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

Object

Representation ID: 18380

Received: 24/03/2021

Respondent: Johnson Mowat

No objection to the overall hierarchy of settlements but concerns over the over dependency on the the Regional City and the disproportionately low proportion of new dwellings to be delivered across settlements outside the Regional City.

Wording changes are suggested:

Under Principal Towns - omit the word 'local' - re-word to "Outside of the Regional City, Ilkley, Keighley and Bingley will be the main focus for housing and employment growth, shopping, leisure, education, health and cultural activities and facilities’.

Support for the indication that Local Growth Centres should ‘make a significant contribution to meeting the District’s needs for housing, employment and provide for supporting community facilities’.

For local service centres omit the phrase 'smaller scale' -and re-word to ‘Within the Local Service Centres… the emphasis will be on a smaller scale of development comprising both market and affordable housing appropriate to the particular location, together with…’

Object

Representation ID: 18381

Received: 24/03/2021

Respondent: Johnson Mowat

In line with the NPPF it is correct that release of Green Belt is identified as a third priority after the allocation of land within settlements.

However, it is queried what ‘sustainable greenfield opportunities’ actually means and consideration should be given to revising this wording to remove ambiguity.

For these reasons, part A/2 of draft Policy SP4 should be amended to read: ‘Second priority to greenfield land located within and around the settlements where sustainable development can be achieved’.

To reflect NPPF paragraph 137 part A/3 of draft Policy SP4 should be amended to read:

‘Third priority to the release of Green Belt land in order to meet the remaining identified development need in full and as set out under Policy SP5’.

Object

Representation ID: 18382

Received: 24/03/2021

Respondent: Johnson Mowat

Johnson Mowat agrees that there is an ‘acute and intense need for housing (market and affordable)’ and a ‘shortage of alternative sites’ (i.e. insufficient capacity within non-Green Belt sites to meet the identified housing need).

Johnson Mowat supports the Council’s assessment that exception circumstances exist (as required by national policy) to allow the release of Green Belt land and the allocation of this for development.

In accordance with our comments made in relation to meeting identified need in full (see draft Policy SP8 below)) Johnson Mowat objects to the list of sites set out within parts B of draft Policy SP5 as the development achievable from these is either insufficient in total or inappropriate in other regards (as applicable) such that a revision to the lists is required. This is likely to require the addition of further sites to the lists and the removal of certain sites already listed.

Object

Representation ID: 18383

Received: 24/03/2021

Respondent: Johnson Mowat

Housing Requirement

The proposed 1,704 dwellings / annum is a substantial reduction compared to the Council's 2017 position tested in examination i.e. 2,476.

HBF calculates minimum housing need (standard methodology) to be 1,699. The additional 35% uplift to be applied to minimum need for Bradford (and other large urban areas) is a central Government requirement and not an option for a LA to accept or reject. It is inappropriate to reject this as the Council has done in paragraphs 3.8.11 and 3.8.12

The identification of ‘strategic constraints (Green Belt)’ as a reason not to apply the uplift is unacceptable.

PPG indicates this increase / uplift is expected to be met by the cities and urban centres themselves, rather than the surrounding areas’. i.e. the uplift should not be met by substantial additional allocation of land in rural areas or lower order settlements.

However, the allocation of additional green belt land abutting the main urban areas is appropriate.

Part A of Policy SP8 should be amended to:

‘The Local Plan will seek to deliver a housing requirement of 41,407 new homes over the plan period 2020-2038, equating to an indicative average of 2,300 new dwellings per annum.'

Object

Representation ID: 18384

Received: 24/03/2021

Respondent: Johnson Mowat

Housing Distribution - Bradford City Centre

The proposed spatial distribution places an over-reliance on the city centre. We have no objection to ambitious levels of housing growth within the city centre in their own right, provided these are realistic, deliverable. However a realistic view must be taken on the underlying social and economic changes that are required to achieve this.

We object to the use of a high target number for the city centre to justify unduly low or reduced target numbers in other locations.

Given the requirement for a broad mix housing types and locations, additional allocations should be made across all settlements.

An alternative distribution is proposed derived by:
- applying the adopted Core Strategy proportions to the Local Housing need (excluding 35% uplift).
- adding and distributing the 35% uplift to the Regional City including retaining the City Centre focus;
- making various adjustments.
- allocating additional land accordingly to accommodate the increased targets;

Object

Representation ID: 18385

Received: 24/03/2021

Respondent: Johnson Mowat

Previously Developed Land

Johnson Mowat supports the Council in making as much use as possible of previously developed land (PDL) in accordance with NPPF.

However, we consider that it is important to ensure that the prioritisation of PDL does not compromise the delivery of sufficient homes in sustainable locations to meet identified needs.

We therefore query whether the proportions indicated within part H of the draft Policy are realistic and achievable, particularly given the assumptions relating to density and demand/values/viability that this will depend upon to deliver large numbers of dwellings within the inner urban and post-industrial areas.

It is therefore considered that the proportions indicated are presented as targets with a degree of flexibility.

Object

Representation ID: 18392

Received: 24/03/2021

Respondent: Johnson Mowat

With reference to part A of draft Policy TR3, Johnson Mowat queries what ‘Applicants will be expected to adhere to Healthy Streets and 15 Minute Neighbourhood Principles’ means in practice and how this should be interpreted in the determination of planning applications.

It is suggested that this sentence is revised as follows to reflect support for the principle rather than an expectation of adherence which is likely to be beyond the influence of particular applicants for planning permission:

‘Developments that adhere or contribute to Healthy Streets and 15 Minute Neighbourhood Principles will be supported'

Object

Representation ID: 18393

Received: 24/03/2021

Respondent: Johnson Mowat

With reference to Table 1 and the following paragraph, Johnson Mowat objects to the category description of any development other than that categorised as ‘Zero-Car’, ‘Traffic-Free’ or ‘Car-Light’ as ‘Unsustainable’. The sustainability of any development depends upon a range of social, environmental and economic factors. It is not appropriate to define a category of development as ‘unsustainable’ in outright terms when consideration is given only to location and parking provision.


Johnson Mowat is concerned that the inclusion of unduly low parking standards in the draft Plan and the application of these in practice risks causing problems of on-street and inconsiderate parking including damage to landscape planting and verges etc. Parking provision should be carefully considered at the planning application stage in the particular context of the development proposed.

Object

Representation ID: 18394

Received: 24/03/2021

Respondent: Johnson Mowat

Johnson Mowat supports and endorses the position of the Home Builders Federation as set out in its representations regarding draft Policy HO1.

In particular, the Plan must allocate a sufficient range of sites to provide enough sales outlets to enable delivery to be maintained at the required levels throughout the plan period.

Policy SP8 should adopt a higher requirement and accordingly, it will be necessary to allocate additional sites under draft Policy HO1.

As indicated above, separate representations are submitted on behalf of individual clients in relation to particular sites and locations which will assist the Council in identifying additional sites.

Object

Representation ID: 18395

Received: 24/03/2021

Respondent: Johnson Mowat

Johnson Mowat supports and endorses the position of the Home Builders Federation as set out in its representations regarding draft Policy HO4.

In particular, it is important that a flexible approach is taken regarding housing mix which recognises that needs and demand will vary from area to area and site to site; ensures that the scheme is viable; and provides an appropriate mix for the location and market.