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

Object

Representation ID: 3381

Received: 22/03/2021

Respondent: IMCO Holdings

Agent: Tetra Tech (Manchester)

As one of six Local Growth Centres in the district, the Local Plan should be seeking a more ambitious housing delivery target. The approach to utilise sites on the edge of the settlement which would have the least impact upon the purposes of the Green Belt and sensitive landscape features should be adopted.

Account should be taken of the very few existing residential planning commitments currently in Queensbury (19 units), which represents just 4% of the housing delivery target for plan period. The lack of existing commitments should be reflected in the Council’s delivery strategy. A 10% buffer to the housing delivery target to account for non-implementation or under delivery is not realistic. A 20% buffer would be more realistic.

Support

Representation ID: 3382

Received: 22/03/2021

Respondent: IMCO Holdings

Agent: Tetra Tech (Manchester)

On behalf of the landowner, support is provided for the allocation of site QB4/H – Brighouse Road.

We are supportive of the approach to plan for Green Belt release and the allocation of sites within Policy SP5. Without significant Green Belt release distributed across the District’s hierarchy of centres it is evident that the District’s future housing needs will not be met.

Support

Representation ID: 3383

Received: 22/03/2021

Respondent: IMCO Holdings

Agent: Tetra Tech (Manchester)

On behalf of the landowner, the allocation of this site is welcomed.

The site is considered to be developable within 3-5 years. Baseline surveys and feasibility work undertaken have established the deliverability of the site. There are no fundamental physical constraints for the delivery of the site, with a formalised direct access now in situ.

We agree that the site currently makes a low contribution to the purposes of including land within the Green Belt. Development of the site would enable a far stronger, more defendable and permanent Green Belt boundary to be defined.

The site should more appropriately be identified as exhibiting ‘low’ potential for urban sprawl. It is well contained by surrounding existing development on all sides. The golf course provides a strong prevention to future sprawl south into the Green Belt.

Object

Representation ID: 3384

Received: 22/03/2021

Respondent: IMCO Holdings

Agent: Tetra Tech (Manchester)

We are not in support of Part E of this policy and would advocate for its deletion from the plan. There is no requirement in the NPPF to control housing land release through a phased process over the plan period. This approach would compromise and stifle the otherwise sustainable development of sites, unnecessarily so in the District’s outlying established Principle Towns and Local Growth Centres.

The phasing of housing land release would provide no benefits outside of the city centre, where settlements are not reliant on the strategic phasing of sites for infrastructure or regeneration purposes. Delaying the release of housing land would compromise rather than support the successfully delivery of meeting the District’s housing need requirements.

If a phased approach is taken forward, this should be carefully limited to strategically important sites where there are justified reasons at a site specific level for a phased approach.

Support

Representation ID: 3385

Received: 22/03/2021

Respondent: IMCO Holdings

Agent: Tetra Tech (Manchester)

We support the hierarchy of centres outlined. We also support establishing within Policy SP3 that the Local Growth Centres should make a significant contribution to meeting the District’s housing needs.

Object

Representation ID: 3386

Received: 22/03/2021

Respondent: IMCO Holdings

Agent: Tetra Tech (Manchester)

Housing Need and Requirement

Policy Parts A and B - The housing requirement target of 30,672 does not appropriately adopt the Government’s required 35% “cites and urban centres” uplift and its application for the District. The housing strategy is not suitably ambitious to address the District’s housing requirements in this regard and is a significant backwards step from the adopted Core Strategy. Further Green Belt release should appropriately be planned for through a greater dispersion of the housing need across the settlement hierarchy.

• It is our view that the overall housing requirement target of 30,672 for the District is not sufficiently ambitious and that the Plan should seek to meet the Government’s 35% “cities and urban centres” uplift within its housing targets.

Support

Representation ID: 3387

Received: 22/03/2021

Respondent: IMCO Holdings

Agent: Tetra Tech (Manchester)

QB4/H Brighouse Road – On behalf of the landowner, the allocation of the site for 40 dwellings is welcomed and supported. An allocation for 40 dwellings is commensurable with the landowner’s aspirations for the site.

Support

Representation ID: 25115

Received: 23/03/2021

Respondent: IMCO Holdings

Agent: Tetra Tech (Manchester)

• On behalf of the landowner of the site, the inclusion of site QB4/H Brighouse Road, Queensbury, as a preferred allocation for housing is welcomed.

Object

Representation ID: 25116

Received: 23/03/2021

Respondent: IMCO Holdings

Agent: Tetra Tech (Manchester)

Housing Distribution - Queensbury

Policy Part E - Further housing growth should be planned for in the Local Growth Centres. For Queensbury, the housing requirement of 450 dwellings should be increased to be more ambitious for this Local Growth Centre. A standard 10% buffer to the housing delivery targets for each settlement to account for non-implementation or under delivery is not realistic. A 20% buffer would be more realistic

• Utilisting a standard 10% buffer to the housing delivery targets for each settlement to account for non-implementation or under delivery is not realistic. A 20% buffer would be more realistic to reflect the reality of site delivery within the plan period.

Comment

Representation ID: 25117

Received: 23/03/2021

Respondent: IMCO Holdings

Agent: Tetra Tech (Manchester)

• The approach for Green Belt release is supported. However, to provide a more ambitious housing delivery target, the allocations process could be extended further across the Principle and Local Growth Centre settlements. Further Green Belt release within Queensbury is feasible to sustainably accommodate future growth, without undermining the local and strategic functioning of the Green Belt.