Consultation Question 9

Object

Representation ID: 10327

Received: 24/03/2021

Respondent: Barratt Homes and David Wilson Homes Yorkshire West

Agent: Sheppard Planning

Housing Distribution:

Alternative distribution scenarios are presented which would incorporate the 35% uplift - the option favoured is one which keeps the City Centre figure at 7,000 but makes significant increases in Bradford SE and smaller increases elsewhere reflecting the availability of additional sites so far rejected, environmental constraints, and green belt areas which are considered to be strategically less important.

Object

Representation ID: 10952

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

Housing Need and Requirement

The recently adopted Core Strategy planned for 42,000 homes over a shorter plan period (i.e. 2,476 per annum). The latest local Housing need requirement for Bradford is 2,300 per annum based on the 35% uplift that must be applied.

The suggestion that only 1,704 dwellings per annum will be delivered is not justified or consistent with national planning policy therefore the Policy is unsound.

Paragraph 3.8.57 indicates that the Council have dismissed the 2,300 dpa figure on the basis that it would result in more Green Belt release. However the 2,300 figure results in a similar number of homes prescribed in the recently adopted Core Strategy and that was deemed sound despite the fact that it noted a lot of Green Belt release would be required.

To now suggest that that approach is not sustainable is not accepted as being a reasonable approach. Why would it be ok in 2017 and not in 2021 when the Council’s position on housing delivery has clearly not improved in the interim.

The plan period should be over 20 years resulting in an overall requirement of 46,000 homes.

Object

Representation ID: 10953

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

Housing Distribution - Queensbury

Queensbury should retain its Growth Area status as endorsed through the adopted Core Strategy and be subject to an uplift over and above the basic population baseline position and retain its target of 1,000 homes.

Within the Draft Local Plan Queensbury is now ranked 4th place out of 6 Local Growth Centres with just 450 homes. This is a significant change (55% reduction) that is not justified with any robust evidence. It would result in Queensbury’s population growing by circa 10% whereas most of the other Local Growth Centres (bar Steeton) will see a 20%+ increase. This is despite Queensbury being the largest of all the Local growth Centres by some margin and arguably being the most sustainable of all the Local Growth Centres due to the range of services it contains.

Investment decisions will have been made on the back of the Core Strategy spatial distribution of homes and the Council have not formally advertised through a revised LDS that they seek to amend the adopted spatial strategy.

Object

Representation ID: 11012

Received: 17/03/2021

Respondent: The Strategic Land Group

Agent: Walsingham Planning

Housing Need and Requirement

The Local Plan should include a minimum annual local housing requirement of 2,300 dwellings per annum, instead of 1,704 per year, to take into account the requirements of the NPPF and PPG to apply a 35% cities and urban centres uplift in the Top 20 cities/urban centres. The uplift cannot be excluded, discounted or removed and must form one of the defined stages of the standard method. It should be met across the District’s various settlements/areas and by appropriate levels of Green Belt release to enable the minimum need figure to be met/exceeded.
The Core Strategy (2017) includes a higher requirement of 2,476 dwellings, showing that an increase requirement can be accommodated.

There is a need for additional sites, including the release of Green Belt land as well as brownfield/underutilised land. Land at Haworth Road, Sandy Lane (SHLAA Ref: NW/020) is proposed to assist in meeting this requirement.

Comment

Representation ID: 11402

Received: 17/03/2021

Respondent: Mr Robert Felstead

Query the proportion of new homes provide on brownfield land. Information not in Local Plan paperwork.

SHMA suggests at least 25% of housing should be affordable homes. However, the issue of under-delivery persists, raising questions. Over the last 5 years stands at 17% of the housing total.

Key issue is not affordability but one of income and social housing provision. Affordable housing is needed. Affordable social housing is needed geared towards those whose income is less that £18,200 and are not catered for in the Plan.

Government’s definition of affordable housing noted, however Council should consider using an alternative definition, e.g. that used by Manchester City Council. It is reviewed annually to determine how much of the city’s housing is affordable.

Inevitable that some housing must be met from Green Belt. Burley’s housing allocation in this section shown as 326 units, not the 625 shown in the Local Plan.

Object

Representation ID: 12314

Received: 24/03/2021

Respondent: Caddick Land

Agent: Peacock and Smith

Housing Need and Requirement

In summary, it is considered that the proposed approach of Policy SP8 to not include the 35% uplift applied by Government on the top 20 cities and urban centres cannot be sound when there are suitable sites such as Caddick’s proposed allocation at Odsal that would allow the Council to deliver a much greater quantum of housing than 1,704 dwellings/annum.

There is no reason why the Council should not comply with the 35% uplifted figure of 2,300 new homes per year nor any evidence of subsequent adverse impacts on the District. Indeed, prior to the Government’s amendments to how the housing requirement is to be calculated the Council were looking to identify land for 2476 dwellings per annum. At no point during that exercise did the Council raise any concerns about them not being able to meet that requirement.

Support

Representation ID: 13203

Received: 20/03/2021

Respondent: Silsden Town Council

Housing Distribution - Silsden

The reduction in the housing numbers associated with Silsden are welcomed. We have we have a number of Brownfield sites which are focused on and are in suitable places for accessing the A.V.T.R.

Object

Representation ID: 13321

Received: 24/03/2021

Respondent: Mitre Residential LPP

Agent: DPP Planning

Housing Need and Requirement

It is considered that Policy SP8 is not fit for purpose and is unsound. We object to the proposed policy as it does not include the 35% uplift in housing need set nationally. There is no reason why the housing requirement provided by the standard methodology cannot be met.

Object

Representation ID: 13812

Received: 20/03/2021

Respondent: John Finnigan

Housing Need and Requirement

My representation is that the Council should not adopt the 35% uplift and should adopt the second reasonable alternative at paragraph 3.8.57 (ie for a reduction in the 1704 dpa) to release fewer Green Belt sites, it not being the case that this would increase the gap between housing supply and need, as need has been overstated. For this reason (and others) exceptional circumstances for Green Belt release on the scale proposed do not exist.

Comment

Representation ID: 13814

Received: 20/03/2021

Respondent: John Finnigan

In respect of site allocations I propose that these be reviewed on a five yearly basis to minimise the risk of surplus Green Belt releases being included.
If that were the case the Council could not show exceptional circumstances at present for Green Belt site allocations. After the first five years it may be that the Council could show exceptional circumstances by reference to changes in housing growth predictions, but precious Green Belt land would not be lost to the District any sooner than absolutely necessary.

Object

Representation ID: 15212

Received: 22/03/2021

Respondent: Freda Butterfield

Tried to understand the outline planning BMDC have intentions of carrying out in the lovely green space city of ours.

Housing - there are enough empty homes in city to accommodate what is needed, taking account of those left derelict and empty apartment buildings closed for being unsafe. Council has powers to intervene. Several planning applications for apartments have been passed in the last six months.

Green Belt should not be used in any circumstances – there are enough brownfield sites available for housing.

Has anyone thought about schools - how they are going to accommodate the children.

Has thought been given to water supply? Bradford still encounters droughts - will not ease with growing population.

With all the properties, there will be extra pollution in age of climate change. No use just looking at the city centre - the rest of city with major roads and excessive housing needs to be considered.

Support

Representation ID: 15405

Received: 19/03/2021

Respondent: Highways England (Yorkshire & North East Team)

Housing Distribution

It is considered by CH2M that Highways England should support the aspirations of Policy SP8 – primarily Schedule 1 – which aims to locate the majority of new housing across the Plan period within Bradford, the Principal Towns and Local Growth Centres. It is considered by CH2M that these settlements tend to be more sustainable in nature with more transport hubs and increased network coverage.

Notwithstanding, these aspirations should be supported by a robust transport evidence base.

Object

Representation ID: 15756

Received: 24/03/2021

Respondent: Mr John Thompson

Housing Distribution - Addingham

Addingham is designated a SMALL SERVICE CENTRE and as such does not have the infrastructure to support large numbers of additional housing especially at the western side of the village. How has the housing allocation for Addingham has been derived.

There are plenty of brownfield sites in Bradford close to employment and transport which are therefore more suitable for development.

Death of the high street - it would make more sense to re-purpose empty retail space within cities.

Comment

Representation ID: 15775

Received: 24/03/2021

Respondent: West Yorkshire Combined Authority (WYCA)

Housing Need and Requirement

It is noted that the Plan’s housing requirement does not meet the recently updated Local Housing Need figure for Bradford which incorporates a 35% Cities and Urban Areas uplift, resulting in a figure of approximately 2,300 dwellings per annum. The supporting text for Policy SP8, under Paragraph 3.8.57, provides justification for this approach.

The collective City Region ambition is to deliver between 10,000 – 13,000 net additional homes per annum, as set out in Matter 8 the LCR Statement of Common Ground (2020). Based on the number of homes planned across the City Region authorities, through draft or adopted plans, the provision proposed in the Bradford Draft Plan (without the 35% Cities and Urban Areas uplift) will still allow the collective City Region housing growth range to be achieved. On that basis the Local Plan will contribute to the SEP housing delivery ambitions. However, we are seeking advice from Government regarding how the 35% Cities and Urban Areas uplift should be applied locally and any potential sub-regional implications.

Comment

Representation ID: 15831

Received: 24/03/2021

Respondent: West Yorkshire Combined Authority (WYCA)

Housing Distribution

We are encouraged that the Local Plan provides several policy hooks that dovetail well with the WY Transport Strategy and draft West Yorkshire Connectivity Infrastructure Plan.

The Local Plan settlement hierarchy approach, which directs growth in the main centres and along strategic transport corridors, is consistent with other Partner Councils in West Yorkshire. The quantum of development proposed in the smaller settlements is reduced with the focus on the larger settlements in the districts.

This approach is supported and aligns well with programmed and future transport investments particularly schemes identified in the West Yorkshire Transport Fund and Transforming Cities Fund. It also aligns well with the existing public transport network provision that tend to be strongest in the main centres.

Object

Representation ID: 16238

Received: 24/03/2021

Respondent: Mr Michael Nichols

Housing Distribution - Addingham

The number proposed of 181 homes is far too high and cannot be accommodated without severely compromising the council’s own policies clearly set out elsewhere in the Local Plan.

- The proposal is contrary to the Partial Review of the Core Strategy in 2019 which reduced the housing target number for Addingham from 200 new houses to 75 - no justification for a return to a higher target;
- There is a severe lack of infrastructure, services and facilities in the settlement - local road network and congestion; schools such as Ilkley Grammar at capacity; the village has few leisure facilities and little parking; the centre of the village is prone to groundwater flooding;
- potential impact on the character and setting of the village and on biodiversity, green and blue infrastructure;
- many of the sites are located a distance from village services and perform poorly against Policy SP7

Object

Representation ID: 16264

Received: 24/03/2021

Respondent: Keighley Town Council

Housing Distribution - Oakworth

The local plan suggests 75 new dwellings are required in Oakworth over the life of the plan.

Over the last few decades, numerous estates have been built throughout the village and the local plan does not provide the clear evidence base that more are required.

Object

Representation ID: 16268

Received: 22/03/2021

Respondent: Robbie Feather

Agent: ID Planning

Housing Need and Requirement

A number of required changes are sought to policy SP8 as detailed in submission, summarised as:
• Policy too long and should be split into a number of separate shorter policies;
• 35% uplift should be applied to the requirement;
• Housing requirement calculation should be clear and transparent and provided in the supporting text;
• The statement in Part A referring to ‘a significant boost in housing delivery’ should be deleted.
- Part C of the policy to be amended to provide clear guidance policy on what additional growth opportunities are supported.
• Object to the windfall allowance, further evidence to justify the amount is needed;

Support

Representation ID: 16275

Received: 24/03/2021

Respondent: Keighley Town Council

Components of Supply

The council also strongly supports the provision of 250 dwellings within the town centre. The council does have some concern that this target could be achieved through the Town Deal Board which recently submitted its bid to central government.

Object

Representation ID: 16341

Received: 24/03/2021

Respondent: Newett Homes

Agent: Quod North

Housing Requirement:

The Government have proposed a 35% increase above the current Standard Method- BCC will therefore be required to identify a minimum deliverable supply of land for 2,300 dpa.

BCC have not sufficiently evidenced how this uplifted housing requirement can be accommodated whilst addressing historic shortfall. This is necessary to ensure the DBLP meets the tests of soundness and also supportive of broader policy objectives (such as supporting economic growth and meeting social needs).

Without providing a detailed analysis of whether this is feasible, BCC propose a significant reduction of 772 dpa against the adopted CS requirement (2,476 dpa). This is in the context of a housing shortfall of 8,588 homes since 2013 and an under supply of homes (2.03 years).

In this context, it is inappropriate for BCC to propose this reduction before fully assessing delivery / infrastructure issues and impacts on historic deprivation, housing supply and affordability issues.

Newett Homes recommend that BCC take responsibility for addressing the significant previous shortfall.

Object

Representation ID: 16342

Received: 24/03/2021

Respondent: Newett Homes

Agent: Quod North

Housing Distribution - Wilsden

As set out in these Representations, BCC’s approach to spatial distribution is inappropriate and will prevent the delivery of sustainable development and its associated benefits over the plan period (2020-2038).

Building on its existing services and facilities, Wilsden (and other Local Service Centres) has capacity to be identified for greater, proportionate growth and grow sustainably.

In doing so, development, community and necessary infrastructure can be planned for and feasibly
delivered. This will allow development to provide and enhance community facilities, and for BCC to develop an efficient and viable sustainable transport network.

A greater level of growth will also provide greater opportunities for improved community and sustainable transport infrastructure within the Local Service Centres.

Object

Representation ID: 16555

Received: 22/03/2021

Respondent: Mr David Wilmshurst

Previously Developed Land

From paragraph 3.6.15 it would therefore appear that the Plan does not allow for the expected reduced demand for retail and office space resulting from the pandemic. Following from that, the Plan does not appear to be fulfilling the requirements on the Council laid out in paragraphs 3.8.42 and 43 by the National Planning Policy Framework (NPPF) to make as much use as possible of previously developed and under-utilised land and buildings, which could be used for housing. The shortfall of 5,000 units stated in para 3.5.5 would therefore appear to be excessive and the amount of Green Belt land to be built on should therefore be reduced accordingly. The Plan should therefore be redrafted taking the effects of the pandemic into account.

Object

Representation ID: 16721

Received: 24/03/2021

Respondent: Shipley Town Council

New housing development should be based on the following principles and we would like to see all of these reflected throughout the draft plan.
- Social Equity
- Sustainable Development
- Urban Capacity
- Zero carbon Design
- Participative Process

It appears that the proposed greenfield land take in the draft Plan is approaching double what it would need to be if all greenfield development were built to the policy-compliant 50dhpa net.

This being the case, then the exceptional circumstances for Green Belt releases have not been demonstrated.

Object

Representation ID: 16748

Received: 24/03/2021

Respondent: Addingham Civic Society

Housing Distribution - Addingham

There is no specific evidence offered in support of the latest increase in the housing target from 75 to an unsustainable 175 - this will have severe adverse long term impacts on the village.

The District-wide housing requirement has not changed since the Partial Review, and it forms the basis for the current Draft Local Plan Consultation. However, Ilkley’s figure has now been reduced further to 300 while Addingham’s has been sharply increased to 175.

The increased housing requirement contradicts many of the assumptions underlying the Plan’s policies for Local Service Centres – such as a reduced scale of growth, preventing unnecessary dispersal of development top smaller settlements.

The Housing Requirement for the village needs to be reduced back to 75 dwellings.

The impacts on future working patterns post covid-19, reducing the need for city centre office space and retail will result in 100’s of new houses – this will reduce pressure / need for green field sites.

Object

Representation ID: 16959

Received: 23/03/2021

Respondent: Avant Homes

Agent: ID Planning

Housing Need and Requirement

A number of required changes are sought to policy SP8 as detailed in submission, summarised as:
• Policy too long and should be split into a number of separate shorter policies;
• Object to the proposed housing requirement figures linked to identifed job growth in SP6
- 35% uplift should be applied to the requirement;
• Housing requirement calculation should be clear and transparent and provided in the supporting text;
• Part A statement referring to ‘a significant boost in housing delivery’ should be deleted.
- Part C of the policy to be amended to provide clear guidance policy on what additional growth opportunities are supported.
• Object to the windfall allowance, further evidence to justify the amount is needed;

Object

Representation ID: 16987

Received: 18/03/2021

Respondent: Bingley Town Council

Housing Distribution - Bingley

In 2020 the partial review of the Core Strategy recommended a lower overall housing requirement for Bradford, including Bingley circa 800, Cottingley 0.

Bingley Town Council Draft Neighbourhood Plan Housing Chapter P28-29 states; ‘the level of housing planned for the town was highlighted as a major concern of respondents to the consultation undertaken as part of the preparation of this Plan. It showed that residents were not opposed to further house building but were very concerned about the scale of new housing planned to take place, much of it on land presently in the Green Belt. In particular, that it would be ‘disproportionate and not sustainable. It was placing significant pressure on already stretched facilities such as health, education, green spaces and the road network. In addition, it was adding to the already high levels of commuting away from the Parish for jobs and services.’

An independent Housing Needs Assessment was carried out for Bingley Town Council’s Draft Neighbourhood Plan in 2020. This is available at https://bingleytowncouncil.gov.uk/?mdocs-file=61310 We would draw your attention to the policies agreed based on the data and information contained in this Housing Needs Assessment.
-H1 Green Hill Housing Development
-H2 Mix and Type of Housing
-H3 Crosley Wood Affordable Housing
-H4 Affordable Housing
-H5 Exception Sites for Affordable Housing
-H6 Climate Emergency Design Considerations
-H7 Flooding and Water Management Considerations
-H8 Resilient Building

Object

Representation ID: 17115

Received: 24/03/2021

Respondent: Caddick Developments Ltd

Agent: DPP Planning

Housing Requirement

It is considered that Policy SP8 is not fit for purpose and is unsound. We object to the proposed policy as it does not include the 35% uplift in housing need set nationally. 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.

Object

Representation ID: 17116

Received: 24/03/2021

Respondent: Caddick Developments Ltd

Agent: DPP Planning

Housing Distribution - 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.

Support

Representation ID: 17121

Received: 24/03/2021

Respondent: Countryside Properties Yorkshire

Agent: DPP Planning

In respect of Question 9 regarding Policy SP8 and housing growth we support the proposed allocation of the sites known as SE4/H and SE30/H and we consider that they will make a valuable contribution to the housing requirement for the Bradford SE housing market area.

Object

Representation ID: 17126

Received: 24/03/2021

Respondent: Countryside Properties Yorkshire

Agent: DPP Planning

Housing Need and Requirement

It is considered that Policy SP8 is not fit for purpose and is unsound. We object to the proposed policy as it does not include the 35% uplift in housing need set nationally.

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 except for Bradford City Centre.