Consultation Question 9

Object

Representation ID: 29440

Received: 24/03/2021

Respondent: The Illingworth 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: 29545

Received: 24/03/2021

Respondent: The Thompson 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).

Object

Representation ID: 29546

Received: 24/03/2021

Respondent: The Thompson 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: 29565

Received: 23/03/2021

Respondent: Harvey Bosomworth

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: 29605

Received: 17/03/2021

Respondent: Mr Mark Summerson

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?

Comment

Representation ID: 29657

Received: 24/03/2021

Respondent: Leeds City Council

Housing Need and Requirement

1. Housing and green belt release.

a. The plan proposes allocations for 30, 672 new homes required over the plan period 2020-2038, which equates to 1,704 dwellings per annum. The vast majority of the proposed allocations needed to meet these requirements are on brownfield land, which is supported.

It is noted that some greenfield and green belt land is also required. The Council notes that exceptional circumstances for the release of green belt relate solely to the need to meet the overall housing number. This housing number does not include the Government uplift of 35% which would require an additional 10,735 new homes, totalling 41,407 if uplift was applied. Whilst we understand that were this higher number to be addressed it is highly likely that more greenfield and green belt land would need to be released we would welcome this being formally tested as a reasonable alternative so that we could understand and provide a view on its impacts, particularly with regard to the spatial strategy, further green belt encroachment/release, phasing of development and the wider impacts upon infrastructure and school place planning. We understand that Bradford intend to carry out further evidence in support of this and wish to reserve our position on this until further evidence/information is provided through further consultation (with specific Leeds sections such as Highways and Children’s Services) and/or duty to cooperate discussions.

Object

Representation ID: 29682

Received: 24/03/2021

Respondent: Redrow Homes

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: 29683

Received: 24/03/2021

Respondent: Redrow Homes

Agent: Johnson Mowat

Housing Distribution - Ilkley

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 Ilkley.

Ilkley has seen significant reductions in its housing apportionment, with the Adopted Core Strategy requiring 1,000 dwellings, which was reduced to 500 in the Core Strategy Partial Review and now proposes a further reduction to 300 dwellings in the Draft Local Plan. This falls significantly short of the baseline population proportionate distribution which is 756.

The 35% uplift to the housing requirement should apply to Ilkley.

As a starting point a target of 657 for Ilkley is proposed resulting in the need to find sites for an additional 357 dwellings.

Object

Representation ID: 29695

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Barton Wilmore

Housing Distribution - Bradford City Centre & Menston

The Council’s approach to distribution in the draft Local Plan is considered to be flawed for a number of reasons. Firstly, the decision to uplift the target from 3,500 (4,000 in the Core Strategy Review) to 7,000 is a mistake given Bradford’s historic deliverability issues in the City Centre.

Not only that, it is at odds with the likely shift in living expectations following the Covid-19 pandemic, which is likely to see an even greater desire for more rural living, in areas close to countryside and green space.

The extent of housing in the City Centre should be retained at 3,500 as per the adopted Core Strategy and the residual 3,500 spread out around the District.

In terms of Menston, which is one of six Local Growth Centres, it has been apportioned the 2nd lowest distribution. Menston is closely related to Guiseley, which the two settlements almost merging into one, and it is therefore more sustainable than settlements such as Burley-in-Wharfedale and should be apportioned a similar level of new homes.

Object

Representation ID: 29699

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Barton Wilmore

Housing Distribution - Cottingley

The Council’s approach to distribution in the draft Local Plan is considered to be flawed for a number of reasons.

Firstly, the decision to uplift the target from 3,500 (4,000 in the Core Strategy Review) to 7,000 is a mistake given Bradford’s historic deliverability issues in the City Centre. Not only that, it is at odds with the likely shift in living expectations following the Covid-19 pandemic, which is likely to see an even greater desire for more rural living, in areas close to countryside and green space.

In terms of Cottingley, it is closely linked to Bingley and is a short distance away from this Principal Town. We would question why it has been allocated fewer homes than Haworth as an example, which is an isolated settlement , which is poorly related to Keighley, the nearest Principal Town.

Cottingley is well served by local services in its own right an can accommodate additional growth over and above what is being proposed.

Object

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.

Object

Representation ID: 29707

Received: 24/03/2021

Respondent: Keyland Developments Ltd

Agent: Barton Wilmore

Housing Distribution - Regional City

Objects to the proposed distribution - the Council are proposing to deliver 7,000 units in 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 this is 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.

Following the Covid pandemic people's aspirations are to live close to the countryside and green spaces. By the Council’s own admission, the City Centre has a significant deficiency in green spaces, and it is not feasible to make such a significant increase when it is unlikely to be delivered.

It is noted that the Council are seeking to limit the extent of land released from Green Belt, however, this should not be the main driver in setting the level of distribution, the ability to deliver the housing requirement should take precedence.

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: 29737

Received: 24/03/2021

Respondent: Mrs Caroline Whitaker

Housing Distribution - Silsden

It appears that the Town is still, despite a reduced target, bearing the brunt of the plan’s housing allocation. It seems it has been given this huge target by default because it is surrounded by green fields, rather than because of local housing need ie the site allocation for houses 'works backwards' from sites that are easy to deliver such as low density greenfield sites which commercial housebuilders will happily deliver.

Following on from this Silsden is saddled with a disproportionately large (700) number of new houses. This is on top of the hundreds that we have already seen built in recent years.

Looking simply on the basis of existing population, our allocation would be just over 400 new houses.

In addition the suggested numbers on sites in Silsden would deliver a density of 28.6 units per hectare, which is considerably below the Councils stated policy HO2 which calls for a minimum density of 35 units per hectare.

Since these houses are unlikely to be occupied by people working in local industry, it drives up the number of commuter journeys, is wasteful in land resources and imposes a damaging environmental impact. All of which is goes against the stated net-zero carbon strategy and transport policies.

I WOULD LIKE TO SEE

• A reduction in the housing allocation for Silsden. Note also that since the publication of the draft plan, planning permission has been granted for a further 40 house at The Willows (ref 20/03878/MAO), next to the canal and, in addition, the brownfield site Land And Premises At Rotary Works 121 Bolton Road Silsden West Yorkshire BD20 0JF (ref. No: 20/05292/MAF0 for 20 dwellings (adjacent to already approved 18/05140/MAR) looks likely to be approved shortly. This has not been taken into consideration with the total number and size of sites required to meet the target housing numbers in the draft.

Comment

Representation ID: 29769

Received: 25/03/2021

Respondent: Ilkley Town Council

Components of Supply - Windfall

Housing from windfall sites and development that takes place before the Plan is adopted should be removed from the total number of houses required in the Ilkley settlement.

Comment

Representation ID: 29771

Received: 25/03/2021

Respondent: Ilkley Town Council

Housing Distribution - Ilkley

Bradford is being required by central government to build a given number of new houses. Given the numbers being proposed in other settlements locally, the number of 283 houses allocated for Ilkley does not seem unreasonable. For example:
Silsden allocation 522 dwellings
Addingham allocation 163
12
Burley in Wharfedale allocation 549
Menston allocation 181
Steeton allocation 169
Bingley allocation 703
Baildon allocation 195
Shipley allocation 1189

If we accept that 283 houses are reasonable, then two further issues necessarily arise:

(a) the type of housing; and
(b) the area of land necessary.

Object

Representation ID: 29773

Received: 25/03/2021

Respondent: Ilkley Town Council

Previously Developed Land

If the Council were to provide for the 35% uplift (around 10,000 homes) in a way that fulfils the expected urban centre focus, this would amount to a significant shift in the spatial distribution of housing towards the urban centre. By implication, this suggests that the current 50% brownfield target for the district does not reflect the total amount of brownfield land across the district, but rather that the Council has chosen to distribute development to the other levels of the settlement hierarchy in a way it considers reflects the development needs of the other settlements, but does not necessarily maximize the district-wide use of brownfield land.

Object

Representation ID: 29793

Received: 23/03/2021

Respondent: Ilkley Civic Society

Previously Developed Land

The NPPF para 138 strongly favours the use of brownfield sites over green field and green belt despoilation. Bradford Council area is substantially endowed with brown field sites, many of which are easily accessible to the city centre. The council wants to develop the city centre as part of urban regeneration. Some brownfield sites are urban waste and leaving them in that state detracts from Bradford ever becoming a commercially thriving city. Using Wharfedale green belt sites for housing in no way supports the city centre. It merely provides costly overspill housing for Leeds.

The allocation of green belt sites for housing in preference to the allocation of brown field sites contradicts the NPPF and Bradford’s own strategies for economic regeneration.

WYCA FUNDING
WYCA has recently announced funding of £167m to BMDC to support Brownfield development. While this initiative is welcome, it also reinforces the need to develop brownfield sites first. Making green belt available for housing development undermines this funding.

Object

Representation ID: 29794

Received: 23/03/2021

Respondent: Ilkley Civic Society

Components of Supply - Windfall

In Ilkley, approximately 25 dwellings per year are generated from windfall sites. These are as a result of using gardens, domestic demolition and re development. With the post-Covid changes to the High Street expected to have some impact another series of dwellings may be achieved via permitted development rights. These should all be taken into account.

SITES NOT YET AVAILABLE
When the plan lifespan was extended to 2038, consideration should have been given to sites which by that time may become available, for example, the sewage works in Ilkley.

Additional windfall sites are likely to arise from shop and office conversions to residential, which may be covered by permitted development rights. We are beginning to see commercial to residential conversions in central Ilkley as a result of the pandemic and business closures.

Object

Representation ID: 29803

Received: 23/03/2021

Respondent: Ilkley Civic Society

Housing Need and Requirement

We feel strongly that NO decisions should be taken about housing until after the Pandemic is over and commercial life revives. The plan including the core strategy were conceived and established during the period before either Covid 19 or Brexit became the main economic factors in the UK. Until the pandemic crisis is over and some economic stability is regained, people will not know where they want work and live, how much they will need to travel, how much they can afford on housing or the type of housing they need.

The emphasis at present should be on ensuring progress in building all those homes which already have planning permission, in order to meet current demand.

Object

Representation ID: 29812

Received: 23/03/2021

Respondent: Addingham Parish Council

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.

Object

Representation ID: 29910

Received: 17/03/2021

Respondent: Bridge View Developments Ltd

Agent: Bradley Stankler Planning

Housing - Components of Supply

•The 10% discount on committed sites for non-implementation is an under-estimate for sites in Thornton.
•Existing sites are long-standing commitments with constraints and are unlikely to make a meaningful contribution to the housing requirement for Thornton.
•The likely contribution from commitments will be 80%, therefore the committed sites are likely to achieve 35 dwellings, not 43. Land for a further 8 dwellings will need to be allocated.
•Application of the 10% reduction for non-delivery/non-implementation on the allocated sites is unreasonable and fails to take account of individual site circumstances.
•An assessment of the draft allocations indicates that a number of the sites are constrained and the blanket 10% reduction is not supported by evidence. The number of dwellings likely to be achieved will be significantly lower.

Object

Representation ID: 29913

Received: 24/03/2021

Respondent: The Laver Family

Number of people: 2

Agent: Johnson Mowat

Housing Distribution - Baildon

The housing target in Baildon in the Draft Local Plan is 250 dwellings (Policy SP8), which includes the proposed allocation of six greenfield sites, including three Green Belt sites, of which BA2/H and BA6/H form two of.

The housing target in Baildon is significantly below the baseline distribution of the housing requirement based solely on population, which is 820 dwellings.

The Council’s Housing Growth Technical Note refers the significant difference between the baseline target and the preferred distribution in Baildon and justifies this as being due to the lack of suitable sites and land supply being the main issue. Clearly BA2/H and BA6/H are important sites, required to meet the proportionately low housing requirement in Baildon.

It is our clients position that whilst the inclusion of BA2/H and BA6/H are supported it is considered that the overall requirement for both Baildon and the District as a whole should be significantly higher.

Object

Representation ID: 29933

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

Land Supply & Housing Mix

Our analysis reveals deliverability issues and constraints on a number of proposed City Centre sites (see schedule for details). There is limited evidence of many of the sites which date in cases back to 2012 being imnplemented.

We conclude that there are doubts about the following sites – CC1, CC2, CC6, CC10, CC12 CC13, CC15/H, CC16, CC18, CC19, CC21, CC23, CC25, CC28, CC29 with a potential lost capacity of 2,476 units and an overall shortfall against the 7,000 requirment for the City Centre of 4,500 units

Recommendation 1: BMDC need to allocate a developable mix of housing sites to account for the c.-4,500-unit shortfall in Brownfield City Centre sites alone. In the interests of an effective plan in accordance with the NPPF.

Object

Representation ID: 29954

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

Housing Need and Requirement

Having regard for the New Standard Methodology, the 35% cities and urban centres uplift equates to an additional 596 homes per year within the Bradford District and creates a ‘policy on’ housing need figure of 2,300 new homes per year. This is a significant increase from the 1,704 proposed within policy SP8. It is therefore a matter of national policy that the local authorities with the 20 largest urban areas meet these new figures. We understand this is not optional.

Recommendation 4: The Council implement the 35% uplift as set out by MHCLG. BMDC should therefore adopt a housing target of at least 2,300 dpa in the interests of NPPF compliant, justified and positive plan making. We understand this is not optional.

Recommendation 5: The Council should review its evidence base to understand and adopt a ‘policy on’ housing figure to align the ambitions of the Leeds City Region Growth Strategy, in the interests of justified and positive plan making.

Object

Representation ID: 29955

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

Housing Distribution - Bradford SE

Within Schedule 1 of Policy SP8 we note the level of housing distributed to the South East of Bradford has reduced from 4,000 dwellings within the adopted Core Strategy to 3,030 in the 2019 Core Strategy Partial Review and now to 2,200 dwellings.

We note this is partly as a result of the significant levels of growth attributed to Bradford City Centre which is a risk as we have detailed elsewhere.

The Core Strategy Review was predicated on 1,704dpa and as paragraph 5.32.21 lists there is a
comprehensive evidence base which has led to the 3,030 figure. It is unclear why the 2021 plan has now changed to derive a lower figure still, despite the risk in overlying on city centre sites and need to effectively meet regeneration objectives vs. the availability of developable sites such as reference SE/163. Draft 2021 Plan Paragraph 5.3.21 – 5.3.23 offers no explanation in the way 5.32.21 and therefore can only be regarded as unsound.

Recommendation 6: Provide greater evidence base justification for the reduction in housing targets for South East Bradford, in the interests of effective plan making.

Object

Representation ID: 29982

Received: 24/03/2021

Respondent: Ilkley Town Council

Previously Developed Land

Firstly, I am concerned about a possible lack of building on Brown Field sites in Bradford. Building on Brown Field sites is important as it helps in the regeneration of the city, something that Bradford desperately needs. It is important that Bradford looks to building on brownfield sites first before building on Green belt areas which are important for people living in the area. I am not convinced that Bradford has in fact made as much use as possible of suitable brown field sites in Bradford to fulfil its aims for increased urban regeneration.

Object

Representation ID: 30004

Received: 23/03/2021

Respondent: Daniel Spencer

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: 30038

Received: 24/03/2021

Respondent: Banks Property

Housing Distribution

In determining its housing requirement, the Council has not applied a 35% uplift in accordance with the Government’s latest Standard Method (Dec 2020).

We consider that more housing allocations should be identified to reflect a move towards this uplift. The 35% uplift applies to the whole authority area. The Council therefore has options to allocate more housing by releasing more land on the periphery of the city and wider areas in a more dispersed approach to development.

There are also notable inconsistencies in the current approach to spatial distribution and settlement hierarchy, for example the allocation of only 300 units in the Principal Town of Ilkley. More allocations should be distributed across the mid and lower tiers of the settlement hierarchy to achieve sustainable development and growth across the district.

Object

Representation ID: 30054

Received: 17/03/2021

Respondent: Clive Brook Planning

Housing Distribution

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. less

Object

Representation ID: 30055

Received: 17/03/2021

Respondent: Mrs Helen Miller

Housing Distribution - Ilkley & Wharfedale

In addition, 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 or Bradford employment opportunities, or indeed employment opportunities in Ilkley itself.