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

Object

Representation ID: 25157

Received: 23/03/2021

Respondent: Home Builders Federation

The Council proposes a Plan period of 2020-2038. The HBF considers it may be beneficial to take a cautious approach as the timetable has already slipped, with adoption now expected in 2023, whilst the 2038 figure would give the 15 years recommended by the National Planning Policy Framework (NPPF) it does not allow for any further slippage. The HBF considers that the Council may want to consider extending the plan period further to 2040.

Object

Representation ID: 25158

Received: 23/03/2021

Respondent: Home Builders Federation

Housing Need and Requirement

The NPPF expects strategic policy-making authorities to follow the standard method in this guidance for assessing local housing need. The HBF has considered the LHN using the Standard Methodology set out in PPG, it can be calculated as follows:

Step 1 - Setting the baseline:
2014-based household projections in England average annual household growth over a 10-year period, with the current year being used as the starting point. The household projection for 2021 was 213,692 and in 2031 it is 229,467, therefore the growth equals 15,775, giving an average of 1,577.5 households each year.

Step 2 - An adjustment to take account of affordability:
The most recent median workplace-based affordability ratio for Bradford (2019) is 5.23.

Where an adjustment is to be made, the formula is:

Minimum annual local housing need figure = (adjustment factor) x projected household growth.

For Bradford this would be: Minimum annual local housing need figure = (1.076875) x 1,577.5 = 1,699.

Step 3 - Capping the level of any increase
The Bradford Core Strategy was adopted in 2017, and is less than five years old, therefore the local housing need figure is capped at 40% above average annual housing requirement figure set out in the most recently adopted strategic policies. The Core Strategy has a housing requirement of 2,476dpa, 40% above the 2,476 would be 3,466dpa. The minimum annual LHN is therefore below this cap, and therefore does not limit the increase to the local authority’s minimum annual housing need figure.

Step 4 – Cities and Urban Centres Uplift
A 35% uplift is then applied for those urban local authorities in the top 20 cities and urban centres list. This includes Bradford.
The 35% uplift for Bradford would be 1,698.77 x 0.35 = 594.5695

Therefore, the minimum LHN for Bradford as calculated by the standard method is 2,293 dwellings each year.

The HBF is concerned that the Bradford Local Plan housing requirement, at 1,704dpa is significantly below the identified LHN of 2,293dpa. The Plan states that ‘based on current evidence it is considered that the additional 35% uplift of the standard method cannot be realistically met in terms of deliverable land supply, strategic constraints (Green Belt) and potential significant adverse impacts within the Regional City of Bradford’. The HBF does not consider this to be consistent with national policy or the Government’s objective to boost the supply of homes.

It should be noted that the standard method identifies the minimum LHN and there may be circumstances, as set out in the PPG, when it is appropriate to plan for a higher housing need figure than the standard method identifies. These circumstances include where there are growth strategies, strategic infrastructure improvements, an unmet need from neighbouring authorities or where previous levels of housing delivery in the area or previous assessments of need are significantly greater than the outcome of the standard method. The HBF recommends that the Council give further consideration to these circumstances.

The HBF considers that the Council should amend the housing requirement to better reflect the LHN identified by the standard method, and to take into consideration the circumstances where it may be appropriate to plan for a higher figure.

Object

Representation ID: 25159

Received: 23/03/2021

Respondent: Home Builders Federation

Previously developed land (PDL)
This part of the policy states that at least 50% of new homes will be on PDL, although the proportions may vary across the district.

The HBF supports the Council in making as much use as possible of previously developed land (PDL) in accordance with 2019 NPPF. However, the HBF considers that it is important to ensure that the prioritisation of PDL does not compromise the delivery of homes in sustainable locations to meet local needs. The HBF also considers it will be important to consider the future deliverability of intensely developed residential schemes, which will be dependent on the viability of PDL and demand for high density urban living post Covid-19.

Support

Representation ID: 25160

Received: 23/03/2021

Respondent: Home Builders Federation

Affordable Housing

This part of the Policy seeks to ensure that approximately 25% of the total housing requirement is affordable housing, this will be delivered through policy HO5: Affordable Housing.

The HBF generally supports the Council in seeking to meet their affordable housing needs. 25% of the housing requirement would be 426dpa. The Strategic Housing Market Assessment (SHMA) (2019) states that the overall net annual imbalance is calculated to be 441 affordable dwellings each year. The PPG states that ‘total affordable housing need can then be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, taking into account the probable percentage of affordable housing to be delivered by eligible market housing led developments. An increase in the total housing figures included in the plan may need to be considered where it could help deliver the required number of affordable homes’. The HBF considers that the Council need to ensure that this affordable housing need is given consideration in determining an appropriate housing requirement.

Comment

Representation ID: 25161

Received: 23/03/2021

Respondent: Home Builders Federation

This policy seeks to achieve a target of net zero carbon emissions by 2038, by ensuring that new development minimises emissions as much as possible. It is noted that this policy is setting a target ahead of the Government target of net Zero Carbon by 2050. The HBF does not generally object to encouragement for the need to minimise the carbon emissions. The HBF supports moving towards greater energy efficiency via a nationally consistent set of standards and a timetable for achieving any enhancements which is universally understood and technically implementable. The HBF acknowledges that the Government has not enacted its proposed amendments to the Planning & Energy Act 2008 to prevent the Council from stipulating energy performance standards that exceed the Building Regulations. However, the HBF considers that the key to success is standardisation and avoidance of every Council in the country specifying its own approach to energy efficiency, which would undermine economies of scale for both product manufacturers, suppliers and developers.

The Government has consulted on The Future Homes Standard. The UK has set in law a target to bring all its greenhouse gas emission to net zero by 2050. New and existing homes account for 20% of emissions. It is the Government’s intention to future proof new homes with low carbon heating and world-leading levels of energy efficiency. The Government wants to create certainty and consistency. An uplift to Part L standards will improve the energy efficiency of new homes and prepare housebuilders and supply chains in readiness for the further uplift in 2025 to meet the Future Homes Standard.

Comment

Representation ID: 25162

Received: 23/03/2021

Respondent: Home Builders Federation

This policy looks to meet the housing requirement set out in Policy SP8 by allocating a range of sites of different types, sizes and locations. The allocations are not set out within the policy they set out in Section 5 of the Plan, with relevant site proformas.

The HBF considers it may be beneficial for the policy to provide a table summarising the allocations, their size and their proposed capacity. This could be similar to table 4.14.1 but to include all of the sites.

Comment

Representation ID: 25163

Received: 23/03/2021

Respondent: Home Builders Federation

The HBF is keen that the Council produces a plan which can deliver against its housing requirement. To do this it is important that a strategy is put in place which provides a sufficient range of sites to provide enough sales outlets to enable delivery to be maintained at the required levels throughout the plan period. The widest possible range of sites by both size and market location are required so that small, medium and large housebuilding companies have access to suitable land to offer the widest possible range of products. A mix of sites provides choice for consumers, allows places to grow in sustainable ways and creates opportunities to diversify the construction sector. Under the NPPF , the Councils should identify at least 10% of the housing requirement on sites no larger than one hectare or else demonstrate strong reasons for not achieving this target. The HBF and our members can provide valuable advice on issues of housing delivery and would be keen to work proactively with the Council on this issue.

The Plan should ensure the availability of a sufficient supply of deliverable and developable land to deliver the Council’s housing requirement. This sufficiency of housing land supply (HLS) should meet the housing requirement, ensure the maintenance of a 5 Year Housing Land Supply (5YHLS), and achieve Housing Delivery Test (HDT) performance measurements. The HBF also strongly recommends that the plan allocates more sites than required to meet the housing requirement as a buffer. This buffer should be sufficient to deal with any under-delivery which is likely to occur from some sites. Such an approach would be consistent with the NPPF requirements for the plan to be positively prepared and flexible.

The HBF does not wish to comment upon the acceptability or otherwise of individual sites. It is, however, important that all the sites contained within the plan are deliverable over the plan period and planned to an appropriate strategy. The HBF would expect the spatial distribution of sites to follow a logical hierarchy, provide an appropriate development pattern and support sustainable development within all market areas.

The Council’s assumptions on sites in relation to delivery and capacity should be realistic based on evidence supported by the parties responsible for housing delivery and sense checked by the Council based on local knowledge and historical empirical data.

Comment

Representation ID: 25164

Received: 23/03/2021

Respondent: Home Builders Federation

This policy states that unless site specific considerations indicate otherwise development should achieve a minimum density of 35 dwellings per hectare (dph), with developments in locations including town centres and areas well served by public transport and local amenities will be expected to achieve densities of at least 50dph. The setting of residential density standards should be undertaken in accordance with the NPPF where policies should be set to optimise the use of land. A range of density standards specific to different areas of the city is appropriate to ensure that any proposed density is appropriate to the character of the surrounding area.

The flexibility provided by this policy in relation to certain considerations is noted, this will allow developers to react to some site-specific issues. However, further amendments could be made to create greater flexibility to allow developers to take account of the evidence in relation to market aspirations, deliverability and viability, the site’s context and accessibility.

The Council will also need to consider its approach to density in relation to other policies in the plan. Policies such as open space provision, cycle and bin storage, housing mix, residential space standards, accessible and adaptable dwellings and parking provision will all impact upon the density which can be delivered upon site.

Comment

Representation ID: 25165

Received: 23/03/2021

Respondent: Home Builders Federation

This policy looks for all major residential development to incorporate a mix of housing types, sizes, prices and tenures. It suggests the exact mix should be based both on market demand and evidence of local housing need. The HBF understands the need for a mix of house types, sizes and tenures and is generally supportive of providing a range and choice of homes to meet the needs of the local area. The HBF recommends a flexible approach is taken regarding housing mix which recognises that needs and demand will vary from area to area and site to site; ensures that the scheme is viable; and provides an appropriate mix for the location and market.

Comment

Representation ID: 25166

Received: 23/03/2021

Respondent: Home Builders Federation

This policy requires affordable housing contributions on all major residential development, it sets different targets based on zones and whether the site is PDL or greenfield. The affordable housing requirement ranges from 10% in Inner Bradford and Keighley to 40% on greenfield sites in Wharfedale. The policy goes on to suggest that the tenure mix will be 65% for affordable rent and 35% affordable home ownership products. It also states that in line with national policy at least 10% of the overall affordable housing contribution from a site should be available for affordable home ownership.

The Financial Viability Assessment Report sets out the latest viability position. It highlights that there are viability issues in in the lower and lower medium value zones and recommends a reduced affordable housing requirement in these areas. For the lower zones the Assessment recommends reducing the affordable housing requirement to nothing, although it does suggest that it may be possible to set the level at 10% in line with the NPPF and consider proactive interventions in the market to support delivery. It is not apparent from the policy what proactive interventions the Council proposes.

The HBF notes that the NPPF states that where major development involving the provision of housing is proposed, planning policies should expect at least 10% of the homes to be available for affordable home ownership, unless this would exceed the level of affordable housing required in the area. The HBF are concerned this has been misinterpreted by the Council. The 10% affordable home ownership is a proportion of the overall number of homes provided, not from the affordable housing contribution. As such if the Council is following the recommendation from the Viability Assessment in terms of the lower value areas the affordable housing provision from these areas should be only in the form of affordable home ownership homes. The HBF considers that the Council should also give further consideration of this NPPF requirement in relation to the tenure split proposed across other areas too. As at present it would not be possible to provide both the NPPF 10% affordable home ownership homes and the meet the proposed affordable housing split set in the policy.

The HBF supports the need to address the affordable housing requirements of the borough. The NPPF is, however, clear that the derivation of affordable housing policies must not only take account of need but also viability and deliverability. The Council should be mindful that it is unrealistic to negotiate every site on a one-by-one basis because the base-line aspiration of a policy or combination of policies is set too high as this will jeopardise future housing delivery.