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

Object

Representation ID: 17167

Received: 24/03/2021

Respondent: Jones Homes (Yorkshire) Limited

Agent: Savills (UK) Ltd

The plan period proposed for the Draft Local Plan runs from 2020 to 2038, a period of 17 years as stated
within the draft Local Plan.

The draft however also states that the Core Strategy runs for a 17 year period from 2013 – 2030, and at paragraph 2.10.7 of the draft Local Plan that 2021-2038 is a 17 year period.

Clarity is therefore required on whether the plan period is calculated in line with the Core Strategy (i.e. 18 years for the period 2020 - 2038), or intentionally differently at 17 years. For reference we therefore calculate that the plan is over an 18 year period, which accords with the average dwellings per annum figure set out at Draft Policy SP8.

Recommendation 1: Clarity needs to be provided on how the 2020-2038 period is calculated as a 17 year
period, when the Core Strategy and Draft Local Plan take different approach elsewhere.

Comment

Representation ID: 17168

Received: 24/03/2021

Respondent: Jones Homes (Yorkshire) Limited

Agent: Savills (UK) Ltd

We support the broad principles of Policy SP2 as drafted, and the role of Cottingley as a Local Service Centre.

We however have significant concern over the draft Local Plan’s soundness in reference to the identified need to “meet the needs of the district. It is not considered that significant deviation from the Standard Methodology is likely to result in a Local Plan which will identify and allocate sufficient land to meet local need.

We do not propose amendments to Draft Policy SP2, however have made recommendation in relation to the local housing need and other policies below, to ensure their compliance with the Spatial Priorities.

Comment

Representation ID: 17169

Received: 24/03/2021

Respondent: Jones Homes (Yorkshire) Limited

Agent: Savills (UK) Ltd

Policy SP3 designates Bingley as a Principal Town and Cottingley as a Local Service Centre. We agree that these are the most appropriate hierarchy positions for the two urban areas.

In line with our comments on draft Policy SP2, we do not consider that the current single housing allocation within Cottingley for 155 dwellings will provide protection of character, or a balanced growth strategy.

Recommendation 4: notwithstanding our recommendations set out below on the quantum of housing delivery within Cottingley, the overall housing delivery on greenfield sites within Local Service Centres should not be delivered through a single allocation which would be disproportionate in scale to the existing urban area. Multiple smaller allocations should instead be progressed in line with the Government’s objectives set out within the Housing White Paper to enable SME Housebuilders to increase delivery and to ensure development is locally distinctive, with a wider range of house types and tenure, and likely to be delivered as multiple outlets, therefore delivering homes across the plan period.

Comment

Representation ID: 17170

Received: 24/03/2021

Respondent: Jones Homes (Yorkshire) Limited

Agent: Savills (UK) Ltd

We broadly agree with the approach centred on brownfield first but which also includes greenfield and green belt land
with strong transport accessibility once deliverable and viable brownfield sites have been identified.

The Shipley Golf Course site at Cottingley is considered to be sustainable in terms of access as set out within the Accessibility Appraisal included at Appendix B, and is therefore an appropriate location for development, as per the aims of policy SP4.

Recommendation 5: In order to deliver the approach set out within Policy SP4 in a plan-led way, the overall housing requirements for the Local Authority should be reviewed urgently to enable the LPA to identify and deliver a robust supply of housing land in accordance with the accessibility orientated approach identified. This will prevent an approach to future application determinations based predominantly on the presumption in favour of sustainable development.

Object

Representation ID: 17171

Received: 24/03/2021

Respondent: Jones Homes (Yorkshire) Limited

Agent: Savills (UK) Ltd

Recommendation 6: Policy SP5 on Green Belt is amended to allow for greater release of Green Belt land to meet the stated ‘acute and intense need for housing’ identified.

Recommendation 7: The land south of Shipley Golf Course, previously referenced within the 2015 SHLAA as CO/006 ‘Hazel Beck, Cottingley Bridge’ should be included within both Policy SP5 and the Proposals Map for release from the Green Belt, as a sustainable site with a very weak contribution to the existing Green Belt.

An assessment of the site against the 5 green belt purposes is provided.

Object

Representation ID: 17172

Received: 24/03/2021

Respondent: Jones Homes (Yorkshire) Limited

Agent: Savills (UK) Ltd

Housing Need and Requirement:

The Draft Local Plan sets out a requirement for 30,672 new homes, down from the 42,100 net homes targeted within the 2017 Core Strategy.

We do not consider that the total set out within the draft is appropriately ambitious, and should be increased to meet the requirements as set out by central Government within the Standard Methodology. When taking the 35% uplift into account, as the Government’s preferred approach for meeting national housing delivery targets, the plan should be delivering around 2,300 homes per annum, equating to 41,400 over the 18 years of the plan period.

It should also be noted that the Standard Method figure is a ‘floor’ rather than a ‘ceiling’ figure. The implications for restricting growth, under-delivery and engagement of the presumption in favour of sustainable development could therefore be significant if the Council does not at this stage identify land for a more aspirational housing delivery target.

Object

Representation ID: 17173

Received: 24/03/2021

Respondent: Jones Homes (Yorkshire) Limited

Agent: Savills (UK) Ltd

Housing Distribution - Cottingley

Based on the Core Strategy and the Standard Methodology, we do not consider that any aspiration below 41,400 (the Standard Methodology) homes is appropriate.

If the housing aspiration is raised to the required 41,400, and distributed in the same manner as the draft local plan (therefore with 37,351 on allocated sites), Local Service Centres would deliver 1,681 homes, with 187 in Cottingley.

Recommendation 8: The housing delivery target set out at Policy SP8 needs to be increased significantly to meet the requirements of the Standard Method.

Recommendation 10: That the specific housing site allocations as identified at Schedule 1 and Paragraph D2 of Policy SP8 should increase the housing allocation for Cottingley to at least 187, with at least 1,681 allocated across all Local Service Centres.

Comment

Representation ID: 17174

Received: 24/03/2021

Respondent: Jones Homes (Yorkshire) Limited

Agent: Savills (UK) Ltd

The policy as worded is broadly appropriate and should continue to allow for development and enhancement in any future draft of the policy.

The site south of Shipley Golf Course / Hazel Beck is allocated in part within the current Development Plan as a Local Wildlife Site and within the emerging Local Plan as Countryside and a Local Wildlife Site. With this in mind an Ecological Constraints Assessment has been undertaken for the site and adjacent land under the same ownership. The Ecological Assessment is included at Appendix D.

The survey identifies an area south of the site which could be used as an area for ecological improvement,
to offset any loss of habitat within the Local Wildlife Site.

Object

Representation ID: 17175

Received: 24/03/2021

Respondent: Jones Homes (Yorkshire) Limited

Agent: Savills (UK) Ltd

We do not consider that a single allocation for 155 homes is appropriate either in the context of delivering the total requirement for the District area, or in providing a mix of smaller development sites.

As such we recommend that:
Recommendation 11: The Local Area Strategy and Plan for Cottingley should include for at least two housing allocations on non-committed sites, to meet local need by enabling SME housebuilders to deliver additional homes, in the interests of a justified and effective plan.

Recommendation 12: The land at Hazel Beck / Shipley Golf Course should be allocated for residential
development to meet local need in the interests of a justified and effective plan.

Object

Representation ID: 17176

Received: 24/03/2021

Respondent: Jones Homes (Yorkshire) Limited

Agent: Savills (UK) Ltd

As set out within this representation and its appendices, the land at Hazel Beck would be a wholly appropriate site for sympathetic residential development with appropriate ecological mitigation possible.

The site specific Green Belt assessment for the proposed allocation at Marchcote Lane identifies that it
has a ‘moderate potential impact’ on the Green Belt whereas we identify the land at hazel Beck as having
only a very weak contribution to the purposed of the Green Belt as set out within national Policy, the land
at Hazel Beck is therefore sequentially preferable in terms of Green Belt impact.

Recommendation 13: The Housing allocation at CO1/H should be included as part of the housing delivery
strategy for Cottingley however in order to meet the needs of the District it is essential that additional sites
are allocated in the local vicinity. We strongly recommend the allocation of the land at Hazel Beck (CO/006) as an appropriate and deliverable site for residential development.