Consultation Question 9

Object

Representation ID: 30056

Received: 24/03/2021

Respondent: Mitre Residential LPP

Agent: DPP Planning

Housing Distribution - Bradford City Centre & Queensbury

There is no reason why the housing requirement provided by the standard methodology cannot be met and this housing requirement should be distributed appropriately in accordance with the settlement hierarchy expect for Bradford City Centre.

We object to the housing distribution set out in Policy SP8 in respect of Bradford City Centre and suggest that the current provision should be decreased and dispersed across the District.

Object

Representation ID: 30057

Received: 22/03/2021

Respondent: Robbie Feather

Agent: ID Planning

Housing Distribution - Bradford City Centre / Baildon

• Object to the proposed distribution which puts too much reliance on the City Centre, particularly in the absence of the 35% uplift. The distribution should be more closely aligned to the baseline distribution for the sub areas with additional uplift in the city centre and urban areas via the 35% uplift.
• The proposed distribution to Baildon should be increased to more closely align with the baseline population.

Object

Representation ID: 30058

Received: 23/03/2021

Respondent: Avant Homes

Agent: ID Planning

Housing Distribution - Bradford City Centre / Ilkley / Wilsden

• Object to the proposed distribution which puts too much reliance on the City Centre, particularly in the absence of the 35% uplift. The distribution should be more closely aligned to the baseline distribution for the sub areas with additional uplift in the city centre and urban areas via the 35% uplift.

-The proposed distribution to Wilsden, Ilkley and other settlements should be increased, at least to baseline requirement.

Object

Representation ID: 30059

Received: 23/03/2021

Respondent: Mr & Mrs . Pyrah and Saunders

Number of people: 4

Agent: ID Planning

Housing Distribution - Bradford City Centre

• Object to the proposed distribution which puts too much reliance on the City Centre, particularly in the absence of the 35% uplift. The distribution should be more closely aligned to the baseline distribution for the sub areas with additional uplift in the city centre and urban areas via the 35% uplift.

Object

Representation ID: 30060

Received: 23/03/2021

Respondent: Barratt Homes and David Wilson Homes

Agent: ID Planning

Housing Distribution - City Centre / Steeton

• Object to the proposed distribution which puts too much reliance on the City Centre, particularly in the absence of the 35% uplift. The distribution should be more closely aligned to the baseline distribution for the sub areas with additional uplift in the city centre and urban areas via the 35% uplift.
• The proposed distribution to Steeton should be increased to more closely align with the baseline population.

Object

Representation ID: 30061

Received: 23/03/2021

Respondent: Bannister Investments Limited

Agent: ID Planning

Housing Distribution - City Centre / Burley in Wharfedale

• Object to the proposed distribution which puts too much reliance on the City Centre, particularly in the absence of the 35% uplift. The distribution should be more closely aligned to the baseline distribution for the sub areas with additional distribution to support Local Growth Centres and uplift in the city centre and urban areas via the 35% uplift.
• The proposed distribution to Burley in Wharfedale should be increased to recognise the sustainability of the centre and the distribution it can make to housing needs.

Object

Representation ID: 30062

Received: 24/03/2021

Respondent: The Emerson Group

Agent: Johnson Mowat

Housing Distribution - Regional City / Bradford SE

As a starting point, it is suggested that the same proportional distribution as the adopted Core Strategy be maintained and this be applied to the Local Housing Need figure (excluding the 35% uplift), then the uplift figure be added and distributed across the Regional City areas, including the particular focus on the City Centre as planned.

A figure of 5,212 is advocated for Bradford SE.

Support

Representation ID: 30067

Received: 24/03/2021

Respondent: Gleeson Homes

Agent: Pegasus Group (Leeds)

Housing Distribution

Our client is generally supportive of the distribution of housing growth (however note there are concerns that overall the level of growth i.e. the housing requirement is not based upon robust evidence and has failed to apply the 35% uplift for largest cities and urban areas introduced by the Government)

Object

Representation ID: 30068

Received: 24/03/2021

Respondent: Persimmon Homes (West Yorkshire)

Agent: Lichfields

Housing Distribution - Silsden

The general inconsistencies of the approach to the District Wide Housing Requirement adopted by CBMDC are clearly apparent with reference to land at Bolton Road, considered in further detail below.

This has reduced from an apportionment to Silsden of 1,200 as set out within the adopted Core Strategy (2017), and also a reduction from 800 proposed in the Core Strategy Partial Review in 2019. It is important to note that the reduction from that in Core Strategy Partial Review to that in the draft Local Plan has occurred despite the overall district wide housing requirement not changing between the two documents. This reduction seems inexplicable when there is land (site SI/004) within the defined settlement boundary of Silsden that CBMDC has identified as being unconstrained and capable of accommodating in excess of a further 1141 dwellings, yet has not chosen to allocate.

Notwithstanding the need to increase the housing requirement overall, a reduction in the housing apportionment is not justified in respect of Silsden where there is non-Green Belt land which is suitable and available for development, and is clearly identified as such within the Council’s own evidence base.

Object

Representation ID: 30085

Received: 23/03/2021

Respondent: Mrs Savia Lorain Hughes

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: 30106

Received: 19/03/2021

Respondent: Snell Developments Ltd

Agent: Pegasus Group (Leeds)

Housing Distribution - Addingham

- generally supportive of the distribution of housing growth

-Policy SP8 identifies Addingham for 175 no. dwellings over the plan period. Table A, provided identifies the provision of 181 no. dwellings within Addingham through the preferred allocations. Accordingly, Policy SP8 should be amended to reflect this

- the policy should not use 181 no. dwellings as a ceiling, and more of an approximate figure to allow for increased provision of housing where sites are able to accommodate these additional units in a sustainable manner

Comment

Representation ID: 30108

Received: 10/03/2021

Respondent: SDS Land Ltd

Housing Distribution - Ilkley

1.0. Ilkley is defined as a Principal Town in the Local Plan with a key role within the District. However when considering the Objectively Assessed Need the number of new homes allocated is extremely low. The other Principal Towns are allocated homes, in the draft plan, proportional to the baseline distribution, whilst Ilkley is provided with only 39.7% of the requirement ie

2.0. The inclusion of site IL/012B as an Allocation would provide a further 150 dwellings giving a total of 450 which represents an improved percentage to 59.5%. This would increase supply of affordable homes in Ilkley for which there is a great shortage.

3.0 Site IL/012B provides a robust boundary for the green belt and a softer woodland edge to Ilkley and should be included as an Allocation in the Local Plan.

Object

Representation ID: 30109

Received: 24/03/2021

Respondent: Patchett Developments Ltd

Agent: Johnson Mowat

Housing Distribution – Bradford South West

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

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 SW.

It is now the intention of the Plan to reduce the overall requirement for Bradford SW to 3,175 dwellings. This is not supported by our client; it is our clients position that the overall requirement for the both Bradford South West and the District as a whole should be significant higher.

Additional material and suggested changes provided in submission document.

Object

Representation ID: 30110

Received: 24/03/2021

Respondent: Patchett Developments Ltd

Agent: Johnson Mowat

Housing Distribution - Bradford NW

The Local Plan should identify additional sites in and on the edge of the urban area to accommodate the 35% housing requirement uplift.

Given the Government’s commitment and objective of significantly boosting the supply of housing the direction of travel by the Council in the Bradford North West sub area does not follow this required drive. There has been a continual reduction of housing directed to Bradford North West over time despite its status as part of the Regional City continuing.

The proposed apportion of dwellings to Bradford North West falls significantly short of the baseline population proportionate distribution of 4,043.

It may be suggested that the same proportional distribution as the adopted Core Strategy be maintained and this be applied to the Local Housing Need figure (excluding the 35% uplift), then the uplift figure be added and distributed across the Regional City areas - this would give a housing requirement for Bradford NW of 3,909

Object

Representation ID: 30135

Received: 22/03/2021

Respondent: Robbie Feather

Agent: ID Planning

Components of Supply

Policy SP8 details three components of supply, residential commitments, new allocations and broad locations. In respect to residential commitments, we welcome the removal of outline applications from this source of supply in accordance with NPPF. Paragraph 3.8.19 of the Plan states that supply from commitments provides a capacity of 6,415 units.

The supporting text and the technical note explain that a 10% discount is applied to the sources of supply. Neither the policy itself or supporting text provide a summary of the supply figures. Indeed, the figure for actual housing allocations are not provided until later in the plan under the individual settlement sections. For the reader the policy does not provide sufficient clear information on existing supply and the amount of dwellings required through new allocations. The policy and supporting text should be amended to be more transparent.

Required change

The policy should be amended to be more transparent, providing a summary of the requirement, supply and allocations required.

Object

Representation ID: 30136

Received: 22/03/2021

Respondent: Robbie Feather

Agent: ID Planning

Windfall

The sources of supply also include a windfall allowance of 300 dwellings per annum for years 3-18. Paragraph 3.8.27 states that based on historic windfall delivery rates and future trends the Council considers that it is reasonable to make a modest assumed contribution of 300 units. Whilst the Council consider this contribution to be modest, 300 dwellings per annum equates to 16% of the annual requirement and therefore is a significant proportion of the expected supply. No evidence is provided as to what the historic windfall rates have been or what evidence there is to support a continuation of these rates. On this basis, we object to the inclusion of 300 dwellings per annum (4,800 dwellings over the plan period) as a source of supply.

Required change

Evidence should be provided to determine the appropriateness of the windfall allowance. The quantum of windfall sites being relied on comprises a significant proportion of the annual requirement (16%) and therefore it should be robustly evidenced. The information provided at paragraph 3.8.27 does not constitute robust evidence to justify the quantum of windfalls the Council is seeking to rely on.

Object

Representation ID: 30138

Received: 23/03/2021

Respondent: Jeffrey Rothery

Agent: ID Planning

Housing Distribution

It is not considered that the provision of 625 dwellings, less than 2% of the district requirement makes a ‘significant contribution’ to the Districts housing needs. The proposed distribution to Burley in Wharfedale is too low and should be increased to support its role and function as a growth centre.

Whilst we support the Council’s strategy that the majority of housing should be distributed to the Regional City, the distribution of 73% of the LHN requirement to this area is too high and negatively impacts on the distribution to the wider district and other settlements. The proposed distribution to the Regional City and in particular the Bradford City Centre and Shipley and Canal Road Corridor areas is unrealistic.

The distribution results in the allocation of urban extensions on the east and western edges of the City which are physically remote from rail services at the expense of sites in smaller centres with railways stations.

Required Change
Whilst the Regional City should be the main focus for housing delivery in the absence of the 35% uplift being applied the quantum of housing should be reduced to a more realistic level (60%) and additional houses should be distributed to Principal Towns, Local Growth Centres such as Burley in Wharfedale where there are not the deliverability constraints and where the delivery of additional houses in these settlements is realistic. This approach will ensure the housing requirement and the plan is deliverable.

Overall, however, we object to the 35% uplift being excluded as this would provide the preferred growth strategy for the urban areas whilst also ensure and maintain a balanced distribution of housing growth to meet identified needs in the wider district and sustainable settlements.

Required Change
The proposed distribution to Burley in Wharfedale should be increased. Additional Green Belt releases should be made to allocate smaller sites in the settlement to provide choice and mix of sites to support delivery. The site at Hag Farm Road is well contained and would form a natural extension to the settlement to provide a mix of use in accordance with the Neighbourhood Plan. The allocation of an additional site will ensure the delivery of a mix of sites to provide market and affordable housing and support services and facilities in the settlement.

Comment

Representation ID: 30146

Received: 24/03/2021

Respondent: Andrew Coates

Agent: Rural Solutions

Housing Distribution - Addingham

Our previous representations to the emerging Local Plan process initially focussed on the fact that in our opinion Addingham is a sustainable settlement and thus we disagreed that it should only have 75 houses in the plan period. We welcome that the new Local Plan seeks to promote 175 dwellings through the plan period.

Object

Representation ID: 30168

Received: 23/03/2021

Respondent: Catherine Terry

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: 30206

Received: 24/03/2021

Respondent: CPRE West Yorkshire

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: 30207

Received: 24/03/2021

Respondent: CPRE West Yorkshire

Spatial Distribution
We are not disputing that settlements at all levels of the hierarchy should be enabled to have a quantity and type of development that meets their needs. Furthermore, if some of those settlements are better served than others by public transport, and contain some sites that are more suited than others to implementing 15-minute neighbourhoods, then this does create a justification for adjusting the distribution between settlements to facilitate those sites being developed.

In our view the important first step towards redressing this problem is to measure housing land requirements by land area, rather than by the indicative capacities that are derived from market preference. Calculating land requirements by area in this way is an important, reasonable alternative to the approach currently taken by policy SP8.

Object

Representation ID: 30208

Received: 24/03/2021

Respondent: CPRE West Yorkshire

Neighbourhood Plans

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: 30209

Received: 24/03/2021

Respondent: CPRE West Yorkshire

Previously Developed Land

Based on the quoted percentages within SP8H and the settlement targets, it appears that 14,607 new dwellings will be on greenfield land across the district, which is 48% of the total requirement but 53% of allocations, by number of dwellings. Due to the tightly-drawn Green Belt a high proportion of the greenfield allocations will come from the Green Belt.
Any policy compliant green belt site should be built to at last 50dph - we would expect 14,607 dwellings to require a further 365 ha of greenfield land.

We have so far looked in detail at 25 greenfield sites in the draft Plan, of which the majority are to come from Green Belt. These 25 sites have a total area of 160 ha, and a total indicative capacity of 3,640 dwellings – a gross density of 23dpha – which suggests a net density of around 29dhpa. If this pattern were to prevail across all greenfield sites, in the plan, then 14,607 homes would require 635 ha.

Consequently, 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 and will directly fail to implement key sustainability policies in the Plan. And we cannot see how the proposed site allocations, taken as a whole, will be suitable for the implementation of key policies in the Plan, especially SP7 on sustainable travel and HO2 on density.

Object

Representation ID: 30257

Received: 21/03/2021

Respondent: Mrs Lisa Holden

Housing Distribution - Addingham

Policy SP3 sets out a Hierarchy of Settlements in the plan, and identifies that the Regional City of Bradford (with Shipley and Lower Baildon) will be the prime focus for housing. The Local Service Centres such as Addingham, smaller scale development will allow for ‘the protection and enhancement of those centres. I cannot understand why based on the figures Addingham had been allocated over a 10% increase as opposed to other more suitable areas.

Object

Representation ID: 30259

Received: 21/03/2021

Respondent: Mr Andrew Holden

Housing Distribution - Addingham

Policy SP3 sets out a Hierarchy of Settlements in the plan, and identifies that the Regional City of Bradford (with Shipley and Lower Baildon) will be the prime focus for housing. The Local Service Centres such as Addingham, smaller scale development will allow for ‘the protection and enhancement of those centres. I simply cannot understand why based on the figures Addingham had been allocated over a 10% increase as opposed to other more suitable areas in other areas.
Furthermore, the designated land on the western side of the village is Green Belt and is covered by a protection zone. Building on this land is clearly inappropriate because there are 2 protection zones covering Addingham, lack of supporting infrastructure, risk of increase flooding, significant increase of traffic in Moor Lane/Moor Park/Turner Lane and Main Street in the village leading to increased risk of accidents.

Object

Representation ID: 30288

Received: 23/03/2021

Respondent: Barry Hopkinson

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.

Object

Representation ID: 30295

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Conservative)

Planning Policy states that Green Belt should only be released for housing in exceptional circumstances. Policy SP5 –Green Belt and SP8 –Housing Growth are narrative statements which are subjective and are no justification for releasing this Green Belt siteS for housing.