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

Support

Representation ID: 29950

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

We agree with the Council’s conclusions that exceptional circumstances do exist which justify and require a change to the general extent of the Green Belt as set out in the Plan.

Comment

Representation ID: 29951

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

We agree with the Council’s conclusions that exceptional circumstances do exist which justify and require a change to the general extent of the Green Belt as set out in the Plan.

In the interests of effective planning the Local Plan will need to retain flexibility now within its strategic policies and in order to respond to potential housing land supply shortfalls over the plan period. It may be that more advantageous, sustainable sites exist for example where the five purposes of the Green Belt is weak as opposed to poor performing countryside and brownfield sites.

Object

Representation ID: 29952

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

We welcome mention of the South East Bradford Access Road (SEBAR), however note that this is only included within the pretext and not within the policy itself. The policy should be more explicit to mention the committed South East Bradford Access Road and given it is still an aim of Bradford further detail provided on the projected route.

Object

Representation ID: 29953

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

Safeguarded land

We would recommend the inclusion of Safeguarded Land within Policy SP5 or as a dedicated policy on Safeguarded Land, as detailed as a reasonable alternative. Safeguarded land is essential, particularly in BMDC where the Green Belt boundaries once set are to be of permanence in accordance with NPPF paragraph 136. Again, Bradford is a heavily contained Green Belt authority with 66% coverage.

While we note BMDC’s conclusions that there is not sufficient evidence to include safeguarded land it is important to have an effective mechanism to allow development in accordance with the link road, as was originally envisaged. This is fundamental given the revised standard methodology requiring 2,300 dpa (see comments in respect of recommendation 4) which counter’s the council’s own evidence base on the need to allocate sufficient, flexible land.

By not including safeguard land associated with the committed SEBAR there creates inflexibility in the plan constraining development which would alongside the SEBAR provide regeneration to the Holme Wood area as set out within the Vision Document at Appendix 2. The piecemeal allocation of c. 297 new homes without allocating or, as a minimum, safeguarding the wider site misses the opportunity for comprehensive regeneration.

Recommendation 3: Include Safeguarded Land in respect of the SEBAR and Holme Wood urban extension, setting a boundary across the entire site to build in flexibility over delivery over potentially multiple plan periods in the interests of effectiveness and positive plan making.

Object

Representation ID: 29954

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

Housing Need and Requirement

Having regard for the New Standard Methodology, the 35% cities and urban centres uplift equates to an additional 596 homes per year within the Bradford District and creates a ‘policy on’ housing need figure of 2,300 new homes per year. This is a significant increase from the 1,704 proposed within policy SP8. It is therefore a matter of national policy that the local authorities with the 20 largest urban areas meet these new figures. We understand this is not optional.

Recommendation 4: The Council implement the 35% uplift as set out by MHCLG. BMDC should therefore adopt a housing target of at least 2,300 dpa in the interests of NPPF compliant, justified and positive plan making. We understand this is not optional.

Recommendation 5: The Council should review its evidence base to understand and adopt a ‘policy on’ housing figure to align the ambitions of the Leeds City Region Growth Strategy, in the interests of justified and positive plan making.

Object

Representation ID: 29955

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

Housing Distribution - Bradford SE

Within Schedule 1 of Policy SP8 we note the level of housing distributed to the South East of Bradford has reduced from 4,000 dwellings within the adopted Core Strategy to 3,030 in the 2019 Core Strategy Partial Review and now to 2,200 dwellings.

We note this is partly as a result of the significant levels of growth attributed to Bradford City Centre which is a risk as we have detailed elsewhere.

The Core Strategy Review was predicated on 1,704dpa and as paragraph 5.32.21 lists there is a
comprehensive evidence base which has led to the 3,030 figure. It is unclear why the 2021 plan has now changed to derive a lower figure still, despite the risk in overlying on city centre sites and need to effectively meet regeneration objectives vs. the availability of developable sites such as reference SE/163. Draft 2021 Plan Paragraph 5.3.21 – 5.3.23 offers no explanation in the way 5.32.21 and therefore can only be regarded as unsound.

Recommendation 6: Provide greater evidence base justification for the reduction in housing targets for South East Bradford, in the interests of effective plan making.

Comment

Representation ID: 29956

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

While we welcome the modest allocation of our client’s land in respect of Holme Wood North, we are disappointed to see that the full extent of the Holme Wood Extension has not been allocated for housing.

Comment

Representation ID: 29957

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

While we welcome the modest allocation of our client’s land in respect of Holme Wood North, we are
disappointed to see that the full extent of the Holme Wood Extension has not been allocated for housing.

Comment

Representation ID: 29958

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

While we welcome the modest allocation of our client’s land in respect of Holme Wood North, we are
disappointed to see that the full extent of the Holme Wood Extension has not been allocated for housing.

Comment

Representation ID: 29959

Received: 24/03/2021

Respondent: Harworth Group PLC

Agent: Rob Moore

While we welcome the modest allocation of our client’s land in respect of Holme Wood North, we are disappointed to see that the full extent of the Holme Wood Extension has not been allocated for housing.