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

Support

Representation ID: 29930

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

We note that there is a commitment within the Local Plan to support the regeneration of the district with Policy SP2 detailing Holme Wood as the key regeneration area.

In conjunction with this, Policy SP3 encourages development which supports the regeneration of the city.

These elements of the policy are fully supported and it is essential that it is maintained as an objective for the council. We would draw the council’s attention to the way in which my client’s site SE/163 can deliver on this objective in a way which no other site can.

Support

Representation ID: 29931

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

We note that there is a commitment within the Local Plan to support the regeneration of the district with Policy SP2 detailing Holme Wood as the key regeneration area.

In conjunction with this, Policy SP3 encourages development which supports the regeneration of the city.

These elements of the policy are fully supported and it is essential that it is maintained as an objective for the council. We would draw the council’s attention to the way in which my client’s site SE/163 can deliver on this objective in a way which no other site can.

Comment

Representation ID: 29932

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

It is acknowledged that in broad terms following the steer of the NPPF, priority should be given to Previously Developed Land as a means to limit greenfield release. This is agreed in principle, however there needs to be an appreciation of the risks involved in relying on complex city centre brownfield sites.

The capacity of the main urban areas including brownfield sites cannot accommodate the land required for the 41,400 homes (based on 2,300 dpa) by 2038 and Exceptional Circumstance exist in principle – albeit we believe to a much greater extent.

We question whether the delivery of high-density development in town and city centre locations will meet the requirements of the wider Bradford housing market.

Viability is also an issue.

Object

Representation ID: 29933

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

Land Supply & Housing Mix

Our analysis reveals deliverability issues and constraints on a number of proposed City Centre sites (see schedule for details). There is limited evidence of many of the sites which date in cases back to 2012 being imnplemented.

We conclude that there are doubts about the following sites – CC1, CC2, CC6, CC10, CC12 CC13, CC15/H, CC16, CC18, CC19, CC21, CC23, CC25, CC28, CC29 with a potential lost capacity of 2,476 units and an overall shortfall against the 7,000 requirment for the City Centre of 4,500 units

Recommendation 1: BMDC need to allocate a developable mix of housing sites to account for the c.-4,500-unit shortfall in Brownfield City Centre sites alone. In the interests of an effective plan in accordance with the NPPF.

Object

Representation ID: 29934

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

City Centre Land Supply

Our analysis reveals deliverability issues and constraints on a number of proposed City Centre sites (see schedule for details). There is limited evidence of many of the sites which date in cases back to 2012 being imnplmenmented. We conclude that there are doubts about the following sites – CC1, CC2, CC6, CC10, CC12 CC13, CC15/H, CC16, CC18, CC19, CC21, CC23, CC25, CC28, CC29 with a potential lost capacity of 2,476 units and an overall shortfall against the 7,000 requirment for the City Centre of 4,500 units

Recommendation 1: BMDC need to allocate a developable mix of housing sites to account for the
c.-4,500-unit shortfall in Brownfield City Centre sites alone. In the interests of an effective plan in
accordance with the NPPF.

Comment

Representation ID: 29935

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

A significant proportion of the city centre sites carry risk and if relied upon Bradford may not be able to deliver the quantum of housing envisaged. Our summary assessment of these sites is set out below (Table 1 – Savills City Centre Housing Supply Site Assessment):

CC1/H - Heritage/ build cost implications - has remained vacant through several property cycles. Part flood zone. No clear evidence site is viable.

Comment

Representation ID: 29936

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

A significant proportion of the city centre sites carry risk and if relied upon Bradford may not be able to deliver the quantum of housing envisaged. Our summary assessment of these sites is set out below (Table 1 – Savills City Centre Housing Supply Site Assessment):

CC2/H - Multiple applications in 2005 and 2007 failed to deliver development. Undeveloped for housing through last property cycle. Existing leaseholders. No clear evidence site is viable.

Comment

Representation ID: 29937

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

A significant proportion of the city centre sites carry risk and if relied upon Bradford may not be able to deliver the quantum of housing envisaged. Our summary assessment of these sites is set out below (Table 1 – Savills City Centre Housing Supply Site Assessment):

CC6/H - Heritage/ severe build cost implications with existing mill. Flood zone 2/3. Several applications over late 2000s failed to result in delivery. No clear evidence site is viable.

Comment

Representation ID: 29938

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

A significant proportion of the city centre sites carry risk and if relied upon Bradford may not be able to deliver the quantum of housing envisaged. Our summary assessment of these sites is set out below (Table 1 – Savills City Centre Housing Supply Site Assessment):

CC10/H - Heritage/ severe build cost implications with existing properties. No applications have come forward despite several property cycles.

Comment

Representation ID: 29939

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

A significant proportion of the city centre sites carry risk and if relied upon Bradford may not be able to deliver the quantum of housing envisaged. Our summary assessment of these sites is set out below (Table 1 – Savills City Centre Housing Supply Site Assessment):

CC12/H - Site involves existing car park/ listed buildings on-site with build cost implications. Council-owned in part with leaseholders/ freeholders across the wider site. No applications have come forward. No clear evidence site is viable.