Consultation Question 30

Object

Representation ID: 27898

Received: 23/03/2021

Respondent: Samantha Armitage

BPC would agree that land use needs to be efficient in both city centre and rural settings. Revisions to increase the target minimum from 35 to 50 per hectare need careful consideration, but could assist in the delivery of affordable homes.

We would suggest that apartments could be part of the housing mix. Apart from being less expensive to build, apartments have a smaller total land footprint, are ideal for increasing housing density above the minimum 35 dwellings per hectare and, if built correctly, can support the BDMC’s Climate Emergency goals.

Comment

Representation ID: 27917

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

This policy states that unless site specific considerations indicate otherwise development should achieve a
minimum density of 35 dwellings per hectare (dph), with developments in locations including town centres
and areas well served by public transport and local amenities will be expected to achieve densities of at
least 50dph. The setting of residential density standards should be undertaken in accordance with the
paragraph 123 of the Framework where policies should be set to optimise the use of land. A range of
density standards specific to different areas of the city is appropriate to ensure that any proposed density
is appropriate to the character of the surrounding area.
The flexibility provided by this policy in relation to certain considerations is noted, this will allow developers
to react to some site-specific issues. However, further amendments could be made to create greater
flexibility to allow developers to take account of the evidence in relation to market aspirations, deliverability
and viability, the site’s context and accessibility.
The Council will also need to consider its approach to density in relation to other policies in the plan. Policies
such as open space provision, cycle and bin storage, housing mix, residential space standards, accessible
and adaptable dwellings and parking provision will all impact upon the density which can be delivered upon
site.

Object

Representation ID: 27961

Received: 24/03/2021

Respondent: Bellway Homes Limited

Agent: Barton Wilmore

The policy will require future developments outside of town, district, city and principal town centres to deliver developments at a density of 35 dwellings per hectare , which is an increase from 30 dwellings per hectare in the adopted Core Strategy. Furthermore, in the adopted Core Strategy, only areas within city centres and principal town centres were required to ‘possibly’ achieve densities over 30 dwellings per hectare, however there is now a requirement to achieve at least 50 dwellings per hectare. Whilst it is assumed this has been done to minimise the loss of Green Belt land, it will be at the expense of design. There are ever increasing requirements for new residential proposals such as provision of open space, biodiversity enhancements and space standards and it is considered that when all these matters are factored in, increasing density will put a strain on development proposals. As such, our Client objects to the policy as currently drafted.

Object

Representation ID: 28197

Received: 24/03/2021

Respondent: Sarah Lucas

BPC would agree that land use needs to be efficient in both city centre and rural settings. Revisions to increase the target minimum from 35 to 50 per hectare need careful consideration, but could assist in the delivery of affordable homes.

We would suggest that apartments could be part of the housing mix. Apart from being less expensive to build, apartments have a smaller total land footprint, are ideal for increasing housing density above the minimum 35 dwellings per hectare and, if built correctly, can support the BDMC’s Climate Emergency goals.

Object

Representation ID: 28287

Received: 24/03/2021

Respondent: Stephen Mould

BPC would agree that land use needs to be efficient in both city centre and rural settings. Revisions to increase the target minimum from 35 to 50 per hectare need careful consideration, but could assist in the delivery of affordable homes.

We would suggest that apartments could be part of the housing mix. Apart from being less expensive to build, apartments have a smaller total land footprint, are ideal for increasing housing density above the minimum 35 dwellings per hectare and, if built correctly, can support the BDMC’s Climate Emergency goals.

Object

Representation ID: 28524

Received: 26/03/2021

Respondent: Member of Parliament (Labour)

Housing requirement altered significantly from the Core Strategy (CS) (41,000+), Core Strategy Partial Review (CSPR) (26,100) and draft Local Plan (dLP) (30,672). Change not reflected across the District with Regional City taking significantly increased share.

CSPR requirement was opportunity to safeguard Green Belt - has not happened as dLP requires 5,267 dwellings in it.

Bradford South will suffer disproportionate burden of additional housing and Green Belt loss. 3,500+ dwellings proposed (11% of District requirement), 57% of which are Green Belt (1/3 of district’s total), with the majority (1,500) in one area. Neither equitable/sustainable.

Given Green Belt’s importance/sensitivity, its use should be minimised and development density towards the higher end. Green Belt sites average density (24/Ha) is below that of non-Green Belt sites outside main city/town centres, except Bradford South (28/Ha).

Area highly urbanised with overstretched infrastructure. Will add disproportionate burden on communities by removing more accessible Green Belt and intensifying urbanisation. Will give rise to health/wellbeing concerns.

Does not accommodate additional Government target (10,500 dwellings). Will have to come from Regional City. Concern it can only be met from Green Belt loss/further urban density in Bradford South.

Object

Representation ID: 28526

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

The policy will require future developments outside of town, district, city and principal town centres to deliver developments at a density of 35 dwellings per hectare , which is an increase from 30 dwellings per hectare in the adopted Core Strategy .

Furthermore, in the adopted Core Strategy, only areas within city centres and principal town centres were required to ‘possibly’ achieve densities over 30 dwellings per hectare, however there is now a requirement to achieve at least 50 dwellings per hectare. Whilst it is assumed this has been done to minimise the loss of Green Belt land, it will be at the expense of design. There are ever increasing requirements for new residential proposals such as provision of open space, biodiversity enhancements and space standards and it is considered that when all these matters are factored in, increasing density will put a strain on development proposals.

Comment

Representation ID: 28579

Received: 24/03/2021

Respondent: Baildon Town Council

Prior to building more houses much thought and investment is required in order to alleviate some of the impact on both the environment and the community.

 HOUSE NUMBERS: If the numbers of houses are critical in meeting Government targets then it is clear that more houses could be built on some of the sites especially if the push was for smaller eco-friendly houses with one car space per house, instead of larger detached.

Object

Representation ID: 29069

Received: 29/03/2021

Respondent: Historic England

There are historic areas within Bradford where the densities being proposed would result in considerable harm to their character. Paragraph 4.15.6, add the following text after the second sentence: ‘Densities below those set out in Policy HO2 may be allowed where it can be demonstrated that it is necessary in order to better-reflect the character of that area or to safeguard the setting of a heritage asset.’

We welcome the stipulation within Criterion A of the need
for densities to take account of their surroundings and those areas where local character would warrant lower densities. This will ensure that the densities of new residential developments reflect the character of the area in which they are located. We also welcome the references under Criteria B and C to site specific considerations or local area characteristics justifying lower housing densities in some cases. However, as currently written, it could be interpreted that
similar considerations will not be applied within the City
Centre and Principal Towns. The City Centre and Principal Towns contain the highest concentration of heritage assets in the District which, in some cases will provide opportunities for delivering higher densities, in others may justify developments providing lower densities.To avoid confusion, and to ensure that heritage assets are appropriately conserved, a similar caveat to that provided in Criteria B and C is required under Criterion D relating to development in the City Centre and Principal Towns.

Object

Representation ID: 29220

Received: 23/03/2021

Respondent: Rachel Wood

BPC would agree that land use needs to be efficient in both city centre and rural settings. Revisions to increase the target minimum from 35 to 50 per hectare need careful consideration, but could assist in the delivery of affordable homes.

We would suggest that apartments could be part of the housing mix. Apart from being less expensive to build, apartments have a smaller total land footprint, are ideal for increasing housing density above the minimum 35 dwellings per hectare and, if built correctly, can support the BDMC’s Climate Emergency goals.

Object

Representation ID: 29573

Received: 23/03/2021

Respondent: Harvey Bosomworth

BPC would agree that land use needs to be efficient in both city centre and rural settings. Revisions to increase the target minimum from 35 to 50 per hectare need careful consideration, but could assist in the delivery of affordable homes.

We would suggest that apartments could be part of the housing mix. Apart from being less expensive to build, apartments have a smaller total land footprint, are ideal for increasing housing density above the minimum 35 dwellings per hectare and, if built correctly, can support the BDMC’s Climate Emergency goals.

Object

Representation ID: 29613

Received: 17/03/2021

Respondent: Mr Mark Summerson

BPC would agree that land use needs to be efficient in both city centre and rural settings. Revisions to increase the target minimum from 35 to 50 per hectare need careful consideration, but could assist in the delivery of affordable homes.

We would suggest that apartments could be part of the housing mix. Apart from being less expensive to build, apartments have a smaller total land footprint, are ideal for increasing housing density above the minimum 35 dwellings per hectare and, if built correctly, can support the BDMC’s Climate Emergency goals.

Comment

Representation ID: 29656

Received: 14/03/2021

Respondent: Cullingworth Parish Council

We refer to item 4.15.5 where It states the minimum target for preferred allocations in rural areas to be 35 homes per hectare. We would refer you to Bradford City Centre/Bradford North East/Bradford South East, (urban areas 50 dpha) where preferred allocations are presented as units of 5, 6, 14, and 15. Rural locations should be allowed to incorporate smaller developments as part of their preferred allocations to ensure we protect the heritage and rural authenticity of small rural settlements.

Object

Representation ID: 29708

Received: 24/03/2021

Respondent: Keyland Developments Ltd

Agent: Barton Wilmore

The policy will require future developments outside of town, district, city and principal town centres to deliver developments at a density of 35 dwellings per hectare, which is an increase from 30 dwellings per hectare in the adopted Core Strategy.

Furthermore, in the adopted Core Strategy, only areas within city centres and principal town centres were required to ‘possibly’ achieve densities over 30 dwellings, however there is now a requirement to achieve at least 50 dwellings per hectare.

Whilst it is assumed this has been done to minimise the loss of Green Belt land, it will be at the expense of design. There are ever increasing requirements for new residential proposals such as provision of open space, biodiversity enhancements and space standards and it is considered that when all these matters are factored in, increasing density will put a strain on development proposals.

As such, our Client objects to the policy as currently drafted.

Comment

Representation ID: 29776

Received: 25/03/2021

Respondent: Ilkley Town Council

In the Local Plan, Bradford specifies two projected housing densities. For sites near main transport hubs, 50 dwellings per hectare and for other sites 35 dwellings per hectare.

The housing densities proposed for the sites identified by Bradford, in the Local Plan are very low indeed and much lower than those proposed by Bradford in the Plan.

By way of illustration Ilkley is planned to have 314 dwellings on the four sites.

For example
Only IL4/H approaches 50 dwellings per hectare (at that density it could take 11 dwellings rather than the 9 planned)
IL2/H, 1.18ha is planned to take 20 dwellings. At 50 per hectare it could take 59
IL1/H 7.18ha is planned to take 130, at an astonishingly low density of 18 dwellings per hectare. At 50 per ha it could take 359
IL3/H, 7.41ha is planned to take 155 dwellings (21 per hectare) whereas it could take 370. N.B. this number comes down to 350 if 0.4ha is allocated to a park and ride carpark

Given that three of these sites are on green belt, it seems impossible to justify building at a rate as low as between 18 and 21 dwellings per ha. These densities can only imply the building of large detached houses.

Object

Representation ID: 30012

Received: 23/03/2021

Respondent: Daniel Spencer

BPC would agree that land use needs to be efficient in both city centre and rural settings. Revisions to increase the target minimum from 35 to 50 per hectare need careful consideration, but could assist in the delivery of affordable homes.

We would suggest that apartments could be part of the housing mix. Apart from being less expensive to build, apartments have a smaller total land footprint, are ideal for increasing housing density above the minimum 35 dwellings per hectare and, if built correctly, can support the BDMC’s Climate Emergency goals.

Object

Representation ID: 30093

Received: 23/03/2021

Respondent: Mrs Savia Lorain Hughes

BPC would agree that land use needs to be efficient in both city centre and rural settings. Revisions to increase the target minimum from 35 to 50 per hectare need careful consideration, but could assist in the delivery of affordable homes.

We would suggest that apartments could be part of the housing mix. Apart from being less expensive to build, apartments have a smaller total land footprint, are ideal for increasing housing density above the minimum 35 dwellings per hectare and, if built correctly, can support the BDMC’s Climate Emergency goals.

Object

Representation ID: 30176

Received: 23/03/2021

Respondent: Catherine Terry

BPC would agree that land use needs to be efficient in both city centre and rural settings. Revisions to increase the target minimum from 35 to 50 per hectare need careful consideration, but could assist in the delivery of affordable homes.

We would suggest that apartments could be part of the housing mix. Apart from being less expensive to build, apartments have a smaller total land footprint, are ideal for increasing housing density above the minimum 35 dwellings per hectare and, if built correctly, can support the BDMC’s Climate Emergency goals.