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

Comment

Representation ID: 27540

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

A Plan period of 2020-2038 is suggested, with the revised end date consistent with our suggestions from two (or so) years ago. Given that time has moved on EMFL considers that a cautious approach should be taken given the timetable has already slipped.

With adoption now expected in 2023, whilst the 2038 figure would give the 15 years recommended by the Framework (Para 22) it does not allow for any further slippage. EMFL suggest it would be prudent to consider extending the plan period further to 2040; the start date (for evidence etc) can be the same. Such changes will be consistent with the proposed revisions to the Framework as outlined above.

Support

Representation ID: 27541

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

Generally, the spatial priorities promoting growth of the Local Service Centres as defined in Policy SP3 are supported. No change is required to this policy, although as we suggest later we consider that a greater level of housing growth could and should be should be directed to East Morton.

Support

Representation ID: 27542

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

Part four of the policy refers to the Local Service Centres and Rural Areas stating that development will be of an appropriate scale to ensure that they remain vibrant, dynamic, and attractive places to live. To this end the policy is welcomed where it supports economic diversification, retention and improvement of local services and facilities.

Comment

Representation ID: 27543

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

Changes to the Core Strategy Policy introduce a clear rationale for prioritising Green Belt release. These are generally welcomed but assume that building on greenfield land within a settlement is more sustainable (desirable) than releasing Green Belt land, which is an urban containment policy, not an indication of environmental/ecological value.

It is noted elsewhere that the Local Plan justification appears to conflate Green Belt, which is an urban containment policy tool, with environmental, ecological and cultural heritage values. This is not considered a valid approach.

Object

Representation ID: 27544

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

Notwithstanding comments on the Plan period and the housing requirement, it is welcomed that the Council recognises that exceptional circumstances exist such that land should be released from the Green Belt to meet the future housing and economic development needs of the District, and to provide sufficient land for safeguarding such that Green Belt boundaries endure beyond the Plan period.

An amendment is requested such that the following is added to the list of sites at SP5 Part B

EM12/H – Land at Carr Lane, East Morton

The rationale for this is set out in Section 5 of these representations below.

Support

Representation ID: 27545

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

Introduction of a new strategic policy for economic growth is welcomed reflecting a broader approach to what contributes to a diverse, vibrant, and healthy local economy and improving the health and well-being of the community.

It is considered that the policy is positively worded. It would be appropriate for the policy under Part 5 to also refer to the “land-based industries and economy “.

Object

Representation ID: 27547

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

Housing Need and Requirement

Policy approach is not sound. It is inconsistent with national policy (NPPF & PPG).

Substantial concern that the housing requirement (1.704 p.a.) is significantly below the identified Local Housing Need (LHN) as calculated by the Standard Method, which is 2,295 dwellings per year.
No adequate explanation of departure from national policy or Government’s objective to boost housing supply.

Should amend the housing requirement to better reflect the LHN identified by the Standard Method, and take into consideration circumstances set out in the PPG where it may be appropriate to plan for a higher figure and extended plan period to 2040.

Suggested that Policy SP8 should set out a new housing target of 45,900 dwellings, as a minimum; equivalent to 2,295 units per annum for the period to 2040.

SLA identifies supply of 33,466 units –potential shortfall of 12,400 units against the LHN. Housing trajectory is concerning. Plan should be more aspirational about delivery from adoption.

Comment

Representation ID: 27548

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

Components of Supply

SLA identifies supply of 33,466 units – potential shortfall of 12,400 units against the LHN.

A concern is raised that the housing trajectory setting out the projected housing delivery suggests that the mix of sites will not the Council’s LHN in years 1 to 5, followed by an “explosion” of delivery in Year 6. It would more believable if changes in supply were more graded.

Scepticism is applied to the trajectory and the suggestion that the Plan should be more aspirational in the range of sites and number of outlets to deliver the housing requirement from adoption, not five years hence

Object

Representation ID: 27549

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

Housing Distribution - Local Service Centres / East Morton

Whilst the drop in housing numbers from the Core Strategy to the Local Plan is explained, the change in distribution across the settlement hierarchy is not clear.

Proposed distribution benefits the Regional City and Local Growth Centres at the expense of Principal Towns and Local Service Centres (LSC). This does not appear to be a justified approach and is not explained by boundary changes to administrative and regeneration initiatives.

Appears to be little logic to the distribution to each of the LSC settlements and a lack of consistency.

More appropriate approach is to change the housing distribution proportions to better reflect the population distribution, giving LSC settlements a requirement of around 2,500 dwellings over the plan period (or 4,180 units should the increased housing requirement of 2,295 dpa be adopted).

SLA shows sufficient land around the LSC settlements to accommodate increased development.

Consideration should be given to allocating sufficient land in East Morton for a minimum of 110 dwellings.

Comment

Representation ID: 27642

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

Previously Developed Land / Affordable Housing

50% of new homes are expected to come forward on brownfield/previously developed land. Part of site EM/012 is considered to comprise previously developed land.

Whilst it is important to maximise/make effective use of PDL, it is important the ensure that its prioritisation does not compromise the delivery of homes in sustainable locations to meet local needs. Post Covid-19 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.

25% of the housing requirement (426 dwellings per annum) is expected to be affordable housing, however the SHMA identifies a net annual imbalance of 441 affordable dwellings per year. Consideration needs to be given to total affordable housing need when determining an appropriate housing requirement. An increase in total housing figures may need to considered where it helps delivery affordable housing.