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

Object

Representation ID: 28529

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

Our client understands and agrees with the aspirations of the policy to protect and retain trees where possible.

However, there are occasions where trees need to be removed in order to access development sites.

Part C of the policy proposed a presumption in favour of the retention and enhancement of trees, woodland and hedgerow cover – particularly those which contribute towards – the character of a settlement or its setting, or the amenity of the built -up area; an area’s sense of place or local distinctiveness; valued landscapes; biodiversity and wildlife habitats. Such an approach is not advocated within the NPPF and we would question the need for such a policy. The policy is flawed in that whilst a tree may hold some biodiversity value, its loss and replacement with other enhancements could lead to an overall gain and the policy does not allow for such consideration. This part of the policy is unnecessary as it is covered by Policy DS2 and should be deleted.

Object

Representation ID: 28530

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

The policy requires new residential developments to provide new open space on-site where possible or make a payment in-lieu of on-site provision.

In order to calculate the extent of on-site provision, the Council have included an Open Space Standard at Appendix 11, which sets out the expected level of existing provision per 1,000 of the population and the required maximum distance from residential property to each type of open space. It is then for the applicant to decipher the extent of open space that is required on each development factoring in local deficiencies and surpluses.

We would suggest it is incumbent on the Council to inform the applicant as to the type and level of open space that is required rather than it being the applicant’s responsibility.

A more suitable approach would be to require a set level of open space per dwelling as this gives clarity to applicants when considering development proposals.

Object

Representation ID: 28533

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

Objection to the failure to allocate sites SH/044 and SH/048 for housing development.

It is requested that the Council consider sites SH/044 and SH/048 as one combined site for the purposes of the emerging plan.

It is considered that this combined site represents a logical rounding off of the settlement given its location between an existing school and residential development, would not lead to encroachment into the countryside, urban sprawl or the coalescence of settlements. As such, the land no longer serves a Green Belt purpose and should no longer be protected.

The site represents a far more logical housing site than site SH4/H, which does not relate as well to the settlement and would lead to encroachment into the countryside. Furthermore, the topography of the site is prohibitive with significant access issues.

The combined site SH/044 and SH/048 is not considered to be constrained and matters such as ecological impacts could be mitigated through future design proposals and the site represents a suitable and logical housing allocation.

The site is suitable, available and achievable and also includes previously developed land and is being promoted by a well respected local housebuilder and Bradford Council.

It is noted in the Council’s ‘Site Assessment and Rejected Background Paper’ that site SH/044 has been rejected on a single basis – access. This is incorrect as the Council have previously considered a pre-application enquiry (14/04390/PMJ) for this site for a development of 67 units. The Council’s highways officer stated, “it is considered that the proposal is generally acceptable and it is not anticipated that there will be any major highway issues arising from your proposals”. The indicative layout demonstrates that a suitable access can be achieved to serve SH/044 if it is brought forward in isolation and the Council have incorrectly dismissed the site.

Object

Representation ID: 29009

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

AD/005 should be included in the Plan, it is in the control of Chartford Homes, is suitable and deliverable and can deliver approximately 50-80 homes. These representations demonstrate the following,
- The need for significantly more homes in the plan;
- The need for more homes to be allocated in Addingham;
- The unsuitability of the proposed sites;
- The suitability of Our Clients site.

Addngham is tightly bounded by the Green Belt or designated Local Space, resulting in limited
opportunities for new housing to be developed.

The Council will need to allocate more homes, Addingham should receive a proportion of these and
this site is a suitable location for them. Should the Council not consider more homes are needed, it
is clear that at least one of AD3 or AD4 should be deleted in line with the evidence and as such a
further site for 40 homes needed, which Our Clients site can provide.
However it is considered that once a methodology is published to be able to assess the sites our
Clients site will be shown as more suitable and preferable and it should replace sites for
approximately 80 homes

Object

Representation ID: 29011

Received: 24/03/2021

Respondent: Chartford Homes

Agent: Barton Wilmore

Housing Need and Requirement

The Councils housing requirement is established by using the governments Standard Methodology, which due to an update last year, now includes a 35% uplift over the previous requirement.

The Council’s plan was clearly drafted ahead of this amendment to the methodology and based on the previous version of the Standard Method. The changes to the method are not reflected in the preferred options version of the plan and the Council are currently planning for a significant under delivery (circa 9,000) over the plan period as they are not proposing to include the 35% uplift as required by the standard methodology.

The Council produced a Core Strategy, based on a comprehensive evidence base, examined by an independent Inspector and adopted by the Council. Following adoption of the plan, the government released a Standard Methodology for assessing housing requirements, which at the time provided a much lower level of homes. Rather than allocate sites in accordance with the adopted Core Strategy, the Council took the opportunity to review that plan almost immediately, with a view to supressing the amount of homes that would be delivered.

Given the time that has lapsed since then, the Government have since amended the Standard Methodology and the level of homes now required is similar to that in the adopted Core Strategy.

The Councils simple justification for the avoidance of using the Standard Methodology figure is that there is insufficient infrastructure and the level of homes is not deliverable.

This position is seemingly unfounded, given that only three years ago the Council produced an independent evidence base that demonstrated that this level of homes was both deliverable and viable.

Whilst this amendment to the Standard Method may have been released whilst the draft plan was going through the Councils internal process, rather than pause and implement the changes, two dismissive paragraphs have been added to the text with little justification or assessment to say why it is not viable.

The Standard Method does not provide this flexibility, the level of homes is a minimum and the Councils reluctance to adhere to it needs to be amended as soon as possible so as to not add significant delay to the adoption of the plan and further compound the significant under performance of delivering homes.

The delivery of homes in Bradford is significantly below what is needed. The Council have a woeful five year supply and fail consistently in meeting the housing delivery Test. Ironically having failed the housing delivery test, partly in part due to abandoning the adopted plan, the Councils action plan included the need to allocate more housing sites, the very thing they had abandoned in favour of seeking a lower housing figure.

The Council were adamant that the housing figures in the Standard Method were the most appropriate to use and as such were willing to abandon five years worth of work on an adopted Core Strategy due to the need to follow the Standard Method. The lack of enthusiasm for following that method when doing so doesn’t result in a 35% reduction in housing is clearly unreasonable.

The NPPF is clear that we should be significantly boosting the supply of homes and the reticence to not follow the Standard Method (coincidentally almost the same as a recently adopted figure) is clearly contrary to national planning policy and would result in an unsound plan.