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

Object

Representation ID: 19942

Received: 24/03/2021

Respondent: Avant Homes

Agent: Tetra Tech (Leeds)

Housing Need and Requirement

The Government have introduced changes to the Standard Method for calculating housing requirements - it now requires a 35% uplift on housing numbers in the 20 largest cities and urban areas in England (of which Bradford is one).

The Council is failing to pursue this increased housing requirement.

Bradford has well documented evidence of the problems it has faced in terms of housing land supply, the 5 year housing land supply statement 2020-2025 details that over the period of 2013 – 2020 there has been a shortfall in the planned delivery of homes equalling 8,588 dwellings (a net figure of 9,069 dwellings).

We consider the Council has set a modest and unambitious target, to meet a minimum requirement but such an approach will only serve to compound delivery.

Overall, we consider the Local Plan is contrary the objectives of the NPPF para 59. “To support the Government’s objective of significantly boosting the supply of homes..... ”

We also suggest, as we did in the CSPR 2019, that the scale of need for affordable housing justifies an uplift to the overall housing requirement figure.

Object

Representation ID: 19943

Received: 24/03/2021

Respondent: Avant Homes

Agent: Tetra Tech (Leeds)

Housing Distribution - Bradford City Centre / Menston

We consider the Council has set a modest and unambitious target, to meet a minimum requirement but such an approach will only serve to compound delivery.

It is narrow in its focus, with too much reliance on the Regional City of Bradford whilst restricting provision in some of the outer areas including the more desirable higher market value areas. Not only will this serve to restrict a balanced approach to housing supply it will compromise the range and choice of housing stock that can be delivered to the detriment of local market needs in the outer areas.

We consider additional land should be released from the Green Belt having greater regard for the settlement hierarchy to deliver a wide choice of quality homes and maximise opportunities for delivery.

The reliance on delivery of a large proportion of homes in Regional City of Bradford (72%) and in particular Bradford City Centre, at the expense of delivery in the outer areas, will compromise the choice of quality homes and the mix of types, sizes, tenures across the District. The distribution as currently proposed will not provide a balanced supply to the district.

We consider therefore that changes are required to Policy SP8 to reflects Menston’s status as a sustainable location for new housing development.

Object

Representation ID: 20000

Received: 24/03/2021

Respondent: Avant Homes

Agent: Tetra Tech (Leeds)

The ability to deliver the objectives of Policy HO5 are reliant on an appropriate starting point for overall housing supply and spatial strategy. We consider the approach set out in Policy SP8 will compromise the ability to meet the objectives of Policy HO5.

The majority of the growth in the plan is proposed in the Regional City of Bradford (72%) where much of the city is expected to provide a maximum of 15% affordable housing, with this being 10% for development in Inner Bradford. It is therefore extremely unlikely that 441 affordable dwellings per annum will be delivered by policy HO5.

We therefore suggest, as we did in the CSPR 2019, that the scale of need for affordable housing justifies an uplift to the overall housing requirement figure.

the restriction of housing supply in the higher market value areas will compound the affordability gap. The situation can only be addressed through amendment to Policy SP8.

Object

Representation ID: 20001

Received: 24/03/2021

Respondent: Avant Homes

Agent: Tetra Tech (Leeds)

In relation to Avant Homes land interest at Menston (ME/013):

Menston has seen a significant drop in housing numbers since the original Core Strategy set out a target of 600 residential units. The compression of housing supply in Local Growth Centres such as Menston will continue to restrict choice, inflate the price of existing property and extend the affordability gap.

Menston is acknowledged as a sustainable settlement for housing growth with a good level of facilities. It also has excellent accessibility by public transport to other destinations in West Yorkshire.

The need to promote sustainable patterns of development is important, particularly in districts with a significant proportion of Green Belt, such as Bradford. It is considered that Menston provides the opportunity to release Green Belt land for development which is well-served by public transport in accordance with the NPPF.

We consider therefore that changes are required to Policy SP8 to reflects Menston’s status as a sustainable location for new housing development.

Object

Representation ID: 20002

Received: 24/03/2021

Respondent: Avant Homes

Agent: Tetra Tech (Leeds)

Advocates the allocations of site ME/013 for residential development.

Consider that the site is the Site to be suitable, available, deliverable and achievable and performs favorably when compared against preferred options. For example the preferred green belt option site ME1/H has no direct access, and is reliant on access from the development site to the east, which has a well-documented history and issues with delivery. ME1/H is outside the Core Strategy Accessibility Standards. However, site ME/013 can be safely accessed direct from Otley Road, and complies with the Core Strategy Accessibility Standards.

Site ME0/13, does not appear to be covered in the SA and Strategic Environmental Assessment which forms part of the Local Plan Evidence base.

We disagree with the green belt assessment of site ME/013. Our proposed re-scoring would suggest the overall rating is downgraded from Major to Moderate.

In the context of the comments above and our view that housing targets for Menston should be higher we continue to promote site ME/013 for allocation.

Object

Representation ID: 20003

Received: 24/03/2021

Respondent: Avant Homes

Agent: Tetra Tech (Leeds)

we agree with the Council’s contention under paragraph B of Policy SP5, with regard to exceptional circumstances.

However we do not consider the policy goes far enough and does not plan positively for a sufficient amount, and variety, of housing land to come forward where it is needed, to address the diverse market needs that exist across the district.

It is important that the development strategy is not overly reliant on brownfield sites. Policy SP5 as drafted leaves no headroom for shortfalls in delivery that may develop, particularly in some of the more central areas. Further allocations are required, and Policy SP5 should be amended to redress the concerns on undersupply and the balance of supply across the district in line with the sustainable settlement hierarchy. The Council need to be able to demonstrate that Green Belt boundaries will not need to be altered at the end of the plan period.

We consider that there is capacity for further housing to be accommodated on sustainable sites on the edge of Menston which are well served by public transport and do not compromise the purposes of Green Belt.