Consultation Question 9

Object

Representation ID: 27890

Received: 23/03/2021

Respondent: Samantha Armitage

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: 27960

Received: 24/03/2021

Respondent: Bellway Homes Limited

Agent: Barton Wilmore

Housing Need and Requirement

The Council’s proposal to set the housing requirement at 1,704 dwellings per annum over the plan period is not in accordance with the MCHLG standard methodology.

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.

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, strategic constraints and infrastructure issues. Realistically nothing has changed in this regard and it is entirely unacceptable to claim otherwise.

By not including the 35% uplift, the Council are not using the standard method and in line with the PPG 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. Whilst a ‘brownfield first’ approach is advocated, it is not meant to be a ‘brownfield only’ approach.

As currently drafted the Policy is 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.

Object

Representation ID: 28128

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

Housing Need and Requirement

Johnson Mowat have particular concerns with the Draft Plan’s strategic approach to the overall housing requirement and the Council’s chosen approach of dismissing the Government requirement of a 35% uplift to the housing requirement (Policy SP8).

It is considered at the very least, the 35% uplift as required by the Government should be applied to the overall housing requirement, resulting in an annual requirement of 2,300 dwellings per annum, rather than the Council’s preferred approach of 1,704 dwellings per annum.

On this basis, the Draft Local Plan is over 10,000 dwellings short in its land provision, against the identified need (2,300 – 1,704 x 18 year plan period = 10,728).

Object

Representation ID: 28129

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

Housing Distribution - Bradford SE

The Draft Local Plan significantly increases the urban focus by directing more development to Bradford City Centre.

The Council have applied an urban focus uplift in terms of the distribution of development but without applying an uplift to the overall requirement. This results in a whole shift away from the distribution in the adopted Core Strategy, with disproportionate reductions to the majority of sustainable settlements and sub areas in the District, including South East Bradford.

The South East Bradford Area has seen significant reductions in the proportion of housing, with the Adopted Core Strategy requiring 6,000 dwellings, which was reduced to 3,100 in the Core Strategy Partial Review and now proposes a further reduction to 2,200 dwellings in the Draft Local Plan. This falls significantly short of the baseline population proportionate distribution which is 3,229 (SP8 Technical Paper).

It is important that the Holme Wood Urban Extension is not jeopardised by an inflexible and disproportionately reduced housing requirement in the Bradford South East Sub Area.

Object

Representation ID: 28189

Received: 24/03/2021

Respondent: Sarah Lucas

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: 28234

Received: 24/03/2021

Respondent: Hallam Land Management

Agent: Johnson Mowat

Housing Distribution - Bradford NW

The Preferred Option Draft Local Plan proposes 7,000 dwellings in the City Centre, a significant uplift from 3,500 in the Core Strategy, and 4,000 in the Draft Core Strategy Partial Review. The Council have therefore applied an urban focus uplift in terms of the distribution of development but without applying an uplift to the overall requirement.

This results in a whole shift away from the distribution identified in the adopted Core Strategy, with disproportionate reductions to the majority of sustainable settlements and sub areas in the District, including Bradford North West.

The reduction For Bradford NW from 4,500 dwellings (Adopted Core Strategy) to 2,900 dwellings in Policy SP8 falls significantly short of the baseline population proportionate distribution of 4,043 and is not supported

The overall requirement for the both Bradford North West and the District as a whole should be significantly higher. Applying the 35% uplift in the Bradford North West sub area using the same proportional distribution as the adopted Core Strategy results in the requirement for an additional 1,009 dwellings to be distributed to Bradford North West.

Object

Representation ID: 28279

Received: 24/03/2021

Respondent: Stephen Mould

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: 28432

Received: 24/03/2021

Respondent: Bellway Homes Limited

Agent: PB Planning

Housing Need and Requirement:

The Preferred Options Local Plan identifies that the Council will seek to deliver 1,704 homes per annum, which reflects the Standard Method Calculation without the Cities & Urban Centres Uplift required by Step 4 of the PPG’s prescribed methodology.

The actual minimum housing need is therefore 2,300 homes per annum not 1,704.

Whilst the use of the Standard Method is not mandatory, the PPG is clear that “there is an expectation that the standard method will be used, and that any other method will be used only in exceptional circumstances” (Paragraph: 003 Reference ID: 2a-003-20190220).

The Council’s Housing Need Addendum (February 2021) is inconsistent and incorrect in the way it addresses what the minimum level of housing need is. In particular, the Cities and Centres uplift the uplift is not a variable to be considered when determining if there is evidence to increase the minimum housing need, it is one of the four initial key steps which establishes that Bradford’s minimum housing need is 2,300 homes per annum.

As insufficient evidence has been provided to demonstrate that exceptional circumstances exist for the removal of the Cities & Urban Centres Uplift from the Standard Method calculation, the Local Plan should seek to deliver 2,300 homes per annum over the plan period 2020-2038. Which equates to 41,400 homes.

Object

Representation ID: 28433

Received: 24/03/2021

Respondent: Bellway Homes Limited

Agent: PB Planning

Housing Distribution - Keighley

As insufficient evidence has been provided to demonstrate that exceptional circumstances exist for the removal of the Cities & Urban Centres Uplift from the Standard Method calculation, the Local Plan should seek to deliver 2,300 homes per annum over the plan period 2020-2038. Which equates to 41,400 homes.

If the level of housing distribution to Keighley was retained at 7% the uplift would require the delivery of 2,898 homes within the plan period, an increase of 698 homes. However, retaining the adopted Core Strategy’s level of distribution (11%) would require the delivery of 4,554 homes over the plan period. Which is a level of housing growth which was previously considered sustainable and deliverable following a thorough examination in public process.

Object

Representation ID: 28468

Received: 24/03/2021

Respondent: Lovell Homes

Agent: PB Planning

Housing Need and Requirement:

The Preferred Options Local Plan identifies that the Council will seek to deliver 1,704 homes per annum, which reflects the Standard Method Calculation without the Cities & Urban Centres Uplift required by Step 4 of the PPG’s prescribed methodology.

The actual minimum housing need is therefore 2,300 homes per annum not 1,704.

Whilst the use of the Standard Method is not mandatory, the PPG is clear that “there is an expectation that the standard method will be used, and that any other method will be used only in exceptional circumstances” (Paragraph: 003 Reference ID: 2a-003-20190220).

The Council’s Housing Need Addendum (February 2021) is inconsistent and incorrect in the way it addresses what the minimum level of housing need is. In particular, the Cities and Centres uplift the uplift is not a variable to be considered when determining if there is evidence to increase the minimum housing need, it is one of the four initial key steps which establishes that Bradford’s minimum housing need is 2,300 homes per annum.

As insufficient evidence has been provided to demonstrate that exceptional circumstances exist for the removal of the Cities & Urban Centres Uplift from the Standard Method calculation, the Local Plan should seek to deliver 2,300 homes per annum over the plan period 2020-2038. Which equates to 41,400 homes.

Object

Representation ID: 28469

Received: 24/03/2021

Respondent: Lovell Homes

Agent: PB Planning

Housing Distribution - Bradford NW

As insufficient evidence has been provided to demonstrate that exceptional circumstances exist for the removal of the Cities & Urban Centres Uplift from the Standard Method calculation, the Local Plan should seek to deliver 2,300 homes per annum over the plan period 2020-2038. Which equates to 41,400 homes.

Meaning sufficient land to allocate a further 10,728 homes will need to be found within the District, and the PPG identifies in Paragraph: 035 Reference ID: 2a-035-20201216 that the increase in the number of homes to be delivered through the Cities & Urban Centres Uplift is expected to be met by the cities and urban centres themselves, rather than the surrounding areas, unless it would conflict with national policy and legal obligations.

Lovell Homes’ site at Allerton Road, Bradford is located within the defined area of the Regional City of Bradford and should therefore be considered as an additional housing allocation to meet the increased housing needs of the District within future version of the Local Plan.

Furthermore, even if the level of housing distribution to the North West Area of Bradford was retained at 9% this would require the delivery of 3,726 homes within the plan period, an increase of 826 homes.

Retaining the adopted Core Strategy’s level of distribution (11%) would require the delivery of 4,554 homes. Which of course is a level of housing growth which was previously considered sustainable and deliverable following a thorough examination in public process.

Object

Representation ID: 28522

Received: 26/03/2021

Respondent: Member of Parliament (Labour)

Housing Distribution - Bradford South Constituency Area

Housing requirement altered significantly from the Core Strategy (CS) (41,000+), Core Strategy Partial Review (CSPR) (26,100) and draft Local Plan (dLP) (30,672). Change not reflected across the District with Regional City taking significantly increased share.

CSPR requirement was opportunity to safeguard Green Belt - has not happened as dLP requires 5,267 dwellings in it.

Bradford South will suffer disproportionate burden of additional housing and Green Belt loss. 3,500+ dwellings proposed (11% of District requirement), 57% of which are Green Belt (1/3 of district’s total), with the majority (1,500) in one area. Neither equitable/sustainable.

Given Green Belt’s importance/sensitivity, its use should be minimised and development density towards the higher end. Green Belt sites average density (24/Ha) is below that of non-Green Belt sites outside main city/town centres, except Bradford South (28/Ha).

Area highly urbanised with overstretched infrastructure. Will add disproportionate burden on communities by removing more accessible Green Belt and intensifying urbanisation. Will give rise to health/wellbeing concerns.

Does not accommodate additional Government target (10,500 dwellings). Will have to come from Regional City. Concern it can only be met from Green Belt loss/further urban density in Bradford South.

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.

Object

Representation ID: 28525

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

Housing Distribution - Bradford City Centre / Regional City

Our Client objects to the proposed distribution of housing which is also set out in the policy. The Council are proposing to deliver 7,000 units into Bradford City Centre, which is an increase of 3,500 units when compared to the adopted Core Strategy.

Whilst it is understood why the Council are seeking to deliver a high level of new housing in the City Centre, the reality is it is highly unlikely that this will be achieved given the deliverability issues in the City Centre. Whilst unfortunate, it is an issue that the Council have faced for several years and it is not considered that the situation has changed since the adoption of the Core Strategy and doubling the target is not justified.

The Covid-19 pandemic is likely to have an impact upon people’s aspirations in terms of where they aspire to live and what they require in terms of quality of life.People want to live close to countryside and green spaces. By the Council’s own admission, the City Centre has a significant deficiency in green spaces.

The distribution to Bradford City Centre should be retained at 3,500 units, with the excess 3,500 units spread around the remainder of the Regional City of Bradford

Object

Representation ID: 28695

Received: 24/03/2021

Respondent: Chatsworth Settlement Trustees

Housing Distribution - Keighley / Principal Towns

Policy SP8 - there is insufficient housing distributed to the Principle Towns and to Keighley within this group of settlements which fulfill a District wide significant role as service, employment and transport hubs for their surrounding areas. A very significant increase is not required but a level more in line with the baseline distribution for Principle Towns, including Keighley, would serve to deliver the plans spatial priorities, better reflect ands deliver the settlement hierarchy and thereby achieve sustainable development.
To support this position:
- a 6% increase for Regional City but a 22% reduction for Principle Towns and a $£% increase for local growth centres (baseline to preferred distribution)
- Policy SP2
- Policy SP3 ... Keighley to be main focus for housing...place to live
- By not fulfilling SP2/SP3 you are not meeting Policy SP1 on delivering sustainable development.

Comment

Representation ID: 28723

Received: 25/02/2021

Respondent: Dr Ros Brown

Housing Need and Requirement

We are content with the proposed numerical housing requirement. We strongly support the council’s proposed approach to dealing with the 35% uplift for urban centres because, for this if the uplift were added to the general requirement it could easily result in allocation of peripheral, Green Belt sites that would be poorly targeted for regeneration. The uplift is a policy intervention to boost urban centres, so it would be counterintuitive and counterproductive for it to result in more peripheral development.

Object

Representation ID: 28724

Received: 25/02/2021

Respondent: Dr Ros Brown

Components of supply
The components of supply identified in SP8D effectively describe a sequential approach to supply and the two broad locations for growth. We infer from this that land for the broad locations would be removed from the Green Belt but not allocated. It is difficult to compare this information and the information on the policies map with the list of Green Belt release sites identified in policy SP5, considering that a significant proportion have the total housing supply identified to come from Green Belt is located within the broad locations for growth. It is also unclear whether those broad locations for growth are intended to supply further housing numbers beyond the plan period.
It is of great concern that we cannot see from the draft Plan the proposed what the extent of land-take in the broad locations for growth within and beyond the plan period is likely to be.

Object

Representation ID: 28727

Received: 25/02/2021

Respondent: Dr Ros Brown

Housing Distribution

It would be helpful to know which of the settlements in Schedule 1 have prepared or are preparing neighbourhood plans. SP8F implies that neighbourhood plans could provide for additional housing numbers above and beyond those in Schedule 1, but it appears that the distribution in Schedule 1 has been derived from the availability of known sites and their indicative capacity.

In many cases we know that communities are objecting not to the numerical target itself but to specific site allocations.

Therefore it is important that SP8F is worded to empower neighbourhood plans to specify the type and density of housing, such that meeting or exceeding the numerical target but on fewer sites, or on more smaller sites, is an acceptable role for the neighbourhood plan.

Object

Representation ID: 28731

Received: 25/02/2021

Respondent: Dr Ros Brown

Previously Developed Land

Based on our calculations and assumptions and applying the numbers within the policy i.e. if the brownfield sites achieve 50dpha, but the greenfield sites are developed at the densities which appear to be prevailing in the allocations, then by land area the Plan may only be achieving 37% of housing on brownfield land.

This leads us to conclude that the Plan is not making the most effective use of land, and is not in conformity with NPPF para 137. Indeed, it suggests that the Green Belt land-take may be almost double what it would need to be if density expectations were properly applied.

Consequently, even if the district-wide brownfield rate remained at 50%, it appears that the proposed greenfield land take in the Plan is approaching double what it would need to be if all greenfield development were built to the policy-compliant 50dhpa net.

In other words:
• roughly half of all the proposed greenfield land allocation is a product of low densities, not of meeting development need;
• the majority of Green Belt housing allocations are proposed to be developed well below the densities required by the Plan’s policies relating to density.

This being the case, then the exceptional circumstances for Green Belt releases have not been demonstrated, because the resulting allocations will be profligate in their use of land

Object

Representation ID: 29010

Received: 23/04/2021

Respondent: Abi Lafbery

Housing Distribution - Burley In Wharfedale / Previously Developed Land

•The proposed development of 500 homes at Sun Lane in addition to the 190 homes already delivered in the original Plan Period (according to the MHCLG’s ruling at Sun Lane, point 358) would mean Burley in Wharfedale has met the set housing obligation detailed in the existing Core Strategy apart from 10 homes. As it is proposed that 12 homes will be delivered on the site located at the Old Hermit Public House in Burley Woodhead, this will fulfil Burley’s requirement to deliver 700 homes in the current plan period.
•The new figure constitutes an increase in target from 700 to 750 homes. Could Council explain why Burley have an extra allocation, when many other urban areas have a fall in housing allocation?
•The local plan comments that it will prioritise the allocation of brownfield and non-Green Belt sites first then taking a measured and sensitive approach to Green Belt release. In the first 5 years of the proposed plan period, Bradford will release 666 homes on brownfield (previously developed land), 648 homes on greenfield, 621 homes on green belt (77% of which will come from Sun Lane). This will still leave a shortfall of 6,580 homes and appears contradictory to the desire to release non-Green belt first.

Object

Representation ID: 29011

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

Housing Need and Requirement

The Councils housing requirement is established by using the governments Standard Methodology, which due to an update last year, now includes a 35% uplift over the previous requirement.

The Council’s plan was clearly drafted ahead of this amendment to the methodology and based on the previous version of the Standard Method. The changes to the method are not reflected in the preferred options version of the plan and the Council are currently planning for a significant under delivery (circa 9,000) over the plan period as they are not proposing to include the 35% uplift as required by the standard methodology.

The Council produced a Core Strategy, based on a comprehensive evidence base, examined by an independent Inspector and adopted by the Council. Following adoption of the plan, the government released a Standard Methodology for assessing housing requirements, which at the time provided a much lower level of homes. Rather than allocate sites in accordance with the adopted Core Strategy, the Council took the opportunity to review that plan almost immediately, with a view to supressing the amount of homes that would be delivered.

Given the time that has lapsed since then, the Government have since amended the Standard Methodology and the level of homes now required is similar to that in the adopted Core Strategy.

The Councils simple justification for the avoidance of using the Standard Methodology figure is that there is insufficient infrastructure and the level of homes is not deliverable.

This position is seemingly unfounded, given that only three years ago the Council produced an independent evidence base that demonstrated that this level of homes was both deliverable and viable.

Whilst this amendment to the Standard Method may have been released whilst the draft plan was going through the Councils internal process, rather than pause and implement the changes, two dismissive paragraphs have been added to the text with little justification or assessment to say why it is not viable.

The Standard Method does not provide this flexibility, the level of homes is a minimum and the Councils reluctance to adhere to it needs to be amended as soon as possible so as to not add significant delay to the adoption of the plan and further compound the significant under performance of delivering homes.

The delivery of homes in Bradford is significantly below what is needed. The Council have a woeful five year supply and fail consistently in meeting the housing delivery Test. Ironically having failed the housing delivery test, partly in part due to abandoning the adopted plan, the Councils action plan included the need to allocate more housing sites, the very thing they had abandoned in favour of seeking a lower housing figure.

The Council were adamant that the housing figures in the Standard Method were the most appropriate to use and as such were willing to abandon five years worth of work on an adopted Core Strategy due to the need to follow the Standard Method. The lack of enthusiasm for following that method when doing so doesn’t result in a 35% reduction in housing is clearly unreasonable.

The NPPF is clear that we should be significantly boosting the supply of homes and the reticence to not follow the Standard Method (coincidentally almost the same as a recently adopted figure) is clearly contrary to national planning policy and would result in an unsound plan.

Object

Representation ID: 29012

Received: 23/04/2021

Respondent: Abi Lafbery

Previously Developed Land

•There is sufficient housing land to build a significant number of homes that is classified as unviable for housing delivery. Whilst we accept that some elements of Brownfield may be unviable, why is it that land that would support the delivery of a significant number of homes still unviable 16 years after identification?
•There are 5,000 unoccupied properties in 5 areas of Bradford, the City Centre, Bradford NE, NW, SE, SW. Unviable and unoccupied housing could accommodate a significant proportion of the housing need in the plan period.

Object

Representation ID: 29015

Received: 23/04/2021

Respondent: Abi Lafbery

•The Parish Council would like to express their deep concern about the credibility of many of the policies in the Local Plan, many of which originally appeared in the RUDP and district ‘Vision’ documents. Our concern is that there is insufficient evidence to back up these statements, the nature of the district has changed (e.g. losses in the financial services sector) and there is no measurable evidence of progress (e.g. improving Brownfield viability, or achieving a highly skilled workforce).
•The Parish Council 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.
•The 2011 census shows that 55,755 of Bradford District’s workforce commute to other districts (predominantly Leeds – 27,500) for work. The net outflow from the Bradford district in 2011 was 5,316. This is a complete reversal of the data seen in the 2001 census, which saw a net inflow into the Bradford District of around 5,000.

Comment

Representation ID: 29037

Received: 23/03/2021

Respondent: Anne & H Graham Peacock

Number of people: 2

Components of Supply - Windfall

In addition, many other housing units have been, and are likely to continue to be built by garden division sites and demolition of existing houses which have been replaced by several new units. In Ilkley approximately 25 dwellings per year are generated from windfall sites.

Object

Representation ID: 29038

Received: 23/03/2021

Respondent: Anne & H Graham Peacock

Number of people: 2

Previously Developed Land

Fundamentally, national government policy is for ‘Brownfield first’. So development sites should be found within parts of Bradford District, particularly nearer the city centre where housing will be more ‘affordable’. We have seen that central support for restoring brownfield sites is available : https://www.thetelegraphandargus.co.uk/news/19154067.developers-can-apply-grants-help-build-brownfield-sites-bradford/ T & A 12 March.
Furthermore, WYCA has recently announced funding of £167m to BMDC to support brownfield development.

In terms of Ilkley brownfield sites reusage of the former ’Tesco’ land on Railway Road yielded a significant number of housing units as well as employment land – all since work started on the Ilkley Neighbourhood Plan.

Comment

Representation ID: 29176

Received: 24/03/2021

Respondent: Environment Agency

Previously Developed Land

Within the supporting text of this policy, under ‘Maximising brownfield land’, we recommend the inclusion and reference to NPPF paragraph 170 and 178 regarding conserving and enhancing the natural environment, along with ground conditions and pollution.

Object

Representation ID: 29212

Received: 23/03/2021

Respondent: Rachel Wood

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: 29432

Received: 24/03/2021

Respondent: The Black Family

Agent: Johnson Mowat

Housing Need and Requirement:

Johnson Mowat have particular concerns with the Draft Plan’s strategic approach to the overall housing requirement and the Council’s chosen approach of dismissing the Government requirement of a 35% uplift to the housing requirement (Policy SP8). It is considered at the very least, the 35% uplift as required by the Government should be applied to the overall housing requirement, resulting in an annual requirement of 2,300 dwellings per annum, rather than the Council’s preferred approach of 1,704 dwellings per annum. On this basis, the Draft Local Plan is over 10,000 dwellings short in its land provision, against the identified need (2,300 – 1,704 x 18 year plan period = 10,728).

In the case of the partial rejection of SHLAA Site KY/003, off Hollins Lane, the site falls within and on the edge of Keighley Urban Area where the 35% uplift to the housing requirement should apply. It is considered therefore that the Local Plan should identify additional sites in and on the edge of the urban area to accommodate the housing requirement uplift. This site lies in a sustainable location, it is available and suitable now and is a deliverable site that should be included within the Local Plan.

Object

Representation ID: 29434

Received: 24/03/2021

Respondent: The Black Family

Agent: Johnson Mowat

Housing Distribution - Keighley

The Draft Local Plan significantly increases the urban focus by directing more development to Bradford City Centre.

The Council have applied an urban focus uplift in terms of the distribution of development but without applying an uplift to the overall requirement. This results in a whole shift away from the distribution in the adopted Core Strategy, with disproportionate reductions to the majority of sustainable settlements and sub areas in the District, including Keighley.

Keighley has seen significant reductions in its housing apportionment, with the Adopted Core Strategy requiring 4,500 dwellings, which was reduced to 2,800 in the Core Strategy Partial Review and now proposes a further reduction to 2,200 dwellings in the Draft Local Plan. This falls significantly short of the baseline population proportionate distribution which is 2,602.

As a starting point a target of 2,958 for Keighley is proposed resulting in the need to find sites for an additional 758 dwellings.

Object

Representation ID: 29439

Received: 24/03/2021

Respondent: The Illingworth Family

Agent: Johnson Mowat

Housing Need and Requirement:

Johnson Mowat have particular concerns with the Draft Plan’s strategic approach to the overall housing requirement and the Council’s chosen approach of dismissing the Government requirement of a 35% uplift to the housing requirement (Policy SP8). It is considered at the very least, the 35% uplift as required by the Government should be applied to the overall housing requirement, resulting in an annual requirement of 2,300 dwellings per annum, rather than the Council’s preferred approach of 1,704 dwellings per annum. On this basis, the Draft Local Plan is over 10,000 dwellings short in its land provision, against the identified need (2,300 – 1,704 x 18 year plan period = 10,728).

In the case of the partial rejection of SHLAA Site KY/003, off Hollins Lane, the site falls within and on the edge of Keighley Urban Area where the 35% uplift to the housing requirement should apply. It is considered therefore that the Local Plan should identify additional sites in and on the edge of the urban area to accommodate the housing requirement uplift. This site lies in a sustainable location, it is available and suitable now and is a deliverable site that should be included within the Local Plan.