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

Object

Representation ID: 28466

Received: 24/03/2021

Respondent: Lovell Homes

Agent: PB Planning

Objection to Site Ref. NW/033 being rejected as a housing allocation within the Preferred Options Local Plan.

The site can make a significant contribution to the provision of much needed housing opportunities in the District.

We consider that additional housing sites will need to be released in order to meet the District’s minimum housing needs and that this uplift should be distributed to the District’s most sustainable locations. Which include the Allerton area of the Regional City of Bradford.

The site can deliver a comprehensive development of market and affordable housing alongside a number of community benefits to meet the needs and aspirations of the local area. Lovell Homes are proposing to deliver 40% affordable housing at the site. This far exceeds that required by the Preferred Options Local Plan.

The site will deliver a substantial 3.87ha of greenspace.

A landscape-led development is proposed which responds to the existing landform, vegetative features, and topography.

The proposals will create a ‘green wedge’ of landscape and enhance the existing woodland habitat on the site’s northern boundary. The retention of the existing woodland boundary offers the ability to provide an improved development edge and a soft transition with the reservoirs and existing woodland located to the north of the site, creating a defensible Green Belt boundary in perpetuity in this area of the City.

The opportunity to deliver biodiversity enhancements within the substantial areas of open space, including green corridors which connect the site’s existing areas of biodiversity value with new pocket greenspaces.

The development proposals are situated in a suitable and highly sustainable location in respect of existing settlement form and there are no technical or environmental (built and natural) constraints that would preclude the development of the site.

Lovell’s development proposals represent a sequentially preferable development opportunity to a number of other potential green belt releases being considered by the Council. There are very few other potential housing allocations that benefit from the defensible boundaries and sustainability credentials of the Allerton Road, Bradford site.

Object

Representation ID: 28467

Received: 24/03/2021

Respondent: Lovell Homes

Agent: PB Planning

Rejected Site NW/033 - Lovells's Assessment of the Site's Contribution to the Green Belt Purposes:

The development of the site would not result in unrestricted urban sprawl: - A key consideration is the strength and permanence of existing boundaries and the existing extent of development. The site is physically contained to the north by Chellow Dene. With existing residential development areas providing physical containment along the northern, eastern, and southern edge of the site.

The development of the site would not result in the merging of adjacent settlements: - The site already benefits from strong defensible boundaries, which provide a physical and visual buffer between the edge of Allerton and Daisy Hill, and the physical distance between the two settlement edges would not be shortened by any significant amount as the site’s northern boundary given the proposed retention of existing greenspace within this area of the site by the Illustrative Masterplan.

The site does not assist in safeguarding the countryside from encroachment: - No part of the site is defined as forming part of an Area of Special Landscape Value and the landscape character of the site can be considered to be transitional urban fringe land. As a consequence, the site relates more to the urban edge to which it is adjoined rather than the open countryside, which means that it does not correctly serve a purpose of reducing encroachment.

The proposed development of the site will have no detrimental effect on the setting and special character of historic features: - The site is not located within or adjacent to any designated Conservation Areas. No historic or listed buildings or structures would be affected by the site’s development.

Object

Representation ID: 28468

Received: 24/03/2021

Respondent: Lovell Homes

Agent: PB Planning

Housing Need and Requirement:

The Preferred Options Local Plan identifies that the Council will seek to deliver 1,704 homes per annum, which reflects the Standard Method Calculation without the Cities & Urban Centres Uplift required by Step 4 of the PPG’s prescribed methodology.

The actual minimum housing need is therefore 2,300 homes per annum not 1,704.

Whilst the use of the Standard Method is not mandatory, the PPG is clear that “there is an expectation that the standard method will be used, and that any other method will be used only in exceptional circumstances” (Paragraph: 003 Reference ID: 2a-003-20190220).

The Council’s Housing Need Addendum (February 2021) is inconsistent and incorrect in the way it addresses what the minimum level of housing need is. In particular, the Cities and Centres uplift the uplift is not a variable to be considered when determining if there is evidence to increase the minimum housing need, it is one of the four initial key steps which establishes that Bradford’s minimum housing need is 2,300 homes per annum.

As insufficient evidence has been provided to demonstrate that exceptional circumstances exist for the removal of the Cities & Urban Centres Uplift from the Standard Method calculation, the Local Plan should seek to deliver 2,300 homes per annum over the plan period 2020-2038. Which equates to 41,400 homes.

Object

Representation ID: 28469

Received: 24/03/2021

Respondent: Lovell Homes

Agent: PB Planning

Housing Distribution - Bradford NW

As insufficient evidence has been provided to demonstrate that exceptional circumstances exist for the removal of the Cities & Urban Centres Uplift from the Standard Method calculation, the Local Plan should seek to deliver 2,300 homes per annum over the plan period 2020-2038. Which equates to 41,400 homes.

Meaning sufficient land to allocate a further 10,728 homes will need to be found within the District, and the PPG identifies in Paragraph: 035 Reference ID: 2a-035-20201216 that the increase in the number of homes to be delivered through the Cities & Urban Centres Uplift is expected to be met by the cities and urban centres themselves, rather than the surrounding areas, unless it would conflict with national policy and legal obligations.

Lovell Homes’ site at Allerton Road, Bradford is located within the defined area of the Regional City of Bradford and should therefore be considered as an additional housing allocation to meet the increased housing needs of the District within future version of the Local Plan.

Furthermore, even if the level of housing distribution to the North West Area of Bradford was retained at 9% this would require the delivery of 3,726 homes within the plan period, an increase of 826 homes.

Retaining the adopted Core Strategy’s level of distribution (11%) would require the delivery of 4,554 homes. Which of course is a level of housing growth which was previously considered sustainable and deliverable following a thorough examination in public process.