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

Object

Representation ID: 29682

Received: 24/03/2021

Respondent: Redrow Homes

Agent: Johnson Mowat

Housing Need and Requirement:

Johnson Mowat have particular concerns with the Draft Plan’s strategic approach to the overall housing requirement and the Council’s chosen approach of dismissing the Government requirement of a 35% uplift to the housing requirement (Policy SP8). It is considered at the very least, the 35% uplift as required by the Government should be applied to the overall housing requirement, resulting in an annual requirement of 2,300 dwellings per annum, rather than the Council’s preferred approach of 1,704 dwellings per annum. On this basis, the Draft Local Plan is over 10,000 dwellings short in its land provision, against the identified need (2,300 – 1,704 x 18 year plan period = 10,728).

Object

Representation ID: 29683

Received: 24/03/2021

Respondent: Redrow Homes

Agent: Johnson Mowat

Housing Distribution - Ilkley

The Council have applied an urban focus uplift in terms of the distribution of development but without applying an uplift to the overall requirement. This results in a whole shift away from the distribution in the adopted Core Strategy, with disproportionate reductions to the majority of sustainable settlements and sub areas in the District, including Ilkley.

Ilkley has seen significant reductions in its housing apportionment, with the Adopted Core Strategy requiring 1,000 dwellings, which was reduced to 500 in the Core Strategy Partial Review and now proposes a further reduction to 300 dwellings in the Draft Local Plan. This falls significantly short of the baseline population proportionate distribution which is 756.

The 35% uplift to the housing requirement should apply to Ilkley.

As a starting point a target of 657 for Ilkley is proposed resulting in the need to find sites for an additional 357 dwellings.

Object

Representation ID: 29684

Received: 24/03/2021

Respondent: Redrow Homes

Agent: Johnson Mowat

The site (IL/013) is on the edge of Ben Rhydding suburb of Ilkley, a Principal Town and important urban area of Wharfedale.

The 35% uplift to the housing requirement should apply to Ilkley.

This site lies in a sustainable location, it is available and suitable and is a deliverable site that should be included within the Local Plan.

The site credentials are better than those of site IL3/H to the immediate south, which has been included as a Preferred Allocation. The SLA reason for the rejection of the site is Heritage. Adjoining Site IL/014 (Preferred Allocation IL3/H) receives the same ‘Less than Substantial Harm (Unacceptable)’ across the whole site, yet the site is included as a preferred allocation.

We disagree with the Council’s overall conclusion in the Heritage Impact Assessment which refers to the site not being capable of mitigation to achieve a less harmful impact on heritage significance (for details see document submission).

The Green Belt site specific assessment concludes that Site IL/013 is located in a ‘moderate’ green belt parcel and the site has a ‘moderate’ potential impact on the Green Belt, yet site IL/014, a preferred housing site, has a ‘major’ potential impact on the Green Belt.

The 2013 Bradford Growth Assessment concluded that there may be some potential for Green Belt development to the east and west of Ilkley, where landscaping could contribute to providing a settlement boundary.
The SHLAA3 (July 2015) site summary in relation to the Green Belt stated that:
“Development would probably not be damaging to the openness of the green belt in this location.”

The development of this site provides the opportunity to secure a stronger, defensible boundary, to the settlement.

There is logic in extending the size of Preferred Site IL3/H to the immediate south of IL/013, to incorporate IL/013 and deliver the sites together comprehensively. This will allow more scope via design, to address the heritage constraints associated with the setting of Wheatley Grange, as well as provide an opportunity for creating a scheme to form an important gateway development, when entering into Ilkley from the east.