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

Comment

Representation ID: 29700

Received: 24/03/2021

Respondent: Keyland Developments Ltd

Agent: Barton Wilmore

Chapter 2 includes the Council’s proposed plan period, suggest that the plan would run from 2020 to 2038, meaning the plan will have a lifetime of 18 years.

Whilst our Client does not object to this, there are concerns that the Council’s continued and long-standing record of significantly underdelivering the level of new homes required in the District should be fully accounted for with the emerging plan. This is evidenced by the Council not having been able to demonstrate a 5-year housing land supply for at least 10 years and their continued failure to meet the Housing Delivery Test. Whilst the standard methodology is supposed to account for past under delivery, the Council’s refusal to plan for the 35% uplift entirely undermines this.

Object

Representation ID: 29701

Received: 24/03/2021

Respondent: Keyland Developments Ltd

Agent: Barton Wilmore

Section 2.13 outlines the Council’s strategic objectives, which will be used to ensure that the overall spatial vision for the District is achieved.

It is noted that the second objective is to “ensure that the District’s requirements for housing, business and commerce are met in full in sustainable locations”.

Given the clear remit from the Government that the 20 largest urban areas must provide a 35% uplift to the minimum housing requirement, and the Council’s decision to decline to do so, means that they will not be meeting the District’s housing requirements in full.

Object

Representation ID: 29702

Received: 24/03/2021

Respondent: Keyland Developments Ltd

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.

Object

Representation ID: 29703

Received: 24/03/2021

Respondent: Keyland Developments Ltd

Agent: Barton Wilmore

Our Client supports the Council’s conclusions that exceptional circumstances exist to release land from the Green Belt to meet their housing requirements, as outlined in the supporting text for the proposals. However, our Client objects to the omission of their residential site in Esholt as a proposed housing allocation (site ref: NE/053).

The Site re-uses previously developed land, which means it would be sequentially preferable when considering which land should be released from the Green Belt, as per paragraph 138 of the NPPF.

The fact that the site falls outside of the Bradford North East boundary should not prohibit the site from being allocated, indeed, the Council are allocating the employment element of the Esholt site, which also falls outside the boundary.

Given the above, there is no procedural reason as to why the Esholt residential site cannot be allocated and included within the Bradford North East sub-area, in the context of the employment site being allocated. The Esholt development has always been viewed holistically, and the Council have encouraged the landowners to approach the design of the site in a joined-up manner and we strongly believe it should be allocated as one to ensure the holistic approach is maintained.

Support

Representation ID: 29704

Received: 24/03/2021

Respondent: Keyland Developments Ltd

Agent: Barton Wilmore

Our Client fully supports the Council’s position that ‘exceptional circumstances’ have been demonstrated to warrant to release of land from the Green Belt to meet the Council’s employment needs and we fully support the allocation of NE23/E as an employment site.

The Council’s existing employment land supply is generally of poor quality and small in scale meaning that indigenous businesses wishing to scale up their operations may have to leave the District due to lack of choice in the market. The Esholt development is large in scale and offers a unique location in terms of site characteristics (flat topography; development platforms in situ; previously developed land; attractive landscape surrounds) and well as being highly sustainable due to the proximity of Apperley Bridge railway station, bus routes and the local road network.

The Esholt development is hugely important to the Council and it is essential that it is allocated in order for the Council to meet their employment targets over the plan period.

We note that the proposed allocation does not included the land which is currently being proposed for the vehicular access to serve NE23/E and we would advise that the boundary is revised to safeguard an area around the proposed access route, as without this, it could be argued that the land which his allocated is not achievable as there is no suitable access within the confines of the Site.

Comment

Representation ID: 29705

Received: 24/03/2021

Respondent: Keyland Developments Ltd

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 comments 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: 29706

Received: 24/03/2021

Respondent: Keyland Developments Ltd

Agent: Barton Wilmore

Housing Need and Requirement

Our Client strongly objects to the Council’s proposal to set the housing requirement at 1,704 dwellings per annum over the plan period as this is not in accordance with the MCHLG standard methodology which require the 20 largest urban authorities in England to provide a 35% uplift to the baseline figure. As such, the Council’s housing requirement is a minimum of 2,300 dwellings per annum.

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 with a housing target of 2,476 units per annum.

By not including the 35% uplift, the Council are not using the standard method and there is a requirement to demonstrate exceptional circumstances as to why a different approach has been taken.

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 and strategic constraints and the ability of existing infrastructure to cope with that level of growth. Realistically nothing has changed in this regard and it is entirely unacceptable to claim otherwise.

The Council have already demonstrated that exceptional circumstances exist through the Core Strategy to release land sufficient to accommodate 11,000 new homes, as opposed to 5,500 proposed in the new Local Plan. Those sites remain available and developable, and it is unreasonable for the Council to imply otherwise.

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.

The Council’s view is that the 35% uplift can only be provided within the Regional City of Bradford, however we consider this to be a misunderstanding of the intention of the uplift.

Object

Representation ID: 29707

Received: 24/03/2021

Respondent: Keyland Developments Ltd

Agent: Barton Wilmore

Housing Distribution - Regional City

Objects to the proposed distribution - the Council are proposing to deliver 7,000 units in Bradford City Centre, which is an increase of 3,500 units when compared to the adopted Core Strategy.

Whilst it is understood why the Council are seeking to deliver a high level of new housing in the City Centre, the reality is it is highly unlikely that this will be achieved given the deliverability issues in the City Centre. Whilst this is unfortunate, it is an issue that the Council have faced for several years and it is not considered that the situation has changed since the adoption of the Core Strategy.

Following the Covid pandemic people's aspirations are to live close to the countryside and green spaces. By the Council’s own admission, the City Centre has a significant deficiency in green spaces, and it is not feasible to make such a significant increase when it is unlikely to be delivered.

It is noted that the Council are seeking to limit the extent of land released from Green Belt, however, this should not be the main driver in setting the level of distribution, the ability to deliver the housing requirement should take precedence.

The distribution to Bradford City Centre should be retained at 3,500 units, with the excess 3,500 units spread around the remainder of the Regional City of Bradford.

Object

Representation ID: 29708

Received: 24/03/2021

Respondent: Keyland Developments Ltd

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, 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: 29709

Received: 24/03/2021

Respondent: Keyland Developments Ltd

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 can not be relied on as a means of guiding housing mix. As this is act as an incentive to the Council to keep it up to date.

There are question marks as to how this policy will work in practice 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.