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

Comment

Representation ID: 28498

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

Section 2.13 outlines the Council’s strategic objectives, which will be used to ensure that the overall spatial vision for the District is achieved. It is noted that the second objective is to “ensure that the District’s requirements for housing, business and commerce are met in full in sustainable locations”. Given the clear remit from the Government that the 20 largest urban areas must provide a 35% uplift to the minimum housing requirement, and the Council’s decision to decline to do so, means that they will not be meeting the District’s housing requirements in full.

Object

Representation ID: 28500

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

Whilst our Client supports the Council’s commitment to the presumption in favour of sustainable development, national guidance is clear that local plans should avoid unnecessary repetition of national policy. As such, part A of the policy should be deleted as it is unnecessary and repeats paragraph 11 of the National Planning Policy Framework. We recently appeared at the Doncaster Council Local Plan Examination and the Inspector requested that the Council delete their presumption in favour of sustainable development policy, which they have subsequently proposed through Main Modifications.

We would also question whether part B of the policy is necessary as the detailed development management policies effectively demonstrate how the authority will encourage developments which meet the three elements of sustainable development.

Object

Representation ID: 28502

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

Our Client supports the Council’s conclusions that exceptional circumstances exist to release land from the Green Belt in order to meet their housing requirements, as outlined in the supporting text for the proposals.

However, they object to the inclusion of site SH4/H which is situated on land off Glenview Drive and is proposed to deliver 164 dwellings. They suggest that this site is not deliverable and suffers from steep topography and access problems.

This site should be replaced by a new combined site comprising SLA sites SH/044 SH/048 (see separate objection).

Object

Representation ID: 28513

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

The site, which has reference SH/026 in the Council’s Sustainability Appraisal has a significant number of constraints which means it is unlikely to be developable and it is not a suitable or achievable site and it should not be carried forward as a proposed allocation.

We would question how the site will be accessed, as we assume that it could not be achieved via the B6269 because of the change in levels. There is a potential access off Bankfield Road and in order to achieve this, it would require the removal of a large woodland of mature trees, some of which are understood to be protected by Tree Preservation Orders . In addition, the woodland represents deciduous woodland priority habitat so there will be an adverse impact upon biodiversity through the loss of this woodland. We would question how any future development would demonstrate biodiversity net gain when the loss of the woodland is factored in.

It is noted that the Council believe that the development will be accessed via Glenview Drive, however we would question the suitability of the access given the steep topography and ability to accommodate traffic associated with 164 dwellings.

The site is very steep and is effectively split into two distinct parts – the southernmost being a small area which sits directly behind the row of properties fronting onto Nab Wood Drive. This area is detached from the remainder of the site by a further band of trees which sit on land which is so steep that we consider it highly doubtful that you would be able to construct a road with a suitable gradient to connect the two parcels. As such, if the Council carry this site forward to the Publication draft, the site boundary should be significantly reduced with the southernmost parcel removed along with the mature woodland fronting onto Bankfield Road. A more realistic site area would in fact be around 2 hectares which would reduce the capacity significantly.

Comment

Representation ID: 28520

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

Our Client does not wish to make any significant comments with regards to the Council’s economic growth aspirations other than to note that as per our comments on Policy SP8, the housing target is significantly below the standard methodology and should be increased to align with MHCLG requirements.

As such, the economic growth aspirations should be increased to align with the significant increasing in housing which is required .

Object

Representation ID: 28523

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

Housing Need and Requirement:

Our Client strongly objects to the Council’s proposal to set the housing requirement at 1,704 dwellings per annum as this is not in accordance with the MCHLG standard methodology which require the 20 largest urban authorities in England to provide a 35% uplift to the baseline figure. As such, the Council’s housing requirement is a minimum of 2,300 dwellings per annum.

The Council’s justification for not including for the 35% uplift carries little weight in the context of the Core Strategy, which was only adopted in 2017, which set a housing requirement of 42,100 new homes and which was underpinned by evidence which must have assessed land supply, strategic constraints and the ability of existing infrastructure to cope with the level of growth that was planned. Realistically nothing has changed in this regard.

Moreover the Council have already demonstrated that exceptional circumstances exist through the Core Strategy to release land for 11,000 new homes in the green belt as opposed to the 5,500 in the new Local Plan.

By not including the 35% uplift, the Council are not using the standard method and there is a requirement to demonstrate exceptional circumstances as to why a different approach has been taken.

Whilst it is noted that the 35% is ideally applied to urban areas and thus brownfield land, the PPG does not explicitly state that the 35% is only accounted for in urban areas.

The Council’s view is that the 35% uplift can only be provided within the Regional City of Bradford, however we consider this to be a misunderstanding of the intention of the uplift.

The Policy is therefore unsound as it does not propose to deliver the minimum housing need identified in the standard methodology and does not include the required 35% uplift. As such, the plan is not positively prepared as required by paragraph 35 of the NPPF.

Object

Representation ID: 28525

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

Housing Distribution - Bradford City Centre / Regional City

Our Client objects to the proposed distribution of housing which is also set out in the policy. The Council are proposing to deliver 7,000 units into Bradford City Centre, which is an increase of 3,500 units when compared to the adopted Core Strategy.

Whilst it is understood why the Council are seeking to deliver a high level of new housing in the City Centre, the reality is it is highly unlikely that this will be achieved given the deliverability issues in the City Centre. Whilst unfortunate, it is an issue that the Council have faced for several years and it is not considered that the situation has changed since the adoption of the Core Strategy and doubling the target is not justified.

The Covid-19 pandemic is likely to have an impact upon people’s aspirations in terms of where they aspire to live and what they require in terms of quality of life.People want to live close to countryside and green spaces. By the Council’s own admission, the City Centre has a significant deficiency in green spaces.

The distribution to Bradford City Centre should be retained at 3,500 units, with the excess 3,500 units spread around the remainder of the Regional City of Bradford

Object

Representation ID: 28526

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

The policy will require future developments outside of town, district, city and principal town centres to deliver developments at a density of 35 dwellings per hectare , which is an increase from 30 dwellings per hectare in the adopted Core Strategy .

Furthermore, in the adopted Core Strategy, only areas within city centres and principal town centres were required to ‘possibly’ achieve densities over 30 dwellings per hectare, however there is now a requirement to achieve at least 50 dwellings per hectare. Whilst it is assumed this has been done to minimise the loss of Green Belt land, it will be at the expense of design. There are ever increasing requirements for new residential proposals such as provision of open space, biodiversity enhancements and space standards and it is considered that when all these matters are factored in, increasing density will put a strain on development proposals.

Object

Representation ID: 28527

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

Our Client is generally supportive of the approach to utilise market demand and evidence of local need from the SHMA as a means of dictating housing mix, however, this is reliant on the SHMA being updated regularly.

We would advise that the policy is revised to include a caveat that if the SHMA is out of date, it cannot be relied on as a means of guiding housing mix. As this acts as an incentive to the Council to keep it up to date.

There are question marks as to how this policy will work in practise and which element will take precedence if the demand in the market does not align with the SHMA.

There are concerns regarding part C of the policy which states that additional guidance on housing mix on an area or site basis will be set out in site allocation proformas and Neighbourhood Plans.

Further explanation should be provided as to how the Council would deal with a situation whereby market demand does not align with housing mix as set out in either the SHMA or a Neighbourhood Plan as applicants will require clarity on this whilst preparing planning
applications.

Object

Representation ID: 28528

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

It is noted that the Policy seeks all new homes to meet the Nationally Described Space Standards (NDSS). The PPG is clear that NDSS can only be introduced into local planning policy where there is a clear and identified need to do so and that to do so would be viable.

Whilst in principle our Client understands why the Council may seek to introduce NDSS this must not be done on the basis of being an aspiration, they must be a clear and identified requirement to do so.

Similarly, the requirement for all new properties to meet Building Regulation M4(2) ‘accessible and adaptable dwellings’ and 5% of homes on major developments of 10 or more units meeting Building Regulations M4(3) ‘wheelchair user dwellings’ has to be fully evidenced before being introduced to policy.