Consultation Question 9

Object

Representation ID: 4218

Received: 23/03/2021

Respondent: Mrs Sarah Thomas

Housing Distribution - Ilkley

I think the arguments for the level of additional housing is not well made. I understand there are targets that the Council need to meet but the figure of 300 houses seems random and not based on analysis of the needs of the town.

Object

Representation ID: 4226

Received: 23/03/2021

Respondent: Mrs Catherine Binns

Housing Distribution - Addingham

The numbers of proposed housing allocated to the village of Addingham is too high in proportion to the current housing numbers. More of the proposed housing should be in larger towns that have better infrastructure and more employment opportunities.

Addingham has limited employment opportunities so new residents would have to seek employment further afield which would increase the use of cars. Addingham has limited public transport with no railway so most commuters would use cars for at least some of their journey. The volume of traffic is already too high on Moor Lane and through Addingham with congestion on Main Street and Bolton Road

The local school is already near capacity with some local children recently having to go to an appeal to try to secure a place. If further housing is built this situation would occur again.

Object

Representation ID: 4532

Received: 23/03/2021

Respondent: Mrs Jillian Hargrave

Housing Distribution - Addingham

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

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

Object

Representation ID: 4834

Received: 24/03/2021

Respondent: Mr Ramy Abdalla

Agent: CODA Planning Limited

Housing Need and Requirement

The approach of the Council in maintaining a target of 1,704 dwellings per annum is not in accordance with the NPPF as it is not adopting the current standard methodology [which includes the 35% urban area uplift] – the plans as currently drafted is therefore not being positively prepared.

The approach of the local planning authority should be to fully re-assess the strategy required to deliver the 2,300 new homes per annum over the plan period to meet the Standard Methodology target. This will require the full re-analysis of site previously discounted as being unsuitable as inevitably to meet this need further substantial Green Belt releases will be required.

Object

Representation ID: 4878

Received: 24/03/2021

Respondent: Banks Property

Housing Need and Requirement

Banks Property objects to the Council’s approach to housing growth. In determining its housing requirement, the Council has not applied a 35% uplift in accordance with the Government’s latest Standard Method (Dec 2020). Whilst transitional arrangements apply for Local Plans in preparation, 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: 5190

Received: 24/03/2021

Respondent: Clive Richardson

Housing Distribution - Growth Centres / Thornton

I am totally against your policy which concentrates development on a handful of "growth centres" and villages. It is inevitable with your policy that the character of villages will change, while the green belt is set in aspic, never to change.

Object

Representation ID: 5306

Received: 24/03/2021

Respondent: Mr Peter Jenkins

Unviable and unoccupied housing all have to be deducted from the targets which are therefore inflated, which will affect all shown quotas.
These and brownfield sites should be developed first – as per the policy.
There are too many unsubstantiated statements to be able to support this section, for example on the proportion of brownfield and affordable homes provided.
The quoted figures seem higher than in evidence.
In addition the need for affordable houses is greater than the national average.
The definition of affordable housing in terms of rent or mortgage needs to en revised downwards as other cities (eg Manchester) have done.

Object

Representation ID: 5402

Received: 24/03/2021

Respondent: Mr Bernard Poulter

Housing Need and Requirement / Housing Distribution

Housing Targets should be relevant to the existing and predicted need.....not some "Pin the tail on the Donkey" approach , as BDMC appear to be doing! The ONS have issued migration figures that contradict the proposals of BDMC, and , even then , BDMC are choosing to use the 2014metric to assess the needs, rather that waiting until after the Census taken n the 21/3/21, ...bearing in mind that this piece of work has a deadline of 2023, not 2021!!!

Object

Representation ID: 5435

Received: 24/03/2021

Respondent: Arrowsmith Associates

Housing Need and Requirement

Housing figures fail to meet the 35% uplift which the Government has applied to 20 of the biggest urban centres, including Bradford. As set out in the plan, that uplift would amount to an additional 10,728 homes and an annual average of 2,299/annum.

In failing to incorporate that uplift, the plan risks being found unsound when assessed against at least three of the tests of soundness:

a) Positively prepared – the plan fails to provide a strategy which seeks to meet the area’s objectively assessed needs in a manner consistent with Government policy.
b) Justified – the plan does not provide an appropriate strategy, the reasonable alternative of providing site allocations covering the uplift not having been adequately addressed before being dismissed.
d) Consistent with national policy – the plan as proposed is not consistent with national policy requiring a 35% uplift in Bradford District.

Support

Representation ID: 5493

Received: 24/03/2021

Respondent: CPRE West Yorkshire

Housing Requirement

CPRE believes in meeting genuine housing need by building the right types of homes in the right places.

In that context 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.

Support

Representation ID: 5511

Received: 24/03/2021

Respondent: Mrs Jane Callaghan

Housing Distribution - Wilsden

Broadly supported. If the planning application for Prospect Mill were to be granted, this PDL should count as an allocation against Wilsden's housing need and green belt allocation revoked without future prejudice.

Object

Representation ID: 5607

Received: 24/03/2021

Respondent: Contour Planning Services Limited

Housing Need and Requirement

For the plan to be sound, the Council should follow the Government’s approach to assessing housing need. Without this the Local Plan fails to identify sufficient new homes during the plan period.

Previously Developed Land / Efficient Use of Land / Density

Amafhh are concerned the Council has failed to make the most efficient use of the identified sustainable brownfield sites and that the density and yields of identified sites should be maximised, to ensure the Council’s annual targets and objectives for securing development on PDL can be achieved.

To assist with, this Amafhh has identified two new housing sites (through the call for sites) and recommended the number of units on site SW17/H is significantly increased.

Amafhh do, however, support Part C of Policy SP08 which provides support for additional opportunities that arise, including taking a positive and flexible approach to additional growth opportunities which may arise, particularly those which deliver transformational change in and around the Regional City.

Object

Representation ID: 5685

Received: 24/03/2021

Respondent: Chatsworth Settlement Trustees

Agent: Richard Wood Associates

Housing Distribution - Keighley

In summary, there is insufficient housing distributed to the Principal Towns and to Keighley within this group of settlements which fulfil 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 Principal Towns, including Keighley, would serve to deliver the plan’s spatial priorities, better reflect and deliver the settlement hierarchy and thereby achieve sustainable development

Object

Representation ID: 5921

Received: 24/03/2021

Respondent: Baildon & Shipley Friends of the Earth

Previously Developed Land / Efficient Use of Land

1. The underlying principles of housing growth should be Social Equity, Sustainable Development, Sustainable Location, Urban Capacity, Participative Processes, and Zero Carbon Design
2. See also under SP9 and EN10 concerning zero carbon design.
3. Vauban, Germany, is an example of what can be achieved in terms of neighbourhood passivhaus standards.
4. 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 particular, most of the Green Belt housing allocations are proposed to be developed well below the densities required by the Plan’s policies relating to density.
5. With the climate emergency, there can be no place for any more development involving large detached houses with driveways and garages.
6. ‘Design and Beauty’ and “working with the landscape” are good concepts.

Support

Representation ID: 5984

Received: 24/03/2021

Respondent: SHMS

Policies need to be better aligned to the jobs growth potential in the higher employment areas

Object

Representation ID: 6067

Received: 04/03/2021

Respondent: Simon Cooke

Housing Need and Requirement -
Case should be made for Bradford to take more, not less housing particularly in the popular towns and villages (Bingley Rural).

Object

Representation ID: 6325

Received: 16/03/2021

Respondent: Mrs Fiona Curtin

Housing Distribution - Addingham

There is too higher allocation for the village as a whole compared to other settlements in the ward. In terms of sites there are too many sites proposed on greenbelt and additionally a disproportionate number of sites at the western end of the village that is in excess of 1.4km from the limited local amenities including schools and health. A distance that exceeds the councils own target. This will undoubtedly lead to traffic, congestion and pollution issues as people are forced to drive for convenience and access to facilities. The impact on greenbelt at the western end of the village is major and will affect the historical character of the village.

Object

Representation ID: 6555

Received: 18/03/2021

Respondent: Mrs Eileen Hogg

Housing Distribution - Shipley

How were these figures for housing need in Shipley arrived at? Do the figures come from central government, and not local council? If so, I'm extremely sceptical. And do they take into account increased deaths during the pandemic and possible change in population due to Brexit? Possible fall in birthrate due to lockdown? We're about to have a census. Why not wait? Wouldn't the census give a much better idea of future housing need?

Object

Representation ID: 6764

Received: 18/03/2021

Respondent: Mrs Jean Cawkwell

Housing Need and Requirement

OBJECT to policy SP8.

Bradford needs more housing land than is proposed.
The Council are not proposing as much housing as the 2017 adopted Core Strategy proposed or applying the Government’s 35% uplift.

The suggestion that only 1,704 homes per annum will be delivered is not justified or consistent with national planning policy.

The housing target figure should be at least 2,300 – 2,476 homes per annum depending upon how it is calculated

Comment

Representation ID: 7531

Received: 08/03/2021

Respondent: Mr W Willan

Agent: Townsend Planning Consultants

Housing Need and Requirement / Housing Distribution (Bradford SE)

The Council should be supporting a greater housing number in the district as well as pursuing a greater housing number in south east Bradford

Object

Representation ID: 7654

Received: 20/03/2021

Respondent: Professor Robert Smith

Housing Distribution - Addingham

The 2019 Addingham Referendum in which I voted was in favour of 75 new houses during the 2020-2038 period. This seemed an acceptable level. To increase this to 181 is preposterous. The Main Street through the village is narrow and congested. Additional traffic demands therefore would have serious safety concerns for all proposed sites, but especially those which feed directly into Main Street. Public transport links are insufficient for the proposed increases (with no rail link, unlike Ilkley and other Bradford Council areas covered by the Plan, and reduced bus services now the No 62 does not go to LBA) - excessive car usage would put the village back to where it was before the construction of the A65 bypass. The impact on village facilities, together with the denigration of greenbelt areas and environmental considerations are totally unacceptable and would reduce the quality of life in the village.

Object

Representation ID: 7702

Received: 21/03/2021

Respondent: Addingham Civic Society

Housing Distribution - Addingham

I believe that too many houses have been allocated to this plan for Addingham.

There will be an adverse impact in the work so far undertaken to protect wildlife corridors through the village.
I also think that local services and infrastructure will be unduly impacted.

Object

Representation ID: 7857

Received: 22/03/2021

Respondent: Mr Alan Wilcock

Housing Need and Requirement

Fundamentally, there appears to be no overall justification for the current target housing numbers (1,703 dwellings per annum) over the 2020/2038 period given Bradford’s own analyses and where the country is today.

Object

Representation ID: 8136

Received: 24/03/2021

Respondent: Mrs Vicky Gordon

Housing Distribution - Burley in Wharfedale

The proposal allocates 625 new homes for Burley in Wharfedale, including the 500 at Sun Lane (already approved which I strongly disagree with) and 110 at Scalebor House. Burley has already delivered 190 new homes so, by including Scalebor House, this takes us to a target of 750 homes. Why is Burley having an extra allocation of new house when many other areas have a fall in housing allocation?

Support

Representation ID: 8421

Received: 23/03/2021

Respondent: Mrs Susan Burn

Housing Need and Requirement

I support the decision of BMDC to not adopt the new Government standard method for housing looking for an increase in dwellings of 35% in the largest cities and urban centres in England (including Bradford) above what is considered our base housing requirement (1704 dwellings per year).

Object

Representation ID: 8555

Received: 10/03/2021

Respondent: Mr Michael Bolton

Housing Need and Distribution

It is noted that the target allocation number of 175 houses remains virtually the same as for the period when the Addingham Neighbourhood Plan was being drawn up at 200 houses, despite the 2019 Core Strategy review allocating a target number of 75 houses. Proposals for achieving this target of 75 houses were developed in the Addingham Neighbourhood Plan.

Support

Representation ID: 8761

Received: 15/03/2021

Respondent: Julie Mountain

Housing Distribution - Ilkley

I am in support of the planning for housing development in Ilkley.

I would urge plans to include more affordable housing for young families and no more retirement flats as the age balance in Ilkley for retired/pensioners is almost double the national average at 20%.

It is extremely difficult for young people who have grown up here to afford to live here as adults, mostly impossible.
It seems unfair to me that they are priced out of the market in their home towns.

Object

Representation ID: 8766

Received: 22/03/2021

Respondent: Mrs Sabine Robinson

Housing Distribution - Addingham
Objection to the housing target for Addingham

Bradford's policy SP3 identifies Addingham as a Local Service Center within which a smaller scale development will allow for protection of these centers. The scale of the planned development is disproportionate to the size of the village (an increase of over 10% in total for the entire village). Bradford's own increase is only just above 9% when the plan states that the focus of new development should be in Bradford itself. The suggested housing increase will have a significant and detrimental impact on the character of the village set within the historic farming setting. Before the bypass was built, Addingham Main Street was a dangerous and hazardous road. It is likely that cars from the new houses will once again dangerously increase congestion in the village center as it cannot be assumed that the bypass will be used.

Comment

Representation ID: 9801

Received: 12/03/2021

Respondent: Bradford District Ward Councillor (Labour)

SP 8 I feel that most of the development is aspirational, rather than necessarily deliverable. I would like to comment on “affordability” Bradford and Keighley are low price areas and in national terms affordability seems not much of a problem – since most are pretty cheap. I would like to see some concentration on quality and sustainability issues – insulation, heat pumps, solar panels – rather than an obsession with price.

Object

Representation ID: 10326

Received: 24/03/2021

Respondent: Barratt Homes and David Wilson Homes Yorkshire West

Agent: Sheppard Planning

Housing Need and Requirement.

Barratt consider that the Plan does not currently allocate enough land for housing.

We consider that the Plan should allow for the 35% Cities and Urban Areas uplift which forms part of the standard method. The draft Plan offers very little explanation, and no evidence, on why the 35% uplift is not deliverable or justified.

Options are presented to illustrate how the uplift and additional 10,000 dwellings can be met and in which areas and settlements.