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

Object

Representation ID: 11012

Received: 17/03/2021

Respondent: The Strategic Land Group

Agent: Walsingham Planning

Housing Need and Requirement

The Local Plan should include a minimum annual local housing requirement of 2,300 dwellings per annum, instead of 1,704 per year, to take into account the requirements of the NPPF and PPG to apply a 35% cities and urban centres uplift in the Top 20 cities/urban centres. The uplift cannot be excluded, discounted or removed and must form one of the defined stages of the standard method. It should be met across the District’s various settlements/areas and by appropriate levels of Green Belt release to enable the minimum need figure to be met/exceeded.
The Core Strategy (2017) includes a higher requirement of 2,476 dwellings, showing that an increase requirement can be accommodated.

There is a need for additional sites, including the release of Green Belt land as well as brownfield/underutilised land. Land at Haworth Road, Sandy Lane (SHLAA Ref: NW/020) is proposed to assist in meeting this requirement.

Object

Representation ID: 11015

Received: 17/03/2021

Respondent: The Strategic Land Group

Agent: Walsingham Planning

The Council should define the areas for proposed Green Belt release required to enable the revised minimum annual local housing need figure of 2,300 new homes/year to be met/exceeded.

The adopted Core Strategy outlines that around 11,000 homes are required to be delivered within the Green Belt to meet the minimum housing requirement outlined in that document. Adopting a minimum annual local housing need figure of 2,300 new homes/year for the new proposed plan period will require a similar scale of Green Belt release.

Within such a context, Site Reference NW/020 – Haworth Road, Sandy Lane should evidently form one of the allocated Green Belt release sites for housing.

Safeguarded Land - In any document proposing allocations or Green Belt release locations should also include indications of proposed Safeguarded Land to meet future needs, or to provide flexibility should any of the allocated sites provide undeliverable during the plan period.

Object

Representation ID: 11025

Received: 17/03/2021

Respondent: The Strategic Land Group

Agent: Walsingham Planning

Core Strategy (CS) Policy EC2 confirms that the Council will support the delivery of at least 1,600 new jobs annually up to 2030, a target maintained in the Draft Local Plan. The CS evidence base makes clear, to achieve that target requires the delivery of 2,476 new homes per year, in excess of the proposed Draft Local Plan target.

To ensure that the Council’s economic aims can be achieved, it is essential that a housing strategy is put in place that seeks to deliver minimum annual local housing need figure f, derived from the correct and complete adoption of the standard method - a minimum of 2,300 dwellings per annum for the plan period.

Delivery of sufficient housing is fundamentally key to the Council’s ability to meet its economic target. As such, it is essential that a higher scale of housing delivery is proposed via the Draft Local Plan Strategy.

Comment

Representation ID: 11026

Received: 17/03/2021

Respondent: The Strategic Land Group

Agent: Walsingham Planning

The Strategic Land Group support the objectives and proposed outcomes of each of these Policies; the delivery of appropriate employment land, sites, zones, job creation and skill delivery are essential for the District’s future prosperity.

However, without the delivery of sufficient housing opportunities to support these initiatives, key elements of the District’s existing and future workforce will be lost and their skills and ambitions will be utilised in other localities.

The Draft Local Plan proposes the same annual scale of annual job creation as the adopted Core Strategy but contains a housing delivery target that is over 30% lower. For the proposed scale of job creation to be delivered and the strategic sites and enterprise and other zones to be developed and occupied the Draft Local Plan housing delivery target must be increased, as a minimum to reflect the figure derived from the standard method.

Comment

Representation ID: 11027

Received: 17/03/2021

Respondent: The Strategic Land Group

Agent: Walsingham Planning

The Strategic Land Group support the objectives and proposed outcomes of each of these Policies; the delivery of appropriate employment land, sites, zones, job creation and skill delivery are essential for the District’s future prosperity.

However, without the delivery of sufficient housing opportunities to support these initiatives, key elements of the District’s existing and future workforce will be lost and their skills and ambitions will be utilised in other localities.

The Draft Local Plan proposes the same annual scale of annual job creation as the adopted Core Strategy but contains a housing delivery target that is over 30% lower. For the proposed scale of job creation to be delivered and the strategic sites and enterprise and other zones to be developed and occupied the Draft Local Plan housing delivery target must be increased, as a minimum to reflect the figure derived from the standard method.

Comment

Representation ID: 11028

Received: 17/03/2021

Respondent: The Strategic Land Group

Agent: Walsingham Planning

The Strategic Land Group support the objectives and proposed outcomes of each of these Policies; the delivery of appropriate employment land, sites, zones, job creation and skill delivery are essential for the District’s future prosperity.

However, without the delivery of sufficient housing opportunities to support these initiatives, key elements of the District’s existing and future workforce will be lost and their skills and ambitions will be utilised in other localities.

The Draft Local Plan proposes the same annual scale of annual job creation as the adopted Core Strategy but contains a housing delivery target that is over 30% lower. For the proposed scale of job creation to be delivered and the strategic sites and enterprise and other zones to be developed and occupied the Draft Local Plan housing delivery target must be increased, as a minimum to reflect the figure derived from the standard method.

Object

Representation ID: 11029

Received: 17/03/2021

Respondent: The Strategic Land Group

Agent: Walsingham Planning

The NPPF contains no directions that phasing policies should be contained within Local Plans.

Bradford has suffered from a long-standing undersupply of housing delivery for a sustained period. Its current deliverable supply housing sites is noted to be just 2.06 years, within the Council’s own evidence base.

The Council’s approach of delaying the delivery of the accepted, evidenced and adopted Core Strategy housing numbers by unnecessarily proposing the adoption of alternative housing numbers has further slowed and frustrated the much-needed delivery of new housing in the District.

In this regard, a proposed policy seeking the phasing of housing delivery within the plan-period is considered wholly unnecessary.

Object

Representation ID: 11035

Received: 17/03/2021

Respondent: The Strategic Land Group

Agent: Walsingham Planning

It is considered that site reference NW/020: Land at Haworth Road, Sandy Lane represents a suitable, sustainable and deliverable location to meet some of the District's existing and future urgent housing need.

If the minimum housing delivery number contained within the Local Plan is correctly reflected as being that derived using the standard method (a minimum of 2,300 dwellings per anum), it is expected the site to be upgraded to forming a proposed allocation.

Releasing this site from the Green Belt and allocating it for housing will deliver various far-reaching benefits, whilst creating limited adverse impacts.

Analysis shows that the it scores favourably to site NW/015 and should form one of the Preferred Options for Green Belt release and housing allocation.

Support

Representation ID: 30143

Received: 17/03/2021

Respondent: The Strategic Land Group

Agent: Walsingham Planning

Noting the plan period for the adopted Core Strategy ends in 2030, taking forward a new plan – inclusive of a plan period running to 2038 – is a pragmatic and logical approach, which my client welcomes and supports.

Object

Representation ID: 30144

Received: 17/03/2021

Respondent: The Strategic Land Group

Agent: Walsingham Planning

Paragraph 64 of the NPPF confirms that:

Where major development involving the provision of housing is proposed, planning policies and decisions should expect at least 10% of the homes to be available for affordable home ownership , unless this would exceed the level of affordable housing required in the area, or significantly prejudice the ability to meet the identified affordable housing needs of specific groups.

The above text does not direct that alternative targets should be proposed for greenfield and brownfield land, as such, a single figure should be proposed for each of the suggested areas, so for Zones 3 and 4, a single figure of 10% should be adopted.

Noting that the delivery of Bradford’s housing targets, particularly the adopted Core Strategy figure, requires extensive greenfield and Green Belt development to ensure its achievement, additional barriers, such as an increased affordable housing target, should not be imposed to reduce or potentially prevent the chances of this essential housing being expediently delivered within the new Local Plan.