Consultation Question 9

Object

Representation ID: 17127

Received: 24/03/2021

Respondent: Countryside Properties Yorkshire

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.

Object

Representation ID: 17131

Received: 24/03/2021

Respondent: Addingham Civic Society

Housing Distribution - Addingham

The housing allocation has been increased from 75 (Partial Review of the Core Strategy 2019) to 175 in the latest Preferred Options proposal, representing an increase of 133%. There is no specific evidence offered for this increase, which is incompatible with Addingham’s status as a “Local Service Centre”.

This proposed increase will result in the partial development of the “Sailor Fields” between the village and the A65 by-pass. It will destroy the linear nature of the village and the setting of its 129 listed buildings and monuments. It will also negatively impact the distinctive Dales landscape and bring new development into the South Pennine SAC/SPA Protection Zone.

The Green Belt was established to protect the “Sailor Fields” and this important function was confirmed by the Planning Inspectorate and BMDC itself. No “exceptional circumstances” have been put forward for these Green Belt changes.

These proposals are contrary to Addingham’s Neighbourhood Plan

Object

Representation ID: 17165

Received: 24/03/2021

Respondent: The Norris & Holmes Families

Agent: Savills

Housing Need and Requirement

See attached document.

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

Recommendation 5: The Council should strive for a higher ‘policy on’ housing figure, in the interests of aligning with the ambitions of the Leeds City Region Growth Strategy and Northern Powerhouse, in the interests of justified and positive plan making.

Object

Representation ID: 17166

Received: 24/03/2021

Respondent: The Norris & Holmes Families

Agent: Savills

Housing Distribution - Bradford NE

In the context of Recommendation 4 there should be a revision to the housing targets to raise the overall number which will have a 'trickle down’ effect on the figures quoted in this draft policy.

Schedule 1 of Policy SP8 indicates that the overall numbers for North East Bradford have dropped from 4,400 to 1,850 over the plan period - a decrease by over 50% - more than most. The reduction is not proportionate amongst the quadrants and there is no evidence which sets out the rationale as to why certain areas have been reduced more severely than others.

As detailed previously, delivering Brownfield sites within the city centre is challenging in BMDC.

Recommendation 6: Amend SP8, Schedule 1 in line with implications of recommendation 4, whilst redistributing growth in accordance with the capacity and viability of sites - recognising the full ability of the site to contribute to delivering the required housing. In the interests of effective plan making.

Object

Representation ID: 17172

Received: 24/03/2021

Respondent: Jones Homes (Yorkshire) Limited

Agent: Savills (UK) Ltd

Housing Need and Requirement:

The Draft Local Plan sets out a requirement for 30,672 new homes, down from the 42,100 net homes targeted within the 2017 Core Strategy.

We do not consider that the total set out within the draft is appropriately ambitious, and should be increased to meet the requirements as set out by central Government within the Standard Methodology. When taking the 35% uplift into account, as the Government’s preferred approach for meeting national housing delivery targets, the plan should be delivering around 2,300 homes per annum, equating to 41,400 over the 18 years of the plan period.

It should also be noted that the Standard Method figure is a ‘floor’ rather than a ‘ceiling’ figure. The implications for restricting growth, under-delivery and engagement of the presumption in favour of sustainable development could therefore be significant if the Council does not at this stage identify land for a more aspirational housing delivery target.

Object

Representation ID: 17173

Received: 24/03/2021

Respondent: Jones Homes (Yorkshire) Limited

Agent: Savills (UK) Ltd

Housing Distribution - Cottingley

Based on the Core Strategy and the Standard Methodology, we do not consider that any aspiration below 41,400 (the Standard Methodology) homes is appropriate.

If the housing aspiration is raised to the required 41,400, and distributed in the same manner as the draft local plan (therefore with 37,351 on allocated sites), Local Service Centres would deliver 1,681 homes, with 187 in Cottingley.

Recommendation 8: The housing delivery target set out at Policy SP8 needs to be increased significantly to meet the requirements of the Standard Method.

Recommendation 10: That the specific housing site allocations as identified at Schedule 1 and Paragraph D2 of Policy SP8 should increase the housing allocation for Cottingley to at least 187, with at least 1,681 allocated across all Local Service Centres.

Object

Representation ID: 17240

Received: 24/03/2021

Respondent: Mark Wogden

Housing Distribution - Silsden

Silsden is saddled with a disproportionately large number of new houses - 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.

Since the publication of the draft plan, permission has been granted for a further 40 houses at The Willows, next to the canal. This has not been taken into consideration to meet the target housing numbers.

The site allocation for houses 'works backwards' from sites that are easy to deliver i.e. low density greenfield sites which commercial housebuilders will happily deliver - this will drive up commuting as the houses are unlikely to be occupied by people in local employment.

The suggested numbers for the allocated housing sites in Silsden would deliver a density of 28.6 units per hectare, - below the Councils stated policy HO2.

Support

Representation ID: 17422

Received: 23/03/2021

Respondent: Mr & Mrs . Pyrah and Saunders

Number of people: 4

Agent: ID Planning

Housing Need and Requirement

Support subject to amendments. Changes are 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;
• 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: 17549

Received: 23/03/2021

Respondent: Barratt Homes and David Wilson Homes

Agent: ID Planning

Housing Need and Requirement

A number of required changes are sought to policy SP8 as detailed above. The changes can be summarised as:-
-Policy too long and should be split into a number of separate shorter policies;
• We object to the proposed housing requirement figure of 1,704 per annum and the justification to not include/ or meet the 35% uplift of the standard method. 35% uplift should be applied to the requirement;
• Housing requirement calculation should be clear and transparent and provided in the supporting text;
• 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: 17688

Received: 23/03/2021

Respondent: Bannister Investments Limited

Agent: ID Planning

Housing Need and Requirement

A number of required changes are sought to policy SP8 as detailed above. The changes can be 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;
• 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;

Comment

Representation ID: 18163

Received: 24/03/2021

Respondent: Mr Raymond Wilkes

Housing Distribution - Bradford City Centre

We need lots of new housing but it is very difficult to find locations.

I am pleased that BMDC is finding some city centre locations. This is really great as it helps the centre and avoids filling up fields with houses.

I accept some fields will have to go. It would help if a way could be found to create new woodlands and greenspace and paths around and among new houses.

Many old people live in large houses which were once family houses and more accommodation for the elderly should be created.

Such accommodation is better in urban areas and allows higher density housing while releasing existing family homes. It is understandable that many elderly people who really need to move for their own benefit are reluctant to do so due to nostalgia and inertia. A programme to help such people move would be beneficial and create new housing without new building.

Object

Representation ID: 18383

Received: 24/03/2021

Respondent: Johnson Mowat

Housing Requirement

The proposed 1,704 dwellings / annum is a substantial reduction compared to the Council's 2017 position tested in examination i.e. 2,476.

HBF calculates minimum housing need (standard methodology) to be 1,699. The additional 35% uplift to be applied to minimum need for Bradford (and other large urban areas) is a central Government requirement and not an option for a LA to accept or reject. It is inappropriate to reject this as the Council has done in paragraphs 3.8.11 and 3.8.12

The identification of ‘strategic constraints (Green Belt)’ as a reason not to apply the uplift is unacceptable.

PPG indicates this increase / uplift is expected to be met by the cities and urban centres themselves, rather than the surrounding areas’. i.e. the uplift should not be met by substantial additional allocation of land in rural areas or lower order settlements.

However, the allocation of additional green belt land abutting the main urban areas is appropriate.

Part A of Policy SP8 should be amended to:

‘The Local Plan will seek to deliver a housing requirement of 41,407 new homes over the plan period 2020-2038, equating to an indicative average of 2,300 new dwellings per annum.'

Object

Representation ID: 18384

Received: 24/03/2021

Respondent: Johnson Mowat

Housing Distribution - Bradford City Centre

The proposed spatial distribution places an over-reliance on the city centre. We have no objection to ambitious levels of housing growth within the city centre in their own right, provided these are realistic, deliverable. However a realistic view must be taken on the underlying social and economic changes that are required to achieve this.

We object to the use of a high target number for the city centre to justify unduly low or reduced target numbers in other locations.

Given the requirement for a broad mix housing types and locations, additional allocations should be made across all settlements.

An alternative distribution is proposed derived by:
- applying the adopted Core Strategy proportions to the Local Housing need (excluding 35% uplift).
- adding and distributing the 35% uplift to the Regional City including retaining the City Centre focus;
- making various adjustments.
- allocating additional land accordingly to accommodate the increased targets;

Object

Representation ID: 18385

Received: 24/03/2021

Respondent: Johnson Mowat

Previously Developed Land

Johnson Mowat supports the Council in making as much use as possible of previously developed land (PDL) in accordance with NPPF.

However, we consider that it is important to ensure that the prioritisation of PDL does not compromise the delivery of sufficient homes in sustainable locations to meet identified needs.

We therefore query whether the proportions indicated within part H of the draft Policy are realistic and achievable, particularly given the assumptions relating to density and demand/values/viability that this will depend upon to deliver large numbers of dwellings within the inner urban and post-industrial areas.

It is therefore considered that the proportions indicated are presented as targets with a degree of flexibility.

Object

Representation ID: 18405

Received: 24/03/2021

Respondent: The Emerson Group

Agent: Johnson Mowat

Housing Need and Distribution - Bradford SE

Johnson Mowat object to the Council’s approach to rejecting the Government’s 35% uplift and consider it is fundamentally incorrect to do so.

The 35% uplift to the housing requirement should apply to Bradford South East (including Wyke). It is considered therefore that the Local Plan should identify additional sites in and on the edge of the urban area to accommodate the housing requirement uplift. Site SE/126 would contribute towards the housing need in Wyke and the South East sub area.

Object

Representation ID: 18411

Received: 24/03/2021

Respondent: The Wright Trust

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: 18743

Received: 23/03/2021

Respondent: Matthew, Jonathan & Robert Brooksbank

Number of people: 3

Housing Distribution - Ilkley

1. We believe that the proposed housing numbers for Ilkley, as the principal local town, are very low at 300. When based on population the requirement is for 756 new dwellings.

300 amounts to only 39% of the requirement.

2. In our opinion 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 of nearly 60% of the requirement.

This would increase the supply of affordable homes in Ilkley for which there is a great shortage.

Object

Representation ID: 18922

Received: 23/03/2021

Respondent: Mrs WE Nichol

Agent: Carter Jonas

Housing Need and Requirement

Policy SP8 sets out the housing requirement of 30,672 new homes over the Plan period 2020 to 2038, equating
to an indicative average of 1,704 dwellings per annum (dpa). This does not include the 35% urban centre uplift
required by the standard method which equates to a minimum Local Housing Need of 2,300 dwellings per
year.

We do not consider this to be consistent with national policy or the Government’s objective to boost the supply
of homes.

The PPG makes it clear within paragraph 002 Ref ID: 2a-002-20190220 that the calculation of housing need using the standard method is a minimum figure and does not produce a housing requirement.

The Council should amend the housing requirement to better reflect the Local Housing Need identified by the standard method, and to take into consideration the circumstances where it may be appropriate to plan for a higher figure.

Object

Representation ID: 18932

Received: 23/03/2021

Respondent: Mrs J Kamyar

Agent: Carter Jonas

Housing Need and Requirement

Policy SP8 sets out the housing requirement of 30,672 new homes over the Plan period 2020 to 2038, equating
to an indicative average of 1,704 dwellings per annum (dpa). This does not include the 35% urban centre uplift
required by the standard method which equates to a minimum Local Housing Need of 2,300 dwellings per
year.

We do not consider this to be consistent with national policy or the Government’s objective to boost the supply
of homes.

The PPG makes it clear within paragraph 002 Ref ID: 2a-002-20190220 that the calculation of housing need using the standard method is a minimum figure and does not produce a housing requirement.

The Council should amend the housing requirement to better reflect the Local Housing Need identified by the standard method, and to take into consideration the circumstances where it may be appropriate to plan for a higher figure.

Object

Representation ID: 18942

Received: 23/03/2021

Respondent: Mrs I Wood

Agent: Carter Jonas

Housing Need and Requirement

Policy SP8 sets out the housing requirement of 30,672 new homes over the Plan period 2020 to 2038, equating
to an indicative average of 1,704 dwellings per annum (dpa). This does not include the 35% urban centre uplift
required by the standard method which equates to a minimum Local Housing Need of 2,300 dwellings per
year.

We do not consider this to be consistent with national policy or the Government’s objective to boost the supply
of homes.

The PPG makes it clear within paragraph 002 Ref ID: 2a-002-20190220 that the calculation of housing need using the standard method is a minimum figure and does not produce a housing requirement.

The Council should amend the housing requirement to better reflect the Local Housing Need identified by the standard method, and to take into consideration the circumstances where it may be appropriate to plan for a higher figure.

Object

Representation ID: 18952

Received: 23/03/2021

Respondent: Mr GRN Jones

Agent: Carter Jonas

Housing Need and Requirement

Policy SP8 sets out the housing requirement of 30,672 new homes over the Plan period 2020 to 2038, equating
to an indicative average of 1,704 dwellings per annum (dpa). This does not include the 35% urban centre uplift
required by the standard method which equates to a minimum Local Housing Need of 2,300 dwellings per
year.

We do not consider this to be consistent with national policy or the Government’s objective to boost the supply
of homes.

The PPG makes it clear within paragraph 002 Ref ID: 2a-002-20190220 that the calculation of housing need using the standard method is a minimum figure and does not produce a housing requirement.

The Council should amend the housing requirement to better reflect the Local Housing Need identified by the standard method, and to take into consideration the circumstances where it may be appropriate to plan for a higher figure.

Object

Representation ID: 19386

Received: 24/03/2021

Respondent: Jenefer McCabe

Housing Distribution - Burley in Wharfedale

I wish to add my support to Burley Parish Council relating to the issues regarding the proposal in the plan to allocates 625 new homes for Burley in Wharfedale, including 500 homes at Sun Lane (planning permission now approved) and 110 at Scalebor House.

It is totally unsustainable for the many reasons listed by Burley Parish Council in their report especially those relating to medical provision and education for a village of this size as well as taking into consideration the number of additional vehicles this will generate on local roads which are already at saturation point.

Object

Representation ID: 19454

Received: 24/03/2021

Respondent: Mr Malcolm Lee

Housing Distribution - Ilkley

On a broader note, the description of Ilkley in the introduction accurately portrays the character of the town however, these proposals to squeeze another 300 houses into it´s boundary risks jeopardising this character and attractiveness.It is already blighted by major problems from traffic and parking caused by overdevelopment. Any further development should not require the removal of sensitive and important Green Belt sites. I would describe alternative and less sensitive or important sites in Ilkley as land adjacent the OFS on Wheatley Road, or extension of the residential area adjacent Skipton Road at the town boundary.

In terms of housing provision until 2038, I would suggest the development of less sensitive areas such as South of Silsden on the Keighley Skipton corridor with excellent road and rail links with acccess to the nearby Airedale Hospital. This may mean less annual revenue from Council tax but practical in terms of housing provision.

Object

Representation ID: 19609

Received: 23/03/2021

Respondent: Alison Sampson

Housing Need and Requirement

We should like to oppose the Bradford City Council Local Plan proposals affecting Ilkley sites off Coutances Way and Wheatley Grove.

We would also question the assumptions which have been applied to drawing up the Local Plan housing requirements which also need to take into account the impact of Brexit and COVID-19 which has yet to be quantified in terms of housing demand. Historical data surely cannot be relied upon.

Object

Representation ID: 19610

Received: 23/03/2021

Respondent: Nina Dereix

Housing Distribution - Addingham

I was shocked to discover the extent of the enormous number of 175 houses for the small rural village.

Addingham is a unique village on the edge of the Yorkshire Dales which does not have a rail link to Leeds or Bradford and there is only a limited and lengthy bus service to these towns. I am in doubt as to why the village would be required to accommodate so many new houses given its relatively small semi rural community.

Furthermore several of the sites are Green Belt land which, if developed, would impact hugely on the village.

The neighbourhood plan for Addingham has only just been voted upon and the agreed plan did not impact on any Green Belt areas within the village or surrounding fields. The proposed plans do not take into account the wishes of the local community therefore.

Object

Representation ID: 19774

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

This section of the Local Plan makes no reference to the need to achieve much higher housing densities than are proposed in this plan for Shipley – for example - in order to avoid the use of greenbelt and greenfield sites for housing and / or to mitigate the need to do so.

We note that the Campaign for the Protection of Rural England has previously suggested that 50dph is a minimum reasonable target to aim for in general and especially when considering the use of non-brownfield sites for housing (see CPRE publication, ‘Compact Sustainable Communities’, November 2006, p.3).

Object

Representation ID: 19810

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

This section of the Local Plan makes no reference to the need to achieve much higher housing densities than are proposed in this plan for Shipley – for example - in order to avoid the use of greenbelt and greenfield sites for housing and / or to mitigate the need to do so.

We note that the Campaign for the Protection of Rural England has previously suggested that 50dph is a minimum reasonable target to aim for in general and especially when considering the use of non-brownfield sites for housing (see CPRE publication, ‘Compact Sustainable Communities’, November 2006, p.3).

Object

Representation ID: 19836

Received: 01/04/2021

Respondent: Natural England

As outlined earlier, Natural England welcomes the commitment to ensuring that a sequential approach is taken to site selection and allocation, which is expanded upon within the supporting text for Policy SP8.

We would ask you to note that Brownfield sites can comprise Open Mosaic Habitat (OMH) (a priority habitat). Where development is proposed on sites where OMH is identified, the relevant policies should set out appropriate mitigation measures for any loss of this habitat, such as bespoke green/blue roofs and/or landscaping measures to be incorporated into development proposals and secured by condition.

Object

Representation ID: 19942

Received: 24/03/2021

Respondent: Avant Homes

Agent: Tetra Tech (Leeds)

Housing Need and Requirement

The Government have introduced changes to the Standard Method for calculating housing requirements - it now requires a 35% uplift on housing numbers in the 20 largest cities and urban areas in England (of which Bradford is one).

The Council is failing to pursue this increased housing requirement.

Bradford has well documented evidence of the problems it has faced in terms of housing land supply, the 5 year housing land supply statement 2020-2025 details that over the period of 2013 – 2020 there has been a shortfall in the planned delivery of homes equalling 8,588 dwellings (a net figure of 9,069 dwellings).

We consider the Council has set a modest and unambitious target, to meet a minimum requirement but such an approach will only serve to compound delivery.

Overall, we consider the Local Plan is contrary the objectives of the NPPF para 59. “To support the Government’s objective of significantly boosting the supply of homes..... ”

We also suggest, as we did in the CSPR 2019, that the scale of need for affordable housing justifies an uplift to the overall housing requirement figure.

Object

Representation ID: 19943

Received: 24/03/2021

Respondent: Avant Homes

Agent: Tetra Tech (Leeds)

Housing Distribution - Bradford City Centre / Menston

We consider the Council has set a modest and unambitious target, to meet a minimum requirement but such an approach will only serve to compound delivery.

It is narrow in its focus, with too much reliance on the Regional City of Bradford whilst restricting provision in some of the outer areas including the more desirable higher market value areas. Not only will this serve to restrict a balanced approach to housing supply it will compromise the range and choice of housing stock that can be delivered to the detriment of local market needs in the outer areas.

We consider additional land should be released from the Green Belt having greater regard for the settlement hierarchy to deliver a wide choice of quality homes and maximise opportunities for delivery.

The reliance on delivery of a large proportion of homes in Regional City of Bradford (72%) and in particular Bradford City Centre, at the expense of delivery in the outer areas, will compromise the choice of quality homes and the mix of types, sizes, tenures across the District. The distribution as currently proposed will not provide a balanced supply to the district.

We consider therefore that changes are required to Policy SP8 to reflects Menston’s status as a sustainable location for new housing development.