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

Support

Representation ID: 27956

Received: 24/03/2021

Respondent: Bellway Homes Limited

Agent: Barton Wilmore

Fully support the allocation of site NW10/H for residential purposes. The site is available, achievable and suitable and represents a developable and eliverable site, which would round-off the settlement of Allerton, with minimal impact on the Green Belt.

Should the site be allocated, it is envisaged that a planning application for 75-80 new homes will be submitted following the adoption of the Local Plan. Other than the delivery of the initial site infrastructure we are confident that there are no other major infrastructure works that need to take place prior to the commencement of delivery of new homes on the site. Accordingly, the development will commence within a year of the submission of the planning application. Due to the site’s size, there would be one development/selling outlet delivering new homes at the site. It is therefore anticipated that the development will deliver a yield of at least 40 homes per annum. The development proposals can therefore deliver significant benefits to Allerton and the wider District within the first five-year period of the Local Plan, alongside making a significant contribution to the Council’s ongoing 5-year housing land supply requirements.
The anticipated submission of a pre-application enquiry prior to the examination of the Local Plan will help to
ensure that the deliverability timescales outlined above are met.

Object

Representation ID: 27957

Received: 24/03/2021

Respondent: Bellway Homes Limited

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.

Support

Representation ID: 27958

Received: 24/03/2021

Respondent: Bellway Homes Limited

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.

In addition, they fully support the Council’s proposals to allocate site NW10/H for residential development of circa 160 dwellings, and specifically the 7.17 acres of land (see Appendix 1, below) that forms our Client’s interest in the northern section of the site. This has the potential to accommodate 75-80 new homes.

The site would lead to minimal encroachment into the countryside and minimise sprawl. Also, it would not lead to the coalescence of settlements. In summary, it would represent a sound and logical rounding-off of the settlement and its release from the Green Belt would be acceptable as it no longer serves the five Green Belt purposes.

Comment

Representation ID: 27959

Received: 24/03/2021

Respondent: Bellway Homes Limited

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 comment s 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: 27960

Received: 24/03/2021

Respondent: Bellway Homes Limited

Agent: Barton Wilmore

Housing Need and Requirement

The Council’s proposal to set the housing requirement at 1,704 dwellings per annum over the plan period is not in accordance with the MCHLG standard methodology.

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.

It is unclear how only four years ago the Council were confident they could deliver 42,100 new homes over a 17-year period, being fully appraised of the extent of land supply, strategic constraints and infrastructure issues. Realistically nothing has changed in this regard and it is entirely unacceptable to claim otherwise.

By not including the 35% uplift, the Council are not using the standard method and in line with the PPG 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. Whilst a ‘brownfield first’ approach is advocated, it is not meant to be a ‘brownfield only’ approach.

As currently drafted the Policy is 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: 27961

Received: 24/03/2021

Respondent: Bellway Homes Limited

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. As such, our Client objects to the policy as currently drafted.

Object

Representation ID: 27962

Received: 24/03/2021

Respondent: Bellway Homes Limited

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 pro formas 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: 27963

Received: 24/03/2021

Respondent: Bellway Homes Limited

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.

Object

Representation ID: 27964

Received: 24/03/2021

Respondent: Bellway Homes Limited

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.

Support

Representation ID: 27965

Received: 24/03/2021

Respondent: Bellway Homes Limited

Agent: Barton Wilmore

Our Client supports the Council’s Local Area Strategy and Plan for Allerton, which identifies it as a key location for housing growth, with 717 new homes to be allocated and delivered alongside existing planning permissions. Similarly, our Client welcomes the aspiration for new housing developments in Green Belt delivering strong natural landscaping and public open spaces, as these contribute to place making.

We would reiterate our Clients support for the allocation of site NW10/H – Allerton Road, Prune Park Lane, Allerton.