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

Support

Representation ID: 24602

Received: 24/03/2021

Respondent: Gleeson Homes

Agent: Pegasus Group (Leeds)

Our client is supportive of Policy SP3 in so far as it identifies the Regional City of Bradford (with Shipley and Lower Baildon) as the primary settlement in the ierarchy. As such it is appropriate to focus the majority of housing, employment, shopping, leisure, education, health and cultural facilities in the city to support growth and sustainable communities.

The site at Northside Road falls within the urban area of the City and its development for housing would support the sustainable objectives of the emerging plan.

Support

Representation ID: 24603

Received: 24/03/2021

Respondent: Gleeson Homes

Agent: Pegasus Group (Leeds)

Our client is generally supportive of the prescribed hierarchy for the location of development, however, whilst this is an important priority, it must also strike a sensible balanced against deliverability, sustainability and viability to ensure planmaking applies the presumption in favour of sustainable development.

The Local Plan should provide a balanced portfolio of development opportunities, recognising the contribution that appropriately located sustainable greenfield development will make in meeting the overall housing requirement.

Object

Representation ID: 24604

Received: 24/03/2021

Respondent: Gleeson Homes

Agent: Pegasus Group (Leeds)

Housing Need and Requirement

-Concerns that the level of growth is not based upon robust evidence and hence may be found unsound.
- The Council has not applied the 35% uplift which the Government has indicated should be applied to the 20 largest cities and urban centres. To ensure that the plan is found sound at examination the Council will need to clearly demonstrate exceptional circumstances. This should include all considered options.
-It is logical that the 35% uplift is applied to the entire local planning authority area.

Instead of dismissing the urban uplift, we consider other options should be considered. This could include a range of solutions such as new allocations and increased levels of delivery from the preferred allocations, providing any additional development can be accommodated in a sustainable manner.

-The Council should be taking opportunities to secure increased housing development and contribute towards tackling the national housing crisis which the urban uplift seeks to address.

- Policy SP8 should not identify a number of dwellings as a ceiling. Opportunity should be given for more of an approximate figure to allow for increased provision of housing where sites are able to accommodate these additional units in a sustainable manner.

Object

Representation ID: 24605

Received: 24/03/2021

Respondent: Gleeson Homes

Agent: Pegasus Group (Leeds)

-Direction to comments on Policy SP8.
-The Council should consider other options to meet the 35% urban uplift. As highlighted previously, this could include a range of solutions such as new allocations and increased levels of delivery from the preferred allocations, providing any additional development can be accommodated in a sustainable manner.
-Wording of Policy HO1 does not emphasise the fact that the proposed housing requirement is the minimum housing need (Ref Para 60 NPPF).
-There is no requirement within the Framework to manage or phase the release of sites to deliver housing growth. It is noted the Council recognise this and justify the approach by stating “there is however still a need to ensure that sites are delivered in a sustainable manner and housing delivery is a key Government and Council goal”.
However, this is disputed as phasing the release of sites would unduly constrain sustainable developments. The Council’s most recent assessment of 5-year housing land supply identified only a 2.03-year supply; whilst this is based upon local plan requirement, it is clear that additional sites are required. It is therefore considered unjustified to artificially constrain allocations from coming forward.

Support

Representation ID: 24606

Received: 24/03/2021

Respondent: Gleeson Homes

Agent: Pegasus Group (Leeds)

Our client is broadly supportive of Policy HO2 and the flexibility it provides for developers, in particular, the ability to deliver the most dwellings possible, while achieving high-quality design.

Object

Representation ID: 24607

Received: 24/03/2021

Respondent: Gleeson Homes

Agent: Pegasus Group (Leeds)

In determining whether the NDSS should be introduced it is essential to recognise that these are optional standards. Footnote 46 of the 2019 NPPF advises that: “Policies may also make use of the nationally described space standard, where the need for an internal space standard can be justified.”

Standardisation of size diminishes customer choice. Gleeson Homes build a wide range of properties including entry level two, three and four-bedroom. Requiring NDSS compliant properties for all new dwellings could reduce opportunities for people to access the housing market by removing smaller open market products. This will effectively cut-off a source of supply for many first-time buyers, first-time movers and young families. The reduction in diversity may also harm build rates.

Due to the current increase in people working from home additional rooms may be sought to accommodate home offices. Therefore, flexibility is key. It is not considered essential that home offices strictly adhere to the NDSS.

It should also be noted that if the Council can justify the introduction of the NDSS a transitional period should be included within the policy (PPG ID: 56-020-20150327).

Support

Representation ID: 24608

Received: 24/03/2021

Respondent: Gleeson Homes

Agent: Pegasus Group (Leeds)

-The site is at ‘very low’ risk of surface water flooding.
-Not located within a conservation area and does not contain any listed buildings.
-Extensive development within the land surrounding these assets - now located in a firmly modern context within no legibility of their historic surroundings. It is not considered that the proposed development will cause harm to the significance of these heritage assets through changes within their wider surroundings.
-NPPF(para 68) seeks to promote the development of a good mix of sites. The site would provide a modest amount of growth of approximately 60 no. dwellings.
- A stage 2 site investigation has been undertaken. Abnormal costs to development arising from the ground conditions are understood. The site is deliverable, and our client is keen to progress as soon as possible, which will assist in delivering 5-year housing land supply. It is not necessary for the development to be placed in a later phase of the plan.
-Site is identified as a playing pitch under Policy OS4 (RUDP), however has not been in active sports use for over 10 years.
-Site has been subject of previous planning permissions for residential development, dating from the early/mid 1990's. Given the site’s proximity to an area of recreation open space located adjacent to the site, it is considered that the proposed development would not result in any deficiency in the locale.
-Site is deliverable for housing and our client is committed to bringing forward the development opportunity.
-Site will make a significant contribution to the overall housing requirement in a suitable and sustainable urban location.

Support

Representation ID: 30067

Received: 24/03/2021

Respondent: Gleeson Homes

Agent: Pegasus Group (Leeds)

Housing Distribution

Our client is generally supportive of the distribution of housing growth (however note there are concerns that overall the level of growth i.e. the housing requirement is not based upon robust evidence and has failed to apply the 35% uplift for largest cities and urban areas introduced by the Government)