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

Object

Representation ID: 717

Received: 04/03/2021

Respondent: Clive Brook Planning

On behalf of my clients I object to the inclusion of section 5d in this policy which seeks to minimise the use of Green Belt land. This is not a justified and sustainable approach.

Object

Representation ID: 783

Received: 05/03/2021

Respondent: Clive Brook Planning

While various aspects of this policy are supported I and my clients have objections to certain sub policies, some of which can be overcome by extended/clarified policy statements and some which require changes across several related policies.

Support

Representation ID: 792

Received: 05/03/2021

Respondent: Clive Brook Planning

Policy SP3- Settlement Hierarchy is supported with some qualifications which highlight how other plan policies must be changed in order to deliver all the benefits sought for settlements as expressed in this policy.

Object

Representation ID: 793

Received: 05/03/2021

Respondent: Clive Brook Planning

POLICY SC4:- LOCATION OF DEVELOPMENT
The policy should on balance be deleted as it serves very little if any purpose. It is far from clear in the written justification why a system of sequential selection or prioritisation of sites for allocation is necessary. In certain settlements there are few if any previously developed sites likely to come forward except on an unpredictable 'windfall' basis. Given past high rates of development of brownfield it has to be recognised that the opportunities for the future identification of potential brownfield allocations is severely restricted in at least one of the three principal towns and in other settlements in the lower tiers of the hierarchy. Similarly the opportunities for developing greenfield sites are greatly restricted in all tiers of the hierarchy as a result of existing greenfield uses or designations or the need for these to become publicly accessible open spaces in the future.

Object

Representation ID: 923

Received: 07/03/2021

Respondent: Clive Brook Planning

We support the conclusion that there are exceptional circumstances which justify Green Belt releases for housing and employment land. We object to the lack of sufficient Green Belt release provision for the higher levels of need and demand for both housing and employment land as contained in the evidence and responses we put forward on other strategic and topic based policies as well as site specific submissions. We object to the exclusion of any provision for safeguarded land which is justified and required.
We object to a lack of a positive and proactive approach which recognises the considerable multiple benefits which can be achieved via enabling residential developments which are capable of delivering wholly sustainable developments to the benefit of existing and new communities.

Object

Representation ID: 993

Received: 08/03/2021

Respondent: Clive Brook Planning

This objection to the policy is based on the wholly inadequate proposals for job creation and employment land provision and their lack of alignment with the Council's own economic strategy and the much more positive approach being taken by a number of the West yorkshire planning authorities.

Support

Representation ID: 1047

Received: 09/03/2021

Respondent: Clive Brook Planning

We support the policy with a limited number of qualifications.

Support

Representation ID: 1071

Received: 09/03/2021

Respondent: Clive Brook Planning

On behalf of my client landowners and developers I support the selected plan period of 2020 to 2038 and the need for a minimum 15 year period from adoption. However, it has taken a considerable period of time to reach this Regulation 18 Consultation Draft composite plan containing proposed policies and site allocations. The anticipated period remaining to adoption in 2023 is too long and the Council must now do everything possible to speed up production of the plan, particularly as the current land supplies for housing and employment development fall a long way short of requirements and the aspirations of the Council. The sub 2.0 years of housing land supply against the required 5.0 years of deliverable housing supply (recently confirmed by the Inspector and the Secretary of State - planning appeal for 500 dwellings at Burley-in-Wharfedale) requires the earliest possible adoption of a full suite of residential allocations.

Object

Representation ID: 1954

Received: 17/03/2021

Respondent: Clive Brook Planning

Housing Need and Requirement

On behalf of my landowner and developer clients I object to policy SP8 :- These objections relate to :-
1.The considerable under-assessment of the District's housing need and the lack of any applied uplifts to the baseline minimum housing need figure of 1,704 dwellings/annum.
2. The determination of the housing requirement and its distribution throughout the settlements in the Bradford hierarchy.
3. Objections to the proportion of the housing requirement which will be required from the Green Belt to meet the objectively assessed needs of the District in the most sustainable way.

Support

Representation ID: 1958

Received: 17/03/2021

Respondent: Clive Brook Planning

While I support the great majority of the policy content on behalf of my clients I object to the fact that the Council are not supporting the delivery of highly sustainable Green Belt sites, which with enabling residential development can deliver major gains in the form of environmental enhancements and climate adaptation and mitigation measures. Many of the sites selected will be unable to deliver these major gains.