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

Object

Representation ID: 5075

Received: 24/03/2021

Respondent: Barratt Homes and David Wilson Homes Yorkshire West

Agent: Sheppard Planning

Barratt object to the omission of land at High Fernley Road, Wyke from the Plan and the failure to allocate it for housing development with a potential yield of around 140 homes.

We consider that its lack of inclusion is not sound and that the rationale and evidence behind this decision is flawed. We therefore ask that it be allocated for housing in the next draft of the Plan.

Support

Representation ID: 5087

Received: 24/03/2021

Respondent: Barratt Homes and David Wilson Homes Yorkshire West

Agent: Sheppard Planning

This representation supports the allocation of land at Fleet Lane, Queensbury (Ref QB7/H)

A slight density increase to 30dph could deliver some 330 homes, and increase the amount of affordable housing delivered, which would assist the Council with moving closer towards meeting the “urban uplift” element of the “Standard Method”, which is a basic and now integral part of the methodology that is not currently being provided for in the Plan.

(Additional statement provided)

Object

Representation ID: 5148

Received: 24/03/2021

Respondent: Barratt Homes and David Wilson Homes Yorkshire West

Agent: Sheppard Planning

Please see attached statement.

Barratt Homes and David Wilson Homes
Yorkshire West (Barratt) objects to the omissions of land at Thornton Road and Green Lane, Thornton (Site TH/007) from the Preferred Options Draft Plan.

We consider that this is a sensible Green Belt release for Thornton, which can deliver much needed housing in the settlement and support the continued health of its existing services.

The site does not perform Green Belt functions and is accessible to a wide range of services and facilities. It has no environmental constraints and could deliver around 75 homes including 2 affordable homes (15% in line with draft policy H05) in the Plan Period.

Object

Representation ID: 5152

Received: 24/03/2021

Respondent: Barratt Homes and David Wilson Homes Yorkshire West

Agent: Sheppard Planning

Please see attached statement.

Barratt Homes and David Wilson Homes
Yorkshire West (Barratt) objects to the omission of site WI/001 - land at Harden Lane, Bents Lane, Wilsden from the Preferred Options Draft Plan.

The site does not perform Green Belt functions and is accessible to a wide range of services and facilities. It has no environmental constraints and could deliver around 120 homes including 30 affordable homes (25% in line with draft policy H05) in the Plan Period.

Object

Representation ID: 10326

Received: 24/03/2021

Respondent: Barratt Homes and David Wilson Homes Yorkshire West

Agent: Sheppard Planning

Housing Need and Requirement.

Barratt consider that the Plan does not currently allocate enough land for housing.

We consider that the Plan should allow for the 35% Cities and Urban Areas uplift which forms part of the standard method. The draft Plan offers very little explanation, and no evidence, on why the 35% uplift is not deliverable or justified.

Options are presented to illustrate how the uplift and additional 10,000 dwellings can be met and in which areas and settlements.

Object

Representation ID: 10327

Received: 24/03/2021

Respondent: Barratt Homes and David Wilson Homes Yorkshire West

Agent: Sheppard Planning

Housing Distribution:

Alternative distribution scenarios are presented which would incorporate the 35% uplift - the option favoured is one which keeps the City Centre figure at 7,000 but makes significant increases in Bradford SE and smaller increases elsewhere reflecting the availability of additional sites so far rejected, environmental constraints, and green belt areas which are considered to be strategically less important.

Comment

Representation ID: 10328

Received: 24/03/2021

Respondent: Barratt Homes and David Wilson Homes Yorkshire West

Agent: Sheppard Planning

Green Belt.

We generally support the content of Draft Policy SP5, including the removal of site QB7/H.

However, we are concerned about this policy on two grounds:
1) The Plan does not identify enough land to meet OAN, as it does not provide for the 35% uplift as noted elsewhere in this representation. Therefore, it does not remove enough land from the Green Belt to provide for the needs of the current Plan Period.

2) The Plan does not provide for Safeguarded Land, as such it does to provide for longer term development needs, beyond the current Plan Period.

Comment

Representation ID: 10330

Received: 24/03/2021

Respondent: Barratt Homes and David Wilson Homes Yorkshire West

Agent: Sheppard Planning

Policy H04: Housing Mix

Barratt are keen to ensure that the Plan retains flexibility about the mix of housing provided on both allocated and any windfall sites. This is required by NPPF 11a) which suggests that the Plan should be sufficiently flexible to adapt to rapid change.

Part B of the Policy offers guidance on what the Council will find acceptable and signposts key documents that will be referred to, which is helpful. However, Part C suggests setting additional guidance which, in practice, may end up being used in an inflexible way during planning applications, when local circumstances, and changing customer and market needs may require some deviation from the more prescriptive guidance likely to be provided.

It is suggested that the policy notes that any such guidance will be applied in a flexible manner taking into account up to date evidence, or justification for any deviation, provided by applicants.

Comment

Representation ID: 10332

Received: 24/03/2021

Respondent: Barratt Homes and David Wilson Homes Yorkshire West

Agent: Sheppard Planning

H05: Affordable Housing

Barratt are concerned that Part E of the policy is too prescriptive about the acceptable tenure mix. As noted above Para 11a) of NPPF seeks flexibility in policies and the Plan period is 18 years, over which time the needs of the population in Bradford are likely to change.

It is suggested that Part E is amended to remove the “starting point” for negotiations in favour of a reference to the then current SHMA. This approach would better accord with national policy and allow for suitable updates to the basic guidance that informs applications during the Plan Period.

This would also recognise Governments drive to increase home ownership and, as a more flexible policy approach, would not exclude the high proportion of affordable rental properties should this be needed and justified in the area.

Comment

Representation ID: 10333

Received: 24/03/2021

Respondent: Barratt Homes and David Wilson Homes Yorkshire West

Agent: Sheppard Planning

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.