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

Object

Representation ID: 21657

Received: 24/03/2021

Respondent: Patchett Developments Ltd

Agent: Johnson Mowat

Housing Need and Requirement

Our clients have concerns with the Draft Plan’s strategic approach to the overall housing requirement and the Council’s chosen approach of dismissing the Government requirement of a 35% uplift to the housing requirement (Policy SP8).

It is considered at the very least, the 35% uplift as required by the Government should be applied to the overall housing requirement, resulting in an annual requirement of 2,300 dwellings per annum, rather than the Council’s preferred approach of 1,704 dwellings per annum.

The housing requirement of the District and the settlements including Cottingley, Bradford South West and Bradford North West should be seen as a minimum to demonstrate a commitment to significantly boosting housing delivery.

Typically, housebuilders will deliver 35 dph. It should be noted that the CO1/H measures 8.45 hectares. In this context CO1/H is capable of delivering approx. 295 dwellings and the therefore the introduction of a minimum figure will enable a housebuilder to potentially deliver additional units.

Once NW7/H is ‘Allocated’ our client will be looking to submit a planning application almost immediately. In this context the Delivery Timescales should be amended to 0 – 5 years.

Object

Representation ID: 21658

Received: 24/03/2021

Respondent: Patchett Developments Ltd

Agent: Johnson Mowat

Housing Distribution - Cottingley

The Draft Local Plan significantly increases the urban focus by directing more development to Bradford City Centre. The Preferred Option Draft Plan proposes 7,000 dwellings in the City Centre, a significant uplift from 3,500 in the Core Strategy, and 4,000 in the Draft Core Strategy Partial Review. The Council have therefore applied an urban focus uplift in terms of the distribution of development but without applying an uplift to the overall requirement.

This results in a whole shift away from the distribution identified in the adopted Core Strategy, with disproportionate reductions to the majority of sustainable settlements and sub areas in the District including Cottingley (Local Service Centre).

Whilst the increase from 0 dwellings (CSPR) to 150 dwellings in Policy SP8: Housing Growth is welcomed; it remains my client’s position that the overall requirement for the both Cottingley and the District as a whole should be significant higher.

Support

Representation ID: 21659

Received: 24/03/2021

Respondent: Patchett Developments Ltd

Agent: Johnson Mowat

Our clients supports the inclusion of Site C01/H. This site is capable of supporting relevant elements of the Local Area Strategy.

This site is deliverable. There are no known viability issues. There are no environmental constraints associated with the site that cannot be dealt with via
appropriate design.

The site will:
- Deliver of 155 (JM amends) market and affordable homes
- Support the vitality and viability of Cottingley Local Centre
- Protect and enhance existing open spaces and green areas
- Maintain the Green Belt gap between Cottingley, Shipley and Bradford

Comment

Representation ID: 21750

Received: 24/03/2021

Respondent: Patchett Developments Ltd

Number of people: 2

Agent: Johnson Mowat

Site is subject to a planning submission by Barratt Homes proposing 70 dwellings. This would take the total number of dwellings off the cul‐de‐sac to 144 dwellings without a secondary point of access or an emergency access.

Although acceptable for the proposed quantum, further residential development from this single point of access is not considered to be acceptable and contrary to the Leeds Street Design Guide and emerging Leeds Transportation SPD (assuming this is also to be retained as Bradford Highway’s guidance document in the future).

The proposed site layout meets its south western boundary in two locations - a private drive and secondly an adopted shared surface turning head.

Therefore, even if the issues above did not exist, there is no suitable connection to the boundary of this site that would facilitate access to any wider development sites bounding this site, as the internal roads would not meet the required standards of a larger development for either a Type 1 or 2 street, with any cul‐de‐sac also being significantly longer than that permitted.

Object

Representation ID: 21752

Received: 24/03/2021

Respondent: Patchett Developments Ltd

Number of people: 2

Agent: Johnson Mowat

CBMDC states the sites “can be accessed directly from Brook Lane or via Ferndale but Brook Lane is substandard on its approach to main road at Baldwin Lane which will need mitigating”.

However, concerns about the suitability of Brook Lane to deliver additional vehicles are longstanding. The 2004 RUDP Inspector concluded that access could only be achieved by constructing a new road from Baldwin Lane, on land at present within the Green Belt”

A highways technical appendix and assessment is supplied. This examines the significant issues relating to the width of highways and pedestrian walkways, pinch points along Brook Lane and visibility issues at the Baldwin Lane and Brook Lane junction.

CBMDC has suggested that a new road serving SW/3H, SW4/H and SW18/H could be created using land within SW22/H. We indicate that the land required to achieve this option and across which a road would have to cross i.e. the land following the railway tunnel is in the control of Charles Patchett who does not give consent for it to be used. The option and therefore the sites are therefore simply not deliverable.

Object

Representation ID: 21754

Received: 24/03/2021

Respondent: Patchett Developments Ltd

Number of people: 2

Agent: Johnson Mowat

CBMDC states the sites “can be accessed directly from Brook Lane or via Ferndale but Brook Lane is substandard on its approach to main road at Baldwin Lane which will need mitigating”.

However, concerns about the suitability of Brook Lane to deliver additional vehicles are longstanding. The 2004 RUDP Inspector concluded that access could only be achieved by constructing a new road from Baldwin Lane, on land at present within the Green Belt”

A highways technical appendix and assessment is supplied. This examines the significant issues relating to the width of highways and pedestrian walkways, pinch points along Brook Lane and visibility issues at the Baldwin Lane and Brook Lane junction.

CBMDC has suggested that a new road serving SW/3H, SW4/H and SW18/H could be created using land within SW22/H. We indicate that the land required to achieve this option and across which a road would have to cross i.e. the land following the railway tunnel is in the control of Charles Patchett who does not give consent for it to be used. The option and therefore the sites are therefore simply not deliverable.

Object

Representation ID: 21755

Received: 24/03/2021

Respondent: Patchett Developments Ltd

Number of people: 2

Agent: Johnson Mowat

CBMDC states the sites “can be accessed directly from Brook Lane or via Ferndale but Brook Lane is substandard on its approach to main road at Baldwin Lane which will need mitigating”.

However, concerns about the suitability of Brook Lane to deliver additional vehicles are longstanding. The 2004 RUDP Inspector concluded that access could only be achieved by constructing a new road from Baldwin Lane, on land at present within the Green Belt”

A highways technical appendix and assessment is supplied. This examines the significant issues relating to the width of highways and pedestrian walkways, pinch points along Brook Lane and visibility issues at the Baldwin Lane and Brook Lane junction.

CBMDC has suggested that a new road serving SW/3H, SW4/H and SW18/H could be created using land within SW22/H. We indicate that the land required to achieve this option and across which a road would have to cross i.e. the land following the railway tunnel is in the control of Charles Patchett who does not give consent for it to be used. The option and therefore the sites are therefore simply not deliverable.

Object

Representation ID: 21756

Received: 24/03/2021

Respondent: Patchett Developments Ltd

Number of people: 2

Agent: Johnson Mowat

The red line boundary for SW22/H includes land controlled by Charles Patchett (land following the alignment of the railway tunnel).

Our client does not provide approval / consent for this land to be used as part of allocation SW22/H. Approval / consent is also not given for the construction of an access road over this land during this local plan period. Accordingly, the red line boundary for SW22/H needs amending.

A highways technical appendix and assessment is supplied. This suggests that there are a number of issues relating to achieving a suitable access to this site given the limitations of the current extent of its frontage and the need to maintain a 30M offsetting / separation between the access point and from the current access to Frayaleigh Kennels and Cattery opposite the site and to the east of Baldwin Lane.

Object

Representation ID: 23637

Received: 24/03/2021

Respondent: Patchett Developments Ltd

Agent: Johnson Mowat

Housing Need and Requirement

Our clients have concerns with the Draft Plan’s strategic approach to the overall housing requirement and the Council’s chosen approach of dismissing the Government requirement of a 35% uplift to the housing requirement (Policy SP8).

It is considered at the very least, the 35% uplift as required by the Government should be applied to the overall housing requirement, resulting in an annual requirement of 2,300 dwellings per annum, rather than the Council’s preferred approach of 1,704 dwellings per annum.

Further the housing requirement for Bradford South West and the District should be seen as a minimum so as to demonstrate a commitment from CBMDC to significantly boosting housing delivery over recent years.

Should SW/004 and SW146 be is ‘Allocated’ our client will be looking to submit a planning application almost immediately. In this context the Delivery Timescales should be amended to 0-5 years.

Object

Representation ID: 23640

Received: 24/03/2021

Respondent: Patchett Developments Ltd

Agent: Johnson Mowat

Housing Distribution - Bradford SW

The Draft Local Plan significantly increases the urban focus by directing more development to Bradford City Centre. The Plan proposes 7,000 dwellings in the City Centre, a significant uplift from 3,500 in the Core Strategy, and 4,000 in the Draft CSPR.

The Council have therefore applied an urban focus uplift in terms of the distribution of development but without applying an uplift to the overall requirement. This results in a whole shift away from the distribution identified in the adopted Core Strategy, with disproportionate reductions to the majority of sustainable settlements and sub areas in the District, including Bradford SW.

It is now the intention of the Plan to reduce the overall requirement for Bradford SW to 3,175 dwellings. This is not supported by our client; it is our clients position that the overall requirement for the both Bradford South West and the District as a whole should be significant higher.

Additional material and suggested changes provided in submission document