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

Support

Representation ID: 27643

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

Noted that the policy sets a target ahead of the Government for net zero (2038 instead of 2050). Encouragement for the need to minimise carbon emission is supported along with the move towards greater energy efficiency via nationally consistent set of standards and a timetable for achieving any enhancements which is universally understood and technically implementable.

Government has not enacted proposed amendments to the Planning & Energy Act 2008 that prevents Councils from stipulating energy performance standards that exceed Building Regulations.

Government consulted on Future Homes Standards and set in law a target to reach net zero by 2050. Their intention is to future proof new homes with low carbon heating and world-leading levels of energy efficiency, and want to create certainty/consistency.

An uplift to Part L standards will improve energy efficiency of new homes and prepare housebuilders/supply chains for the further uplift in 2025 to meet Future Homes Standard.

Support

Representation ID: 27856

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

Underpinning policy SP10 is the desire to create green infrastructure network across the District, ensuring that new development does not sever existing networks and where possible that new development can improve and enhance current networks.

EMFL supports the policy in principle but considers the policy and justification should recognise issues such as different types of land ownerships and where land is in private ownership with no public access, and different land uses. .

Comment

Representation ID: 27916

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

Would be beneficial for the policy to provide a table summarising the allocations, their size and capacity. It should include EM/012: Land off Carr Lane/Morton Lane.

Plan should provide a sufficient range of sites to provide enough outlets to maintain delivery. Will enable housebuilders of all sizes to deliver a range of products and offer consumers choice as well as allowing places to grow sustainably.

Plan should ensure availability of a sufficient supply of deliverable and developable land to deliver the requirement, maintain a 5-year land supply and achieve Housing Delivery Test measurements.

Recommended more sites than required are allocated to meet the requirement as a buffer to deal with under-delivery and allow flexibility.

Important that sites are deliverable and planned to an appropriate strategy. Distribution would be expected to follow a logical hierarchy, provide an appropriate development pattern and support sustainable development in all market areas.

Assumptions on site delivery/capacity should be realistic.

Comment

Representation ID: 27917

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

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
paragraph 123 of the Framework 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: 27918

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

This policy looks for all major residential development (10 or more units) 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.

EMFL 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.

A flexible approach is recommended that 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.

To this end EMFL considers the allocation of a single small site (less than 10 units) site in East Morton is unlikely to provide an appropriate mix for the future needs of the community.

Comment

Representation ID: 27919

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

Policy requires affordable housing on major residential developments, setting targets based on zones/locations and site’s PDL/greenfield status. It also suggests a tenure mix. Within the Preferred Option no affordable housing will be provided in East Morton.

Viability Assessment highlights issues in lower/lower medium value zones, recommending reduced affordable housing requirements in them. It recommends a zero requirement for lower value zones, but highlights it may be possible to set a level of 10% and consider proactive interventions to support delivery. Not clear what interventions are proposed.

Potential misinterpretation of NPPF where planning policies should expect at least 10% of the homes to be available for affordable home ownership, unless this would exceed the affordable housing requirement in the area

Nneed to address affordable housing requirements is recognised. Affordable housing policies must not only taken account of need but also viability and deliverability.

Unrealistic to negotiate on every site individually because the base-line aspiration of a policy/combination of policies is set too high - will jeopardise future housing delivery.

Object

Representation ID: 27920

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

This policy looks for residential sites of over 100 dwellings to provide at least 5% of the dwelling plots for sale to self-builders. This may well apply to site EM/012 Land at Carr Lane, East Morton.

Considered that the Council’s approach is restrictive rather than permissive by requiring the inclusion of such housing on developments of over 100 dwellings and the approach is not supported by the evidence presented

Object

Representation ID: 27921

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

Support policy aims for new build dwellings to meet Building Regulation requirements M4(2) (accessible & adaptable homes) and for 5% of dwellings on major sites to meet Building |Regulations requirement M4(3) (wheelchair user dwellings).

EMFL is supportive of these aims but considers that the Council has not presented appropriate evidence to adopt the higher optional standards for accessible, adaptable and wheelchair homes the Council should only do so by applying the criteria set out in the PPG.

Policy requires new homes, as a minimum, meet the National Described Space Standards (NDSS) for internal space in new dwellings. They are intended to be optional and can only be introduced where there is a clear need and retain development viability. As such they were introduced on a “need to have” rather than “nice to have” basis. Council has failed to provide sufficient justification for the need for the policy.

Comment

Representation ID: 27922

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

EMFL consider that the Council should not deviate from the Government’s proposals on biodiversity gain as set out in the Environment Bill which will set out the most appropriate approach to biodiversity net gain. This legislation will require development to achieve a 10% net gain for biodiversity. It is the Government’s opinion that 10% strikes the right balance between the ambition for development and reversing environmental decline. 10% gain provides certainty in achieving environmental outcomes, deliverability of development and costs for developers. 10% will be a mandatory national requirement, but it is not a cap on the aspirations of developers who want to voluntarily go further. The mandatory requirement offers developers a level playing field nationally and reduced risks of unexpected costs and delays

Object

Representation ID: 27923

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

New trees and woodland should be planted on all new developments in both public and private areas, including a fruit tree in every garden. EMFL consider this policy should be deleted.