Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
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Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Consultation Question 31
Representation ID: 17655
Received: 23/03/2021
Respondent: Barratt Homes and David Wilson Homes
Agent: ID Planning
The policy supports the delivery of high quality higher density schemes in urban locations and on sites close to public transport facilities. The policy recognises the sustainability of sites located near to transport services.
We support the policy in the context of site ST/1H at Steeton which has good access to Steeton and Silsden Railway Station and access to high frequency bus routes.
Support
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Consultation Question 32
Representation ID: 17656
Received: 23/03/2021
Respondent: Barratt Homes and David Wilson Homes
Agent: ID Planning
Support subject to amendment.
Part C of the Policy stats that specific guidance on housing mix on an area or site basis will be set out as necessary in site allocation proformas and neighbourhood Plans. This approach results in uncertainty for developers and contradicts with part B of the policy which provides flexibility on mix, supported by evidence.
Required Change
Part C of the Policy should provide clarity that any guidance on housing mix will support a flexible approach towards housing as outlined in Part B of the policy.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Consultation Question 33
Representation ID: 17657
Received: 23/03/2021
Respondent: Barratt Homes and David Wilson Homes
Agent: ID Planning
Part E of Policy HO5 sets out the tenure mix which will be starting point for all affordable housing negotiations (65% affordable housing for rent and 35% affordable home ownership and at least 10% available for home ownership in line with national policy). This mix is based on the recommendations set out in the SHMA.
The government has announced measures to increase home ownership by investing in new shared ownership mode. The new model will provide about half of the new homes for affordable home ownership and the reminder for discounted rent.
Whilst we note the policy states the proposed mix is the starting point for negotiations, it is considered the proposed mix too prescriptive, particularly having regard to government drive to increase home ownership.
Required Change
The bullet points in part E of Policy HO5 should be removed so that tenure mixes are considered on a site by site basis having regard to the SHMA or other up to date verifiable evidence.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Consultation Question 37
Representation ID: 17658
Received: 23/03/2021
Respondent: Barratt Homes and David Wilson Homes
Agent: ID Planning
Part C requires all new homes (over 10 dwellings) to be built to accessible standards and 5% of new homes built to M4(3) standards. We generally support the provision of such technical standards however, further evidence is required to justify the requirement as detailed in the policy.
There is no evidence to support the proposed threshold of 10 dwellings or 5% in relation to wheelchair user standards. Further information and evidence is required to justify these requirements.
There are specific costs associated with meeting these needs which could have viability implications for the delivery of housing. Paragraph 4.22.8 explains that the standards have been assessed as part of the whole plan viability and that site circumstances will be considered if the standards are not viability. The viability of meeting the requirements should be mentioned in the policy.
Part E of the policy refers to Nationally Described Space Standards being implemented. Further evidence from the Council is necessary justify the need for internal space standards. Government guidance is clear that there needs to be robust and credible evidence on both need and viability to warrant the introduction of a policy requiring all new homes to meet NDSS.
Required Change
The policy wording should be amended to provide flexibility and viability for future development.
Comment
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Consultation Question 114
Representation ID: 17659
Received: 23/03/2021
Respondent: Barratt Homes and David Wilson Homes
Agent: ID Planning
Whilst we support the Council’s strategy that the majority of housing should be distributed to the Regional City, the distribution of 73% of the LHN requirement to this area is too high and negatively impacts on the distribution to the wider district and other settlements. The proposed distribution to the Regional City and in particular the Bradford City Centre and Shipley and Canal Road Corridor areas is unrealistic given there are significant challenges in terms of deliverability and viability. The quantum of housing proposed would require a significant step change in housing delivery in these areas. To rely on the quantum of housing coming forward as proposed by the preferred option distribution presents a high risk that the plan will not deliver the housing requirement and also impact on the Council’s ability to demonstrate a 5 year housing land supply. The proposed delivery in the city and urban area should be achieved by the application of the 35% uplift which would provide the growth in these areas without detracting from sustainable growth of the wider district.
Required Change
Whilst the Regional City should be the main focus for housing delivery in the absence of the 35% uplift being applied the quantum of housing should be reduced to a more realistic level (60%) and additional houses distributed to Principal Towns and Local Growth Centres such as Steeton where there are not the deliverability constraints and where the delivery of additional houses in these settlements is realistic. This approach will ensure the housing requirement and the plan is deliverable.
Overall, however, we object to the 35% uplift being excluded as this would provide the preferred growth strategy for the urban areas whilst also ensure and maintain a balanced distribution of housing growth to meet identified needs in the wider district and sustainable settlements.
Support
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Consultation Question 115
Representation ID: 17666
Received: 23/03/2021
Respondent: Barratt Homes and David Wilson Homes
Agent: ID Planning
We support the proposed allocation of site ST1/H for residential development. As demonstrated by the Site Assessments we consider that that positive conclusion attributed to the preferred allocation (ST1/H) area extends to the wider site area available (reference ST/001) and the allocation should be amended to include the wider/ larger site referred to as ST/001 to deliver new housing and positive effects for residents in a sustainable extension to the Steeton with Eastburn Growth Centre.
The wider reference ST/001 scores equally in terms of the Green Belt Assessment and against the Sustainability Objectives. We consider the wider allocation provides the potential for the delivery of additional new housing in this sustainable location.
Object
Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021
Consultation Question 9
Representation ID: 30060
Received: 23/03/2021
Respondent: Barratt Homes and David Wilson Homes
Agent: ID Planning
Housing Distribution - City Centre / Steeton
• Object to the proposed distribution which puts too much reliance on the City Centre, particularly in the absence of the 35% uplift. The distribution should be more closely aligned to the baseline distribution for the sub areas with additional uplift in the city centre and urban areas via the 35% uplift.
• The proposed distribution to Steeton should be increased to more closely align with the baseline population.