Consultation Question 37

Showing comments and forms 1 to 26 of 26

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 3702

Received: 23/03/2021

Respondent: Mr Philip Sutcliffe

Representation Summary:

he green belt was set up to stop urban expansion. In the case of
Bradford, to stop it becoming part of Leeds. Bradford planning office
being completely undemocratic wishes to pour cement and tarmac all
over the green belt in Tong. The reason I say undemocratic is as
follows. ~There has not been one survey, or opinion poll taken in
Bradford, which agrees with Bradford councils views on building on
green belt. In fact approx 90 % of population of Bradford totally
disagree with Bradford councils housing and road plans. However, the council which claims
represents the people is acting like a fascist state.

Your new road and housing plans directly effect my Grade II house and
land. However, you have not had the decency to contact me over the
last 10 years. I doubt you care less about me than the environment and
the creatures that need it.

Comment

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 6486

Received: 15/02/2021

Respondent: Bruce Barnes

Representation Summary:

It is disappointing that the plan does not focus on improvements to private sector housing stock, especially energy conservation, for the properties in inner city Bradford. A coherent plan would meet many of the intentions of the local plan-Is there to be a supplementary document to tackle this matter.

Comment

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 9814

Received: 12/03/2021

Respondent: Bradford District Ward Councillor (Labour)

Representation Summary:

HO 9 Housing standards. Always disappointing. New houses are too small in terms of room size. Are there to be stipulations round insulation, energy use, quality of gardens etc. Is it time to specify heat pumps or are we too soon?

Comment

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 10333

Received: 24/03/2021

Respondent: Barratt Homes and David Wilson Homes Yorkshire West

Agent: Sheppard Planning

Representation Summary:

Barratt support the provision of accessible, adaptable and wheelchair user dwellings. However, the requirement for these types of homes should be applied on flexible basis and be supported by appropriate evidence of need.

NPPG offers guidance on what evidence to consider, and Barratt suggest that this need, with suitable flexibilities included, is further examined before particular amounts and types of provision are specified in Policy.

Indeed, NPPG advises that: Planning policies for accessible housing need to be based on evidence of need, viability and a consideration of site specific factors

The current policy sets a standard requirement for all housing to be M4(2) and 5% to be M4(3). This would not accord with NPPF guidance on flexibility in plan making, nor could it reasonably be based on a consideration of viability of any particular site, nor any other site specific factors, given that it is a blanket policy approach.

Barratt suggest that this policy should be reviewed to provide suitable flexibility. This would ensure that accessible housing is provided in the locations where there is an identified need, and to avoid making provision in areas which may be less suitable or accessible to some users.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 10966

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

Representation Summary:

This draft policy requires all new dwellings to be built to M4(2) standards.

If the Council are to adopt these optional technical standards, they must apply the criteria set out in the PPG.

The PPG2 identifies the type of evidence required to introduce such a policy, including the likely future need; the size, location, type and quality of dwellings needed; the accessibility and adaptability of the existing stock; how the needs vary across different housing tenures; and the overall viability. This evidence has not been provided at this stage.

There is also a need to consider other site-specific factors, including vulnerability to flooding, site topography and other circumstances.

The Council must provide a robust evidence base to justify the introduction of the optional technical standards.

Flexibility needs to be added into the policy wording to allow for exemptions to the policy where it may not be possible to achieve the standards due to site-specific matters or viability considerations.

Comment

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 12372

Received: 21/03/2021

Respondent: Manny McKenzie

Representation Summary:

Given the Climate Crisis and Bradford Council's Climate Emergency Resolution, tough building standards should be adopted to ensure all new build homes meet insulation standards at Passiv House or carbon neutral level.
In some areas in Bradford, (inner city/brownfield sites), the margins between cost of development and likely sale price might be slim, therefore the added costs of building to Passiv House standards (10-15%) might make this uneconomic. However, if every effort was made to use available grants/subsidies for energy efficient housing, this would mean such housing would remain affordable particularly for first time buyers and those with a limited budget (who otherwise would be excluded from being able to afford truly energy efficient housing). For more desirable areas there would be less of an issue in a slightly higher asking price for such housing given the lifetime savings on utility bills. Should the Council introduce such a building standard, it would mark Bradford as an environmentally aware and climate-responsible city and increase it's attractiveness.

Comment

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 16607

Received: 24/03/2021

Respondent: Jude Hamon

Representation Summary:

I'm emailing in response to the plans for new-build houses in Ilkley although the principles below should apply to all areas of new housing you are planning to build.

Although I'm not massively in favour of building new houses, I appreciate that they are needed due to the ever increasing population in the UK.

My initial concern would be to avoid greenbelt land but I think we're pretty well only left with that now.

However such housing should incorporate green design, limit impact on environment and build in ability for nature to share the space with new inhabitants i.e.
- carbon neutral homes designed with environmentally friendly boilers, solar panels
- nature friendly so include swift bricks etc.
- tree lined streets
- green spaces between buildings
- incorporate bikes lanes and footpaths into layouts;

Comment

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 16863

Received: 24/03/2021

Respondent: Robin Hamon

Representation Summary:

I would like to suggest the following:
1. Implement energy saving measures in your new builds: roof and wall insulation, double glazing, solar panels.
2. Is it possible to use next generation biomass boilers or at least the highest rated efficiency boilers in these new homes?

3. Could you offer some kind of incentive for residents to use 100% renewable energy suppliers to provide gas and electric to their homes?
4. Install swift bricks.
5. Have you considered installing (communal) compost bins at these sites?

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 16971

Received: 23/03/2021

Respondent: Avant Homes

Agent: ID Planning

Representation Summary:

Part C - We generally support the provision of such technical standards however, further evidence is required to justify the requirement as detailed in the policy.

There is no evidence to support the proposed threshold of 10 dwellings or 5% in relation to wheelchair user standards. Further information and evidence is required to justify these requirements.

There are specific costs associated with meeting these needs which could have viability implications for the delivery of housing. Paragraph 4.22.8 explains that the standards have been assessed as part of the whole plan viability and that site circumstances will be considered if the standards are not viability. The viability of meeting the requirements should be mentioned in the policy.

Part E of the policy refers to Nationally Described Space Standards being implemented. Further evidence from the Council is necessary justify the need for internal space standards.

Required Change
The policy wording should be amended to provide flexibility and viability for future development.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 17658

Received: 23/03/2021

Respondent: Barratt Homes and David Wilson Homes

Agent: ID Planning

Representation Summary:

Part C requires all new homes (over 10 dwellings) to be built to accessible standards and 5% of new homes built to M4(3) standards. We generally support the provision of such technical standards however, further evidence is required to justify the requirement as detailed in the policy.
There is no evidence to support the proposed threshold of 10 dwellings or 5% in relation to wheelchair user standards. Further information and evidence is required to justify these requirements.
There are specific costs associated with meeting these needs which could have viability implications for the delivery of housing. Paragraph 4.22.8 explains that the standards have been assessed as part of the whole plan viability and that site circumstances will be considered if the standards are not viability. The viability of meeting the requirements should be mentioned in the policy.
Part E of the policy refers to Nationally Described Space Standards being implemented. Further evidence from the Council is necessary justify the need for internal space standards. Government guidance is clear that there needs to be robust and credible evidence on both need and viability to warrant the introduction of a policy requiring all new homes to meet NDSS.
Required Change
The policy wording should be amended to provide flexibility and viability for future development.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 17702

Received: 23/03/2021

Respondent: Bannister Investments Limited

Agent: ID Planning

Representation Summary:

We generally support the provision of such technical standards. However, further evidence is required to justify the requirement as detailed in the policy.
There is no evidence to support the proposed threshold of 10 dwellings or 5% in relation to wheelchair user standards. Further information and evidence is required to justify these requirements.
There are specific costs associated with meeting these needs which could have viability implications for the delivery of housing. Paragraph 4.22.8 explains that the standards have been assessed as part of the whole plan viability and that site circumstances will be considered if the standards make the site unviable. The viability of meeting the requirements should be mentioned in the policy.
Part E of the policy refers to Nationally Described Space Standards being implemented. Further evidence from the Council is necessary to justify the need for internal space standards.
Required Change
The policy wording should be amended to provide flexibility and viability for future development.

Comment

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 18166

Received: 24/03/2021

Respondent: Mr Raymond Wilkes

Representation Summary:

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. A good scheme might change nimby’s into supporters.

Usually .if there is a right of way through new housing it is hemmed in by fences and quickly becomes a dump. Paths should be at least 2 metres wide and accessible from the new housing which is usually not the case.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 18398

Received: 24/03/2021

Respondent: Johnson Mowat

Representation Summary:

Supports the position of the HBF regarding draft Policy HO9.

Part C / accessibility standards - it is incumbent on the Council to provide a local assessment evidencing the specific case for Bradford which justifies the inclusion of optional higher standards for accessible and adaptable homes in its Local Plan policy. If the Council can provide the evidence then the HBF recommends that an appropriate transition period is included within the policy.

The requirement for a greater proportion of dwellings to meet particular accessibility standards is likely to affect the overall level of development that may be achieved on a site, which then needs to be reflected in policies relating to the expected density of development (draft Policy HO2) and assessments of development viability.

The requirement at part E/1 of the Policy for all new market and affordable homes to meet the Nationally Described Space Standard (NDSS) for internal space in new dwellings should only be included if the Council can provide appropriate evidence to support this in terms of need, viability and timing as stated in PPG.

Comment

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 19923

Received: 23/03/2021

Respondent: Climate Action Ilkley

Number of people: 7

Representation Summary:

1. All new housing should be mandated to be carbon-neutral, or even carbon positive (generating more renewable energy than they consume) as a condition of planning permission. For example, they should incorporate at minimum:
* A very high standard of insulation, such as Passivhaus.
* Heating and cooking systems that rely on electricity rather than fossil fuels.
* Renewable power generation, such as via rooftop solar PV, air or ground source heat pumps.
* Low energy, high efficiency appliances.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 24607

Received: 24/03/2021

Respondent: Gleeson Homes

Agent: Pegasus Group (Leeds)

Representation Summary:

In determining whether the NDSS should be introduced it is essential to recognise that these are optional standards. Footnote 46 of the 2019 NPPF advises that: “Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified.”

Standardisation of size diminishes customer choice. Gleeson Homes build a wide range of properties including entry level two, three and four-bedroom. Requiring NDSS compliant properties for all new dwellings could reduce opportunities for people to access the housing market by removing smaller open market products. This will effectively cut-off a source of supply for many first-time buyers, first-time movers and young families. The reduction in diversity may also harm build rates.

Due to the current increase in people working from home additional rooms may be sought to accommodate home offices. Therefore, flexibility is key. It is not considered essential that home offices strictly adhere to the NDSS.

It should also be noted that if the Council can justify the introduction of the NDSS a transitional period should be included within the policy (PPG ID: 56-020-20150327).

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 25169

Received: 23/03/2021

Respondent: Home Builders Federation

Representation Summary:

All new build dwellings should meet Building Regulation requirement M4(2) 'accessible and adaptable dwellings'.

On major development sites over 0.5 hectare or 10 or more homes a minimum of 5% of dwellings should meet the Building Regulations requirement M4(3) 'wheelchair user dwellings', designed to be wheelchair accessible, or easily adaptable for residents who are wheelchair users.

The HBF is generally supportive of providing homes that are suitable to meet the needs of older people and disabled people. However, if the Council wishes to adopt the higher optional standards for accessible, adaptable and wheelchair homes the Council should only do so by applying the criteria set out in the PPG.

PPG identifies the type of evidence required to introduce such a policy, including the likely future need; the size, location, type and quality of dwellings needed; the accessibility and adaptability of the existing stock; how the needs vary across different housing tenures; and the overall viability. It is incumbent on the Council to provide a local assessment evidencing the specific case for Bradford which justifies the inclusion of optional higher standards for accessible and adaptable homes in its Local Plan policy. If the Council can provide the appropriate evidence and this policy is to be included, then the HBF recommends that an appropriate transition period is included within the policy.

The PPG also identifies other requirements for the policy including the need to consider site specific factors such as vulnerability to flooding, site topography and other circumstances, this is not just in relation to the ability to provide step-free access.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 25170

Received: 23/03/2021

Respondent: Home Builders Federation

Representation Summary:

The policy goes on to require all new market and affordable homes should, as a minimum, meet the Nationally Described Space Standard (NDSS) for internal space in new dwellings. The NDSS as introduced by Government, are intended to be optional and can only be introduced where there is a clear need and they retain development viability. As such they were introduced on a ‘need to have’ rather than a ‘nice to have’ basis.

PPG identifies the type of evidence required to introduce such a policy. It states that ‘where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies. Local planning authorities should take account of the following areas:
•Need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes.
•Viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted.
•Timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions’.

The Council will need robust justifiable evidence to introduce the NDSS, based on the criteria set out above. The HBF considers that if the Government had expected all properties to be built to NDSS that they would have made these standards mandatory not optional.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 25171

Received: 23/03/2021

Respondent: Home Builders Federation

Representation Summary:

The council will encourage the use of new and innovative smart waste collection systems including underground bin systems where appropriate and feasible, in particular, on larger strategic sites and developments of 500 properties or more or for high density developments. The HBF has concerns about the viability of this policy, at the moment it is not clear what the costs for these smart waste collections might be, but it is likely any underground provision would add significantly to the cost of any development. The HBF also has concerns in relation to the waste authority’s ability to work with these waste requirements, and whether they will be committed to working with these smart solutions for the life of the dwellings, buildings or developments provided.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 27921

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

Representation Summary:

Support policy aims for new build dwellings to meet Building Regulation requirements M4(2) (accessible & adaptable homes) and for 5% of dwellings on major sites to meet Building |Regulations requirement M4(3) (wheelchair user dwellings).

EMFL is supportive of these aims but considers that the Council has not presented appropriate evidence to adopt the higher optional standards for accessible, adaptable and wheelchair homes the Council should only do so by applying the criteria set out in the PPG.

Policy requires new homes, as a minimum, meet the National Described Space Standards (NDSS) for internal space in new dwellings. They are intended to be optional and can only be introduced where there is a clear need and retain development viability. As such they were introduced on a “need to have” rather than “nice to have” basis. Council has failed to provide sufficient justification for the need for the policy.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 27963

Received: 24/03/2021

Respondent: Bellway Homes Limited

Agent: Barton Wilmore

Representation Summary:

It is noted that the Policy seeks all new homes to meet the Nationally Described Space Standards (NDSS).

The PPG is clear that NDSS can only be introduced into local planning policy where there is a clear and identified need to do so and that to do so would be viable. Whilst in principle our Client understands why the Council may seek to introduce NDSS this must not be done on the basis of being an aspiration, they must be a clear and identified requirement to do so.

Similarly, the requirement for all new properties to meet Building Regulation M4(2) ‘accessible and adaptable dwellings’ and 5% of homes on major developments of 10 or more units meeting Building Regulations M4(3) ‘wheelchair user dwellings’ has to be fully evidenced before being introduced to policy.

Comment

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 28037

Received: 24/08/2021

Respondent: Aimee Rawson

Representation Summary:

Housing developments must be forward-thinking eco-homes with an absolute focus on environmentally-friendly buildings and eco-friendly elements. This, as your plan states, needs to be achieved alongside the development of good housing as well as affordable housing options. I’d like to see this reflected in the plan in more detail to show that the proposed developments must be well thought out with well-being in mind, with good outdoor space and space around properties rather than rabbit-hutch development packed in uniform rows to maximise profit rather than quality of living.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 28528

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

Representation Summary:

It is noted that the Policy seeks all new homes to meet the Nationally Described Space Standards (NDSS). The PPG is clear that NDSS can only be introduced into local planning policy where there is a clear and identified need to do so and that to do so would be viable.

Whilst in principle our Client understands why the Council may seek to introduce NDSS this must not be done on the basis of being an aspiration, they must be a clear and identified requirement to do so.

Similarly, the requirement for all new properties to meet Building Regulation M4(2) ‘accessible and adaptable dwellings’ and 5% of homes on major developments of 10 or more units meeting Building Regulations M4(3) ‘wheelchair user dwellings’ has to be fully evidenced before being introduced to policy.

Comment

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 28577

Received: 24/03/2021

Respondent: Baildon Town Council

Representation Summary:

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.

 HOUSING QUAITY: If homes must be built here then, in a climate emergency, it is important that steps are taken to ensure good quality, affordable, eco-friendly, carbon-neutral houses are built. This may cost more in the short term but will save money in the medium to longer term for householders, who may have to retro-fit energy efficient heating and hot water systems, windows and insulation.

Object

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 29710

Received: 24/03/2021

Respondent: Keyland Developments Ltd

Agent: Barton Wilmore

Representation Summary:

It is noted that the Policy seeks all new homes to meet the Nationally Described Space Standards (NDSS). The PPG is clear that NDSS can only be introduced into local planning policy where there is a clear and identified need to do so and that to do so would be viable. Whilst in principle our Client understands why the Council may seek to introduce NDSS, this must not be done on the basis of being an aspiration, they must be a clear and identified requirement to do so.

Similarly, the requirement for all new properties to meet Building Regulation M4(2) ‘accessible and adaptable dwellings’ and 5% of homes on major developments of 10 or more units meeting Building Regulations M4(3) ‘wheelchair user dwellings’ must be fully evidenced before being introduced to policy.

Comment

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 29739

Received: 24/03/2021

Respondent: Mrs Caroline Whitaker

Representation Summary:

I WOULD LIKE TO SEE

Development

• Assurances that, if this plan is adopted, developers will be required rather than requested to build housing of far greater quality including highly insulated/Passivehouse, low energy demand, net zero designs.
• That such houses which are destined for the town should be developed to a very high design standard, with a mix of housing types to serve the community as a whole. This considered approach will achieve a higher density than is currently planned, thus further reducing the amount of green field sites required to meet any agreed housing numbers.

Comment

Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Representation ID: 29768

Received: 25/03/2021

Respondent: Ilkley Town Council

Representation Summary:

We recognise the immense challenges associated with transitioning to a net zero carbon District however these will only get harder and more costly if the Local Plan is not ambitious in addressing these matters in detail at this stage.

Should new housing be required this must be built with the highest insulation standards to promote energy efficiency and the use of renewable energy to prevent fuel poverty as a priority and avoid the need for retrofitting at a later date.