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

Object

Representation ID: 16318

Received: 24/03/2021

Respondent: Newett Homes

Agent: Quod North

Newett Homes generally support the approach set out under Policy SP1. However, Part B (Supporting the Three Objectives of Sustainable Development) does not directly align with NPPF Paragraph 8.

For example, the economic objective is focused on supporting employment uses, whereas national policy more generally refers to supporting the economy, through development “of the right types… in the right places”.

Economic growth is dependent on residential (and other) development that, when planned for together (in mutually beneficial ways), deliver genuinely sustainable development and contribute to economic strength, responsiveness and competitiveness.

Policy SP1 should better align with the NPPF’s sustainable development objectives, or simply refer back to the NPPF, otherwise the DBLP will not be consistent with national policy and will be unsound (NPPF Paragraph 35(d)).

Support

Representation ID: 16319

Received: 24/03/2021

Respondent: Newett Homes

Agent: Quod North

Newett Homes support BCC’s commitment to supporting Local Service Centres (see Policy SP3 below) by providing for homes and local services. They are keen to work with BCC to achieve this and deliver sustainable development benefits through the delivery of their sites in Wilsden.

Object

Representation ID: 16329

Received: 24/03/2021

Respondent: Newett Homes

Agent: Quod North

Policy SP3’s approach to defining the settlement hierarchy and development needs is outdated. The approach taken within the RSS and adopted Core Strategy has failed to deliver against BCC's housing requirements.

A new updated settlement study which factors in capacity to accommodate growth should be produced to inform the hierarchy.

Account should be taken of the impacts of the COVID pandemic and its effects on the way people work, working from home etc. These changes disrupt the outdated notion of settlement hierarchies and the role of smaller settlements.

Wilsden is well located to Principal Towns and Bradford and should (alongside other nearby Local Service Centres) be allocated greater (yet proportionate) growth to achieve important sustainable development objectives and benefits going forwards.

Object

Representation ID: 16330

Received: 24/03/2021

Respondent: Newett Homes

Agent: Quod North

Policy SP4 closely reflects Policy SP3 in terms of purpose and future application (both set a hierarchy / sequential approach to allocating / delivering development).

This Policy should be incorporated into Policy SP3 and then supported by a separate policy covering spatial distribution of development requirements (e.g. housing and employment) and delivery trajectory for the plan period.

Object

Representation ID: 16336

Received: 24/03/2021

Respondent: Newett Homes

Agent: Quod North

Newett Homes agree that Exceptional Circumstances exist for the removal of Green Belt land to accommodate BCC’s housing and infrastructure needs.

However, BCC do not go far enough to sufficiently satisfy Paragraph 136 of the NPPF. The proposed approach (to not allocate sufficient homes to meet the Standard Method + 35% housing requirement) will not ensure the endurance of new Green Belt boundaries beyond the plan period and will make the DBLP’s provisions unsustainable.

Newett Homes are promoting two neighbouring sites in Wilsden, with one having been rejected as a potential allocation by Officers on grounds of landscape impact. This is despite having previously been demonstrated by Newett Homes as suitable for development and having a negligible impact on Green Belt objectives.

Exceptional Circumstances exist to release this (and similar sites) to ensure important development and infrastructure needs are met over the plan period and covered by a robust supply of land.

Object

Representation ID: 16341

Received: 24/03/2021

Respondent: Newett Homes

Agent: Quod North

Housing Requirement:

The Government have proposed a 35% increase above the current Standard Method- BCC will therefore be required to identify a minimum deliverable supply of land for 2,300 dpa.

BCC have not sufficiently evidenced how this uplifted housing requirement can be accommodated whilst addressing historic shortfall. This is necessary to ensure the DBLP meets the tests of soundness and also supportive of broader policy objectives (such as supporting economic growth and meeting social needs).

Without providing a detailed analysis of whether this is feasible, BCC propose a significant reduction of 772 dpa against the adopted CS requirement (2,476 dpa). This is in the context of a housing shortfall of 8,588 homes since 2013 and an under supply of homes (2.03 years).

In this context, it is inappropriate for BCC to propose this reduction before fully assessing delivery / infrastructure issues and impacts on historic deprivation, housing supply and affordability issues.

Newett Homes recommend that BCC take responsibility for addressing the significant previous shortfall.

Object

Representation ID: 16342

Received: 24/03/2021

Respondent: Newett Homes

Agent: Quod North

Housing Distribution - Wilsden

As set out in these Representations, BCC’s approach to spatial distribution is inappropriate and will prevent the delivery of sustainable development and its associated benefits over the plan period (2020-2038).

Building on its existing services and facilities, Wilsden (and other Local Service Centres) has capacity to be identified for greater, proportionate growth and grow sustainably.

In doing so, development, community and necessary infrastructure can be planned for and feasibly
delivered. This will allow development to provide and enhance community facilities, and for BCC to develop an efficient and viable sustainable transport network.

A greater level of growth will also provide greater opportunities for improved community and sustainable transport infrastructure within the Local Service Centres.

Object

Representation ID: 16343

Received: 24/03/2021

Respondent: Newett Homes

Agent: Quod North

Newett Homes generally support BCC’s strategy for Wilsden. However, for the reasons detailed above, Wilsden should be identified for greater, proportionate, growth (more than the proposed 125 dwellings over the plan period).

This will ensure that the DBLP strategy’s objectives and broader sustainability objectives can be achieved. Notably, in relation to sustaining and enhancing local services and facilities and retaining and growing local employment opportunities.

A greater level of growth will also provide greater opportunities for improved community and
sustainable transport infrastructure within the Local Service Centres.

Object

Representation ID: 16346

Received: 24/03/2021

Respondent: Newett Homes

Agent: Quod North

Newett Homes support BCC’s proposed residential allocation to the south of Crack Lane, Wilsden (Ref. WI2/H) (Figure 3.1). However, they disagree with elements of the Site Allocation Proforma and the Site’s SA assessment.

The Site is deliverable now and could reasonably come
forward for development in the first five years of the DBLP. The Policy’s suggested timescale of six to ten years should therefore be revised.

The proposed ‘Development Considerations’ included in the draft Policy requires off-site compensatory improvements to the surrounding Green Belt - this should be removed. This requirement would not satisfy NPPF tests (para 55 & 56).

A number of issues are raised with regards to the SA assessment of the site and modifications proposed.

Newlett Homes disagree with the Green belt Assessment and its conclusion that there will be moderate impact.

Object

Representation ID: 16347

Received: 24/03/2021

Respondent: Newett Homes

Agent: Quod North

Newett Homes object to the rejection of WI/003 (Land North of Crack Lane).

The Site’s appropriateness for development in Green Belt and landscape terms, as well as general suitability, availability and deliverability has been demonstrated previously and again in these Representations. The Site should be identified as a residential allocation in the DBLP.

It is rejected in the SLA due to potential landscape impacts, but this is without any detailed assessment or consideration of the Site (other than on its Green Belt impacts) that, as noted below, do not correspond with the previously submitted information .

Newett Homes disagree with the SLA’s unsubstantiated comments that are anticipated to be lined to the GBOP SSA’s assessment.

The Site has low potential impact on the Green Belt. The GBOP SSA should be amended to reflect this information and the Site should be allocated. SPD2 confirms that the Site is available, deliverable and viable for c. 15 dwellings.