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

Object

Representation ID: 10933

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We consider the plan period should be extended to 2040 resulting in a 20-year period .

The Core Strategy accounted for housing needs between 2004 and 2030 (a 26 year plan period) and sought to actively plan for new homes required between 2013-2030 (i.e. 17 years). The Site Allocations was originally anticipated to be adopted in 2020 resulting in a 10 year period where the Borough would have had a complete set of housing policies in place.
The above demonstrates that it takes a long time to prepare plans and therefore it is our view that once a plan is prepared and adopted it should plan for a considerable period of time. Planning for at least a 20 year plan period will mean plenty of scope and flexibility can be built into the plan to meet more pressing needs should these arise in the interim and before a full review of the Local Plan can be completed.

Support

Representation ID: 10937

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We support this policy but note that the Council are failing to abide by its principles by not positively planning for the number of homes that are required, that was and continues to be clearly set out in the recently adopted Core Strategy and the Local Housing Need requirement.

For the new Local Plan to be found sound, it must positively plan for a minimum 2,300 homes per annum.

Based on a 20 year plan period which we advocate under our response to Question 1, this would equate to 46,000 new homes, which is very similar to that advocated in the adopted Core Strategy bearing in mind the proposed New Local Plan will plan for a longer period of time.

There is no credible evidence available to suggest this level of development cannot be adequately planned for and met in a sustainable manner within the City Region.

Object

Representation ID: 10938

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We object to these policies on the following basis:
- there is justification to plan up to 2040 rather than 2038 and this should be noted in Policy SP2;
- the Policies should make reference to ‘Growth Areas’ as presented in the adopted Core Strategy where additional/extra planned growth for housing can take place;
- We consider Queensbury should be retained as a Growth Area, as provided in the adopted Core Strategy. It is capable of accommodating more homes than currently planned for and could achieve 1,000 homes as per the adopted Core Strategy. Again, this is not tested in the SA as a reasonable alternative;

Object

Representation ID: 10939

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We object to these policies on the following basis:
- there is justification to plan up to 2040 rather than 2038 and this should be noted in Policy SP2;
- the Policies should make reference to ‘Growth Areas’ as presented in the adopted Core Strategy where additional/extra planned growth for housing can take place;
- We consider Queensbury should be retained as a Growth Area, as provided in the adopted Core Strategy. It is capable of accommodating more homes than currently planned for and could achieve 1,000 homes as per the adopted Core Strategy. Again, this is not tested in the SA as a reasonable alternative;

Object

Representation ID: 10942

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

Part 3 of this policy should refer to Green Belt release around the Regional Centre, Principal Towns and Local Growth Centres in particular as this is clearly where the majority of housing need is going to be derived from.

Object

Representation ID: 10943

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We support the Council’s position that exceptional circumstances exist to release land from the Green Belt. However, we object to part B of the policy in that it does not identify land at Queensbury Golf Course for development.

We recognise that this is because the site has not previously been put forwards as a suitable and available site for redevelopment - we can confirm that the site is fully available, suitable and deliverable and should therefore be fully considered in the Council’s evidence base and SA going forward with the view to allocate the site for housing development in the regulation 19 Plan.

To not do so would represent a major departure from the adopted Spatial Strategy for the area where Queensbury was allotted a target of 1,000 homes. Departing from this is not currently justified.

The Council has not sought to identify safeguarded land - this is contrary to NPPF para 139.

Support

Representation ID: 10944

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We actively support the proposed allocations at QB4/H and QB5/H which are located to the north and west of the golf course site. Both have been assessed by the Council as being sustainable and accessible sites and therefore the same must be concluded in relation to the golf course site we are proposing too. Indeed, it is within a short walk from the centre of Queensbury and its associated services.

Support

Representation ID: 10945

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We actively support the proposed allocations at QB4/H and QB5/H which are located to the north and west of the golf course site. Both have been assessed by the Council as being sustainable and accessible sites and therefore the same must be concluded in relation to the golf course we are proposing too. Indeed, it is within a short walk from the centre of Queensbury and its associated services.

Object

Representation ID: 10949

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We very much support part A1 of Policy SP6 and the specific reference in Part C1 to support the delivery of at least 1,600 jobs per annum up to 2038.

However specific reference to housing development and its ability to significantly contribute to the local economy is not featured in this policy or the supporting text to Policy SP6. Housing development would assist in helping the local community that new housing development does not just bring new houses. It brings new jobs directly through the planning, design and construction process and also thereafter through increased household expenditure and taxation jobs, affordable housing and other opportunities.

As such, it would be helpful if Policy SP6 cited a direct relationship between economic growth and housing growth, either in the policy itself or failing that, at least within the supporting text.

Comment

Representation ID: 10950

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We suggest that it would be helpful if this policy cross referred to the spatial strategy and settlement hierarchy policies in terms of confirming where development will be targeted to reduce model travel dependency on the private car. In short, this will mean locating the majority of development towards the Regional Centre, Principal Towns and Local Growth Centres, including Queensbury.