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

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.

Support

Representation ID: 10954

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We welcome the Council’s commitment to deliver on climate change and environmental objectives through this policy. We reserve the right to comment further at later stages in the plan-making process.

Object

Representation ID: 10955

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We support the Council’s desire to create a Green and Blue Infrastructure Network. However, we object to specific reference within Policy SP10 to the plan provided at Appendix 14. This plan is too vague and at such a scale that it is difficult to pinpoint exactly what areas are to be protected or enhanced under this policy.

The policy states that all areas of designated open space will be protected as defined by Policy CO1 but this seemingly applies to private sporting venues, including Queensbury Golf Club.

The Council’s evidence on open space and sports pitches is contained in reports dated 2016, 2018 and 2019. None of the assessments make any reference to golf courses. As such, there is no evidence that has been prepared to confirm that the likes of Queensbury Golf course should be specifically protected.

Sport England do not seek to protect golf courses under the organisations statutory obligations.

Comment

Representation ID: 10957

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We do not take any particular issue with this policy and note that it largely reflects the position in the adopted Core Strategy, which promoted 1,000 new homes to be delivered in and around Queensbury and this was deemed acceptable in 2017.

Queensbury and its hinterlands fall within Zone C - land within 7km of the SPA/SAC boundaries where development of homes needs to consider the potential for new households to place recreational pressures on the SPA/SCA. We support the Policy wording that allows for on or off site mitigation to be provided & flexibility re the best type of mitigation to be offered.

Queensbury is surrounded by a network of public rights of way that provide immediate access to the open countryside. The development of the Queensbury Golf Course site will provide a large area of open space that would provide suitable mitigation on site and create links to existing PRoW networks in the vicinity see indicative site appraisal masterplan.

Object

Representation ID: 10958

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We note that the Council wish to allocate sites that meet walking distance thresholds to public transport stops and other key services as set out in Appendix 6 of the Draft Local Plan.

We consider the 800m / 10 minute walk time applied to local services should also be applied to bus stops that provide a regular service to town and city centre locations. Indeed, if someone is willing to walk 10 minutes to get to local shops and 20 minutes to a school, we think a 10 minute walk to a primary bus corridor is also a suitable distance.

Comment

Representation ID: 10959

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

The Queensbury Golf Course site is highly accessible and within a short walking distance to local shops, bus stops and other day to day services.

In due course a transport assessment and travel plan will be drawn up for the site. But it would be helpful if the Council could articulate what public transport plans are expected to be delivered within the area over the course of the plan period (even if this is just a summary of the Local Transport Plan or cross reference to it).

At this moment in time, we do not foresee an issue in providing the required amounts of parking in line with this policy at the Queensbury Golf course site when redeveloped for housing.

Comment

Representation ID: 10960

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We note that Queensbury is identified as a Local Centre in terms of the retail hierarchy, which we consider is fitting for the role and function of the retail core. However, the proposed boundary of the Local Centre should include the Tesco supermarket, which anchors the centre and the recent development of retail units to the south of the Tesco store. Both function as part of the centre and directly abut the current boundary.

Object

Representation ID: 10961

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

The Queensbury Golf Course site should be included within the policy as a strategic site - it fits the criteria either as a site of at least 150 units fundamental to the delivery of the settlement's housing target or as as a cluster along with allocations QB4/H and QB5/H (on the basis of an increase density of 35dph.

Support

Representation ID: 10962

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We support this policy and in particular the recognition that family housing and affordable housing will play an important part in providing for Bradford’s existing and future housing needs.