Government’s required 35% “cites and urban centres” uplift and its application for the District. The housing strategy is not suitably ambitious to address the District’s housing requirements in this regard and is a significant backwards step from the adopted Core Strategy. Further Green Belt release should appropriately be planned for through a greater dispersion of the housing need across the settlement hierarchy.

• It is our view that the overall housing requirement target of 30,672 for the District is not sufficiently ambitious and that the Plan should seek to meet the Government’s 35% “cities and urban centres” uplift within its housing targets.

Object

Representation ID: 3536

Received: 22/03/2021

Respondent: Climate Action Menston

Housing Distribution - Menston

We have already fulfilled the target for new build for Menston, and we should not be building any more large housing developments on greenbelt or infilling existing green spaces within the village.

As mentioned, modern methods of construction, whether using conventional or unconventional materials, should be encouraged where they can prove their effectiveness in reaching zero Carbon. The construction of the building should also be as low carbon as possible. This would require a major reduction in the use of concrete, and alternative forms of foundations where ground conditions permit.

Object

Representation ID: 3557

Received: 22/03/2021

Respondent: NEAT

Housing Need and Requirement

This policy is allowing housing growth to continue unchecked.
What will be the consequences of this? Bradford will become even more densely built on, with associated deterioration in mental and physical health. People from other areas that have not chosen not to build more houses at whatever cost (e.g. Lakes District, West Dorset, Surrey) will gravitate to areas such as Bradford, thus feeding the demand rather than reducing it. Eventually, there will be an even more marked social segregation, with the poor in urban ghettoes whilst the affluent can afford to live in areas where green/open space has been protected.

Key amendment: Change the word housing" to accommodation.
Don't even think about building on open space until every disused/under-used commercial property has been renovated for accommodation.

Object

Representation ID: 3676

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: 3765

Received: 23/03/2021

Respondent: Mr Andrew Lund

Housing Need and Requirement

The need for housing growth of the extent proposed has not been demonstrated. Such growth is not sustainable and the Council's sustainability and environmental assessments which seek to prove otherwise are overly judgemental and fail to recognise evidence to the contrary. which I provide in my specific representations on certain sites.

Object

Representation ID: 3805

Received: 23/03/2021

Respondent: Jenny Woodward

Housing Distribution - Bingley

I accept quality houses are needed, especially for people on lower incomes. However, the allocation is too high for Bingley (and possibly in other areas). Factors that need to be taken into account include:

The amount of houses that have been built in the last 10 years - Bingley has has hundreds.
More generally, Green Space Infrastructure standards (see Natural England's definition) need to be clearly set and adhered too i.e. if the building work means the standards are not reached (both for the new and existing housing stock) it should not be given planning permission. The most important standard is "at least 2 hectares of green space no more than 300m from home".

Also, all new houses that are built need to confirm to high environmental and health-giving standards e.g. no gas boilers, 'green' or 'natural' landscaping.

Support

Representation ID: 3941

Received: 23/03/2021

Respondent: Mrs Susan Burn

Housing Distribution

I have only chosen 'support' because there are only 2 options (support/object) available and on the whole I do support what BMDC is undertaking with this ambitious overall plan.

I would have preferred to have been able to register 'don't know'. I don't feel competent to comment on the plans for different, unfamiliar parts of the District.

I repeat my earlier observation - I think that the plan has failed to look at Burley/Ilkley/Addingham as an integrated community. The housing allocation for these 3 settlements will mean that the strong existing ties between these 3 settlements will be broken. I think this would be a dreadful loss to what is an extremely successful extended community where children grow up together in a safe, healthy and happy local society.

Object

Representation ID: 4168

Received: 23/03/2021

Respondent: Residents of Moor Lane, Turner Lane, Moor View and Moor Croft, Addingham

Agent: Airedon Planning and Design

Housing Distribution - Addingham

It is accepted that Addingham, as a Local Service Centre, is an appropriate location for some housing growth. However, the number of sites allocated to Addingham would mean that it will increase significantly in size, at a much higher rate than some of the Principal Towns and also a higher proportion of growth than some of the Growth Centres that are identified as sutainable locations for growth. Addingham is not a sustainable location for significant growth as it does not have the level of services or employment opportunities available in larger settlements. The Housing Allocations should roll-out the strategic policy SP3 and therefore allocate fewer houses to Addingham, and locate them in more sustainable locations.